Jackie considered herself to be a great lab tech. She was proud that she followed the rules of the department, especially the safety regulations. Jackie just knew she would have an exciting career that would be free from any lab exposures or incidents, and her proper use of PPE would ensure that she didn’t bring any pathogens home, either. Jackie knew face protection was important, but she did not really consider it when loading racks of specimens onto the chemistry analyzer. She always popped the caps off of the tubes using a counter-mounted shield, but when carrying the rack of open tubes, she didn’t think there was any danger. Her manager discussed this at a staff meeting, so Jackie began to wear goggles in the chemistry department. After one week, a rack slipped out of Jackie’s hand as she was talking to a co-worker. The bottoms of the tubes bounced on the top of the analyzer, and serum from multiple specimens splashed into Jackie’s mouth.
Joseph worked the night shift in the Histology lab, and he was responsible for changing out many chemicals in containers and processors throughout the shift. Since there was no management hanging around, Joseph was not attentive to the safety regulations regarding PPE. He wore a knee-length lab coat, but he left it unbuttoned and rolled up the sleeves. He wore mesh sneakers, too, since no one would see him and he felt they were more comfortable. One night, Joseph was changing a formaldehyde container on the counter. On the floor below was an open carboy of waste formaldehyde. As Joseph turned, an unbuttoned snap on his open lab coat caught on the lip of the carboy. The carboy tipped over and formaldehyde spilled all over Joseph’s sneakers. He began to panic as the chemical soaked into his socks.
When it comes to the best use of Personal Protective Equipment (PPE) in the lab setting, sometimes the regulations spell things out very clearly. Other times, there may be room for interpretation, and if the wrong decision is made, harm can come to employees. Sometimes lab staff need to understand the regulations, but they also need to apply a best practice to them as well.
Many of the safety rules regarding PPE in the lab come directly from the law. Lab accreditation bodies may set standards as well, and that’s important, but laboratorians sometimes forget that there are actual legal regulations behind many safety and PPE practices. Many requirements for the use of PPE in the laboratory come from OSHA standards.
After the OSH Act was made law in 1970, the organization began creating safety laws which are published in the Federal Register. After extensive public review sessions, the final rules are sent to the U.S. Congress and the Government Accountability Office (GAO). Laboratorians are very familiar with some of these laws or standards; the Bloodborne Pathogens standard, the Chemical Hygiene standard, the Hazard Communication standard, the Formaldehyde standard, and more. OSHA expects that employers will follow these safety regulations, and they enforce them via inspections, investigations, and penalties.
By the letter of the law, Joseph did not do what he should have done. He wore PPE, but he wore it incorrectly, and he wore the incorrect shoes for work in a lab setting. If the accident he caused had elicited an OSHA investigation, there would likely be a citation. The employer did not ensure that safety regulations were being followed. Joseph could lose his job, and the organization could face heavy penalties.
By the letter of the law, Jackie followed the regulations, but she still suffered an exposure. OSHA’s standards state that face protection should be used when there is a risk of splash exposures. Jackie wore goggles which are considered adequate. However, if Jackie is going to talk or open her mouth while working with samples (as many of us would do), then perhaps a full-face shield would have been a better choice for her. The laws were written to protect her, but in this case, there was more that could be done, a better safety practice.
When it comes to lab safety, knowing the laws is an important first step for both leadership and staff. Following the laws - those safety regulations - is also key. Lab leaders and safety professionals have a vital role to ensure staff are doing what is best; following those laws and doing so in a way that best protects them from harm. If everyone is looking out for safety, then labs can complete the mission begun by OSHA over 40 years ago- keeping our laboratorians from injury and exposure. It’s a good common goal.