BBP

            BBPs or Blood borne Pathogens and disease spreading microorganisms that are present in human blood. These pathogenic microorganisms have the ability to cause diseases in humans that include Hepatitis B, Hepatitis C, and Human Immunodeficiency Virus. During the semester, our class had the opportunity to tour a lab on campus that does blood work. The lab was located in Grover Center and the professor, Dr. Kushnick was gracious enough to give us the tour of his lab. Once everyone from our class was in the lab, Dr. Kushnick gave us a quick rundown of the work that the students did in his lab and the work they do for OU’s Exercise Physiology Program.

            While going through the lab, Kushnick pointed out various safety checks that he had in place throughout the lab. One of the first ones he pointed out was the cover that was installed on the centrifuge to prevent aerosolizaiton of any blood samples that may have broken in the centrifuge. The next feature he pointed out was the absorbent material that is placed over the main table in the lab. This absorbent material has an absorbent top layer and a plastic layer underneath to trap any liquid that has been spilled on it so the material is easily replaced.

            When looking around the rest of the lab, many things caught my attention, both good and bad. For the bad things, was the fridge that was located in the lab. The fridge itself was just a standard commercial fridge that you could buy at Lowe’s or Best Buy, not the kind required to hold the material that was being stored in it. The next thing was the lack of a proper storage cabinet for chemicals in the lab, but as Kushnick described it, there wasn’t enough money in the budget for one and how he had his chemicals stored in the lab worked for his needs, so he didn’t get into to trouble for it. Probably one of the biggest ‘bad’ things that caught my attention were the old lemonade and juice containers being used as liquid waste storage containers. These jugs had a skull and crossbones on them, but the symbol was small and incredibly faded to the point to where you couldn’t see it.

            When it came to the students in the lab, it is important to note that they will still fall under OSHA protection as an employee. Hence, it is required that they be trained in how to handle blood and working in this lab gave those students the opportunity to improve those skills. All unknown infectious materials when working in a blood lab need to be treated as though they are contaminated with HIV, HBV, or other blood borne pathogens. A good place to start with that is to have engineering controls in place such as sharps containers throughout the lab and fluid resistant barriers used efficiently in the lab. Work place habits such as hand washing are heavily enforced in the lab as there are signs and postings all over the lab and near sinks.

https://www.ohio.edu/riskandsafety/docs/bbp_prog2010.pdf

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10051

Process Safety Management

           Process Safety Management came about in 1992 due to horrific and catastrophic incidents that were occurring around the world that came about as a result of unintended releases of highly hazardous chemicals, or HHCs.  For Process Safety Management, you have fourteen important parts for it to work correctly. 

            Process Safety Information, Process Hazard Analysis, Operating Procedures, Training, Contractors, Mechanical Integrity, Hot Work, Management of Change, Incident Investigation, Compliance Audits, Trade Secrets, Employee Participation, Pre-startup Safety Review, and finally Emergency Planning and Response. Employee Participation is probably the shortest of all the elements, but has the biggest impact. According to CFR 1910.119, employers need to develop a written plan of action regarding the implementation of employee participation. Essentially employees, production, maintenance, and any other staff are to be involved in all aspects of the PSM program. 

            Process Safety Information is considered one of the most concentrated, maintenance-specific listings of all the elements. In CFR 1910.119, it is stated that the employer shall complete a compilation of written process safety information before conducting any process safety hazard analysis. Process Hazard Analysis is one of the more technical elements, and even includes a what-if evaluation. In the CFR, it states that the process hazard analysis needs to be appropriate to the complexity of the process and needs to identify, evaluate, and control the hazards involved in the process. 

            Operating procedures seem like an oversight by many people, but the element itself has a few items to take note of. In cases of physical contact or airborne exposure, control measures are to be taken after startups following a turnaround or an emergency shutdown. The Training element specifically addresses the needs for those during a process operation. Maintenance technicians need to be fully trained for all the functions they are performing, and the training needs to be accomplished through a competent source and very well documented. Contractors can provide a plethora of opportunities to trip an otherwise healthy and well-executed maintenance strategy.

            Pre-Startup Safety Reviews are important reviews that need to take place before any highly hazardous chemical is introduced into a process. With the PSM, it requires the employer to perform a pre-startup safety review for new facilities and for modified facilities when the modification is significant enough to require a change in the process safety information. Mechanical Integrity is something that OSHA believes is important to maintain. The integrity of critical process equipment is important to ensure it is designed and installed correctly and operates properly. Hot Work Permits are issued for hot work operations conducted near or on a covered process. The permit must document that the fire prevention and protection regulations have been implemented prior to beginning the hot work operations, the date or dates authorized for the hot work, and the identity of the object on which the hot work is to be performed. 

            

            One of the other most crucial elements of PSM is Incident Investigation. Incident Investigation is a thorough investigation of any incident to identify the chain of events and causes so that corrective measures can be developed and implemented. PSM requires the investigation of each incident that resulted in, or could reasonably have resulted in, a catastrophic release of a highly hazardous chemical into the workplace. 

https://www.safetyinfo.com/guest-library/materials/process-safety-management-elements-psm

http://www.plantengineering.com/single-article/the-14-elements-of-osha-inspections-how-they-affect-maintenance-processes/124d9efb4bf664edbf59804775c72cc1.html

https://www.osha.gov/Publications/osha3132.html#psi

Hazardous Waste Disposal

            When it comes to Hazardous Chemical Waste Storage and Disposal on Ohio University’s campus, there’s a process that must be followed. Generally there are two situations in which chemicals are required to be picked up on OU’s campus. The first being hazardous laboratory chemical waste and the other being unwanted chemicals.

            Storage of the hazardous laboratory chemical waste may sound like a lengthy process, but in fact in only involves a small number of steps. The first step is to identify the waste stream, which is done by determining if the chemical is hazardous or non-hazardous as defined by the E.P.A. This can usually be determined by looking at the MSDS or SDS for the chemical.  Selecting a container for waste collection does this and ensuring the waste does not weaken or destroy the container. The container must also have a sealable lid. This container is then placed in a secondary containment device, such as a tray or dish to collect spills. This secondary container must be able to contain the volume of the primary container. The next crucial step is to prevent the mix of hazardous and non-hazardous wastes.

Steps 4, 5, and 6 are the steps that require the hazardous material to be placed in the primary and secondary containment, labeled correctly with the provided hazardous waste labels, then correctly placed in a location for the EHS Hazardous Materials Manager or his student workers (myself and one other) to be picked up and moved to the Hazardous Waste Storage Area. Steps 8 and 9 are the steps taken to have the Hazardous Materials Manager or his student workers to come and pick up the chemical waste. During Step 8, a Chemical Waste Disposal form will have to be filled out and sent directly to the HMM, or through the campus mail to Hazardous Materials Manager, EHS, University Service Center. Step 9 is done to help the Hazardous Materials Manager identify the characteristics of the waste for proper storage and eventual pickup by a contractor for disposal. If there were to be any problems during the steps, the person with the waste is given the number for the Hazardous Materials Manager for assistance.

            So then what happens when the chemical is unwanted? The same process takes place. Identify the hazards in the chemical by using the MSDS or SDS, label the chemical correctly, fill out a Chemical Waste Disposal form and send it in, and then finally the Hazardous Materials Manager will come and pick up the chemical. If the chemical is a hazardous waste, it will be placed in the correct storage area on campus and stored there until a contractor comes and picks up the chemical to be disposed of properly. If the chemical is not a hazardous waste, it will be disposed of based on the physical state of the chemical. Liquids will be poured down the sink with copious amounts of water to dilute it and solids will be thrown away in the trash and go to the landfill.  

https://www.ohio.edu/riskandsafety/ehs/environmental/hazmat/chemical.htm

Hazards in the Laboratory

            When people hear the words ‘laboratory hazards,’ the most commonly thought of thing are chemical hazards due to the core belief that every lab has dangerous chemicals in it. This maybe the case for a lot of labs, but chemical hazards aren’t the only dangers found in laboratories. There are three other hazards to look out for in laboratories, and they are physical hazards, biological hazards, and electrical hazards. Other hazards that can be found in labs can include mechanical hazards and radiation hazards, but these are found in more high-end laboratories.

            Chemical hazards are usually found in most labs, and as a result, OSHA has developed two different standards to handle chemical hazards in the lab. The first standard, which is known as the Hazard Communication standard or 29 CFR 1910.1200 and the second is known as the OSHA Lab Standard or 29 CFR 1910.1450. The main focus of 29 CFR 1910.1200 or Hazard Communication is to make sure that any hazards of all chemicals produced or imported are evaluated and all details regarding their hazards are transmitted to employers and employees.  This is done through the Safety Data Sheet or SDS. The HCS requires all chemical manufacturers, distributors, or importers to provide the Safety Data Sheets to communicate the hazards of hazardous chemical products. By June 1, 2015, new SDSs will be required to be in a unified format, include section numbers, headings, and associated information listed in order given by the HCS. The second standard is 29 CFR 1910.1450 or the OSHA Lab Standard, which supersedes any previous OSHA standard related to lab safety, meaning identifying hazards, determination of employee exposure, and the development of a chemical hygiene plan.

            Biological hazards include things like microbes, recombinant organisms, and vectors. Biological agents introduced to experimental animals are also considered a biological hazard. When dealing with biological hazards, there are many key ways to keep exposure to a minimum and reduce the chance of infection, injury, or even death. These will include warning signs, separated working areas in the lab, PPE, safety cabinets, decontamination areas, and the biosafety levels.

            Physical hazards will include things like electrical safety hazards, ergonomic hazards, sharp objects, and even housekeeping issues. Lab operations can result in workers assuming continued or even repetitive postures that can result in injuries to the eyes, back, hands, and neck. Pain is a good indicator that something is wrong and a posture change should be encouraged. Sharps containers are found all over laboratories and following some safety rules can reduce the chance of injuries and infections. Sharps containers should be puncture-proof and prevent leaks. The containers themselves should clearly labeled as sharps containers, never have their covers removed or have the contents transferred to another container. When the container becomes three-fourths full, it should be replaced with an empty container. Finally, housekeeping issues can prevent things like slips, trips, and falls in the lab. Safe and organized storage areas are a great place to start with. Material storage shouldn’t be creating hazards in the lab either. Bags, containers, and bundles should be stacked, blocked, and limited in height so that they are in a stable condition and can’t slide or fall.

            The last main hazard in laboratories comes from electrical hazards. Electrical hazards can be incredibly life threatening and are found way too often in labs. All outlets in a wet location should be equipped with ground-fault circuit interrupters to prevent accidental electrocutions. GFCIs are designed to trip and break the circuit when a small amount of the circuit begins to flow to ground. Wet locations are often located within six feet of a sink, faucet, and any other source of water or outlets located outdoors or in areas that get washed down frequently. Another common electrical hazard is the use of extension cables. These should not be used instead of permanent wiring. If an extension cord has to be used, make sure that the cord insulation is in good condition and never repair cracks, breaks, cuts or tears with tape. Either discard the extension cord or shorten it by installing a new plug end. Make sure not to run extension cords through doors or windows where they can become pinched or cut, and always be aware of any potential tripping hazards that the cords can create. Never remove the grounding pin from an extension cord as well and never use extension cords in series, just use the right length of cord for the job.

https://www.osha.gov/Publications/HazComm_QuickCard_SafetyData.html

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10106

https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=standards&p_id=10099

http://www.labmanager.com/lab-health-and-safety/2011/09/laboratory-hazards-and-risks#.Vspjcceih-g

http://www.safety.uwa.edu.au/topics/biological/hazards

OSHA Lab Standard vs. Other OSHA Standards

The main purpose of the OSHA Laboratory Safety is to supersede and build upon already existing OSHA standards. The primary being the General Duty Clause, which requires an employer to provide it’s workers with a safe work environment free from recognized hazards that are likely to cause injury or death. It also requires employees to comply with occupational safety and health standards and all rules issued that are applicable to their own actions and conduct. The OSHA Lab Standard also covers many other OSHA regulations that covered Hazardous Substances, Protection of Other Personnel In Laboratories, Hazard Communication, Resource Conservation and Recovery, and Definition of a Generator under RCRA.

Regarding “particularly hazardous substances’, you are talking about substances including select carcinogens, reproductive toxins, and substances with a high degree of acute toxicity. In order for a chemical to be classified as a carcinogen, it needs to meet of the following criterion; 1) regulated by OSHA as a carcinogen, 2) listed as ‘known to be a carcinogen’ in the Annual Report on Carcinogens published by the National Toxicology Program or NTP, 3) listed under Group 1 or ‘carcinogenic to humans’ by the International Agency for Research on Cancer, or finally 4) listed in either Group 2A or 2B by IARC or under he category ‘reasonably anticipated to be carcinogens’ by NTP in some cases.

A reproductive toxin is defined as chemicals that affect reproductive capabilities, including chromosomal damage or mutations and effects on fetuses. Chemicals with a high degree of toxicity also require special provisions for worker health. ‘Select carcinogens’, although are specifically identified through reference to other publications, ‘reproductive toxins’ and chemicals with a ‘high degree of acute toxicity’ are not specified further, which has made it more difficult to apply these categories. Some institutions have chosen to adopt the OSHA Hazard Communication Standard definition of ‘highly toxic’, or an LD₅₀ < 50 mg/kg oral dose as a workable definition of  ‘high degree of acute toxicity’. There is little to no agreement on how to determine reproductive toxins.

When handling or working with carcinogens, reproductive toxins, and substances that have a high degree of acute toxicity, consider the use of designated areas, containment devices, special handling of contaminated waste, and decontamination procedures. The OSHA requirement is for evaluation, assessment, and implementation of these special controls when appropriate.

The Resource Conservation and Recovery Act, or RCRA. RCRA was enacted by congress in 1976to address the problem of waste disposal and reduction. Subtitle C of RCRA established a system for controlling hazardous waste from generation to disposal. This is referred to as the ‘cradle to grave’ system. The cradle, however, is the point at which the hazardous material first becomes a ‘hazardous waste’, not when it is first received a laboratory. Under RCRA, the Environmental Protection Agency is given great responsibility in promulgating detailed regulations governing the generation, transport, treatment, storage, and disposal of hazardous waste. RCRA and EPA regulations were written with a focus on industrial-scale generation of hazardous waste, but, with very limited exceptions, they also apply to laboratories that use chemicals.