The Quarterly Site Assessment Summaries (QSAS) communicate, at the department and college level, high-risk deficiencies noted during the annual research safety inspections that have not been addressed by the Principal Investigator.
General Laboratory Safety Items
Training Completed and Documented
Recommendation
Employee training must be documented and filed with the Chemical Hygiene Plan. Training includes but is not limited to the Lab Standard, Building Emergency, laboratory-specific SOPs, and relevant EHS online training.
Resources
Standard Operating Procedures (SOP) and Safety Data Sheets (SDS)
Recommendation
Standard Operating Procedures (SOP) are required by OSHA's Laboratory Standard 1910.1450. It states that the Chemical Hygiene Plan must contain “Standard Operating Procedures relevant to safety and health considerations to be followed when laboratory work involves the use of hazardous chemicals.” Lab-specific SOPs are to be included in the laboratory Chemical Hygiene Plan (CHP). SOPs must address appropriate personal protective equipment, containment devices, decontamination procedures, and waste disposal procedures. SOPs from other laboratories, departments, or institutions may be used as a guide only, but they must be reviewed and edited to be specific to your laboratory procedures and Ohio State regulations. EHS has developed SOP templates for many commonly used chemicals and hazardous operations that can be modified easily to include lab-specific information. Safety Data Sheets (SDS) provide employees with detailed information about hazardous chemicals. Information found on SDS documents can include but is not limited to the following: product name, CAS numbers, ingredients, handling precautions, type of PPE recommended, physical and health hazards, storage requirements, emergency and first-aid procedures, contact information of the chemical manufacturer or the importer. Copies of SDS for all hazardous chemicals must be available to employees. Hard copies may be kept in the lab, or SDSs may be accessed via the online ChemWatch system, but all employees must know how and where to access the information.
Resources
Engineering Controls (Use & Maintenance)
Recommendation
Engineering controls, such as chemical fume hoods or gas cabinets, should be used to prevent and mitigate hazards whenever feasible. The type of controls installed should be appropriate for the laboratory application or process. Hazards can change with time, so it is important that engineering control systems be continually reviewed and updated, if necessary. Overall maintenance should be performed annually. Whenever a change in local ventilation device is made or repairs to fume hoods are necessary, the ventilation devices should be reevaluated for proper function. If used, gas-specific sensors or alarm systems should be tested, calibrated, and replaced per the manufacturer’s recommendations. Documentation of maintenance of laboratory engineering controls should be kept in the lab and made available upon request (i.e., fume hood test sticker, alarm calibration reports, etc.). When operators are away from fume hoods, the sash should be closed. Sash operation should be unhindered by cords, tubing, or equipment. Fume hood baffles and slots should be unobstructed (no more than 25% obstructed). When operators are using a hood, the sash should be positioned to shield the operator.
Resources
Eating or Drinking in the Lab
Recommendation
Enforce policies of no smoking and no food/drink in the lab. Eating, drinking, gum chewing, and cosmetic application (i.e., hand cream) are not permitted in the laboratory. Food shall not be eaten or stored in places where chemicals or biological materials are being used or stored. Employee break or lunchrooms shall be identified in the department or located outside of the laboratory.
Resources
Machinery & Equipment Guards
Recommendation
Machine guards shall be provided and in use for mechanical equipment posing a potential hazard to those operating the equipment.
Resources
Personal Protective Equipment (PPE)
Recommendation
Personal protective equipment must be available and accessible to employees, appropriate for the hazards found in the lab. The OSHA PPE Standard requires a hazard assessment be completed whenever PPE is necessary. Personnel are responsible for knowing the location and proper use of the PPE they are required to use (i.e., appropriate eye protection must be worn by lab occupants whenever warranted by laboratory conditions or hazards, and lab coats should be worn whenever handling liquids or powders that are injurious to the skin or absorbed through the skin, etc.).
Resources
Respiratory Protection
Recommendation
Employees who use respirators or protective masks must be registered with the Ohio State Respiratory Protection program. OSHA and Ohio State have established procedures for using respiratory protective equipment. To use this type of PPE, you must have a medical evaluation to determine whether you can use this type of equipment effectively, be trained, and fit-tested. Call EHS at 614-292-1284 for details.
Resources
Details
Biosafety Items
Protocols in Place
Recommendation
PI must have currently approved IBC protocols for all recombinant and synthetic DNA and biohazard work. It is the PI's responsibility to ensure that all personnel are aware of and can access all approved protocols (IBC, IRB, IACUC) for which they are listed as study team or key personnel and SOPs describing procedures using biohazards and necessary precautions. All biohazard work and recombinant or synthetic DNA work must be submitted to the Institutional Biosafety Committee for review using the online eProtocol system at the link below.
Resources
Training Completed and Documented
Recommendation
Lab supervisor must provide lab personnel with adequate training regarding their duties, the necessary precautions to prevent exposures, and exposure evaluation procedures. Personnel should receive updates annually and when procedural or policy changes occur. All lab personnel, including females of child-bearing age, shall be provided with information regarding immune competence and conditions that may predispose them to infection. All personnel with access to BSL2 areas shall take BSL2 training. If applicable, document that personnel working with human blood or other potential bloodborne pathogens (including human cell lines, tissues, and animal materials intentionally infected with human pathogens) receive bloodborne pathogen training on an annual basis.
Resources
Engineering Controls (Biosafety)
Recommendation
Biosafety cabinets and/or other appropriate containment and protective devices must be used to contain aerosol-producing activities (e.g., opening containers with non-ambient pressures, intranasal inoculation of animals, pipetting, shaking or harvesting of infected tissues), aerosol-producing equipment (centrifuges, safety cups, blenders, shakers), and when using high concentrations or volumes of organisms.
Resources
Personal Protective Equipment (Biosafety)
Recommendation
Protective clothing (PPE) must be worn while working with hazardous materials. Glove selection shall be based on an appropriate risk assessment. Eye protection, appropriate for the anticipated hazard, shall be worn in the lab. Personnel must remove PPE before leaving the laboratory. PPE must be discarded properly after use or is laundered by the institution. PPE shall not be taken home by personnel. If sent offsite for laundering, it is properly bagged, and the laundry facility is notified of potential contaminants.
Resources
Open Deficiencies from Previous Inspection
Acceptable responses to all items outlined during the previous year’s inspection are documented in EHSA.
Recommendation
All corrective action plans must be received for deficiencies found during the previous year’s inspection. Corrective action plans should be submitted using the EHS Assist (EHSA) system within 15 calendar days. The EHSA system is necessary for documenting and providing a means of communicating to the status of pending action items. Items considered to be a significant risk are required to be reviewed by the designated inspector. Once all action items have been completed, the PI will receive an email indicating the inspection is considered closed.
Resources