The Safety Interpretation
The Safety Interpretation

When hospitals were placed on OSHA’s list of “high-risk” work places, no one had to ask why. OSHA adjusts that list based on the number of injuries that occur on the job each year in specific industries, and the rising number of hospital incidents over a couple of years made the regulatory agency take notice. Their purpose, after all, is to ensure the protection of employees in unsafe working conditions. Being placed on the “high-risk” work place list simply means that hospitals are now more frequently going to be inspected by OSHA without cause. That means labs across the nation will be visited as well – and many have been.

OSHA inspectors undergo very specific training, and if they will become healthcare inspectors, they are given detailed instruction about the regulations they are asked to oversee. The Bloodborne Pathogens standard, the Chemical Hygiene standard, and the Respiratory Protection standard are just a few that inspectors need to study in order to properly inspect for laboratory compliance.

If you read through any OSHA standard, it is easy to identify some practices that must occur in the work place. Others, however, are more difficult to see, and they may need interpretation or guidance from other safety agencies or guidelines. For example, the Bloodborne Pathogens standard (BBP) states that protective lab coats must be worn in the laboratory setting. The standard does not define “protective,” but an inspector coming into the lab will not be satisfied if cotton or cloth lab coats are used. They will know those materials do not protect against splashed of blood or body fluids. If you search NIOSH documents, you can see specific types of materials that should be used for lab coats- materials that are protective against incidental splashes, materials that are fluid-resistant (in some special cases the material must be impenetrable).

The Bloodborne Pathogen standard clearly states that no food or drink should be inside the lab, but it makes no mention of gum chewing. It specifically states not to use lip balm or manipulate contact lenses in the lab, but there is nothing stating not to use a cell phone. Remember, one of the purposes of this standard is to minimize or prevent hand-to-face contact in a contaminated setting. It is clearly a best practice for many reasons not to chew gum or use a cell phone in a lab, but OSHA would view these practices as a violation of regulations even though it is not written directly. You can tell an OSHA inspector you put that gum in your mouth in the break room, but you couldn’t prove it, and it does not make chewing it in the lab acceptable.

The BBP standard is very specific about not wearing PPE outside of the lab if it was used inside the department. Signage for staff entering the lab is required as well. While the agency is concerned about the separation of clean and contaminated areas, there is no detail about how those areas should be divided. OSHA looks for a complete separation from floor to ceiling between clean and dirty areas. That means if there is a clean office, break room or rest room adjacent to the lab, there needs to be a closed door that separates the rooms (yes, a rest room for the lab should be considered a “clean” area and no PPE should be used there). If staff is stationed in a cubicle in the lab proper, that space should not be considered clean, so no food or drink should be consumed there, and the employee should at least wear a lab coat while working there.

Laboratory workers tend to be detail-oriented, and they prefer straightforward regulations with no interpretations needed. Unfortunately, many lab safety standards just aren’t that cut and dried. Having things open for interpretation can create difficulties, and OSHA even has a library of “letters of interpretation” to help. However, when in doubt, utilize the interpretation that follows the best practice- the practice that will keep you and your staff safe. Doing that can reduce staff injuries and help make the healthcare setting less of a high-risk work place.

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