In its white paper titled "Three Proven Strategies for Upgrading Your Laboratory Environmental Health and Safety Program," Newton, Mass.-based consulting firm Environmental Health & Engineering says that its audits of various laboratories have "identified three systemic root causes of the vast majority of compliance issues."
Those root causes are:
- Program organization and accessibility – Missing or outdated documents, permits, inspections and data collection requirements.
- Safety violations in laboratories – Including improper storage and labeling of chemicals; out-of-date chemicals; improperly maintained satellite accumulation areas; improper labeling; improper use of PPE; blocked aisles and exits; and inaccessible first aid and spill kits.
- Training deficiencies – The inability of organizations to adequately train employees and to maintain accurate training records as required.
The white paper acknowledges that EHS compliance programs "for any company or institution with laboratories are increasingly complex and challenging to maintain."
"For small and mid-size organizations that may not have a full-time safety officer responsible for keeping the program current, maintaining compliance is especially difficult," the white paper says. "Even the most basic program involves maintaining a variety of permits, performing regular employee training, conducting inspections, complying with a myriad of chemical storage and handling requirements and ensuring a number of contingency plans are current and complete." The white paper adds that "recordkeeping is a constant battle."
The strategies that Environmental Health & Engineering devised to address these three root causes are detailed below.
Improving Program Organization and Accessibility
According to the white paper, not having "a good program organizational mechanism" is a key reason why many laboratories have trouble keeping track of their various federal, state and local compliance requirements and deadlines.
Unable to find an EHS management system "that fully supported a laboratory operation," Environmental Health & Engineering designed a Web portal "that provides a single, centralized point of collection and access for all EHS program documents, data and activities."
Information is organized by compliance category, such as "Environmental Compliance," "Biosafety Programs" and "Fire and Life Safety."
The consulting firm notes that Microsoft Windows SharePoint provided an excellent platform on which to design the site. SharePoint "also offers a highly developed (and intuitive) user interface, compatibility with a wide variety of file types and basic project tools – including task lists, calendars and automatic e-mail notification of deadlines – and the ability to quickly add or modify program structure as required."
Among its benefits, the centralized Web portal "foster[s] a team approach within the organization for EHS program management and lessens the responsibility of any single person for overall program maintenance."
Expanding the Laboratory Inspection Program
To address the second root cause – which centers on inadequate laboratory upkeep and unsafe laboratory practices – Environmental Health & Engineering recommends a regular schedule of laboratory inspections.
While the firm points out that lab inspections "can be a valuable teaching mechanism if used properly," it also notes that the success of inspections can be limited if the lab does not have "a complete feedback mechanism to document corrective actions and to identify trends."
To improve the efficiency of lab inspections, Environmental Health & Engineering developed a laboratory inspection database using Microsoft Access software. The database "generates surveys, follow-up reports for laboratory managers and summary reports for EHS staff and institution management.
After the consulting firm implemented the database at a large research institution in Boston, "the result was a 50 percent reduction in documented deficiencies in the first year and a clear indication of which laboratories need more attention and which compliance issues need additional emphasis during classroom training."
According to the white paper, linking the lab inspection database with SharePoint allows stakeholders to view inspection results at any time through the Web portal – even if they are not familiar with Microsoft Access.
Taking a "Blended" Approach to Safety Training
To meet EPA and OSHA training requirements and to streamline staff efforts, Environmental Health & Engineering recommends a mix of Web-based and classroom instruction. The firm's recommended strategy has two components:
- Use Web-based programs to train employees on general – but required – safety topics such as bloodborne pathogens and hazard communication. Web-based training, the white paper points out, is convenient for employees – because it is easy to schedule – and provides automated management of training records.
- Use classroom training "to focus on site-specific and activity-specific training issues."
At the research institution in Boston, the blended approach boosted on-time completion of training from 75 percent to nearly 100 percent in one year, according to the white paper.
"EHS staff now perform one monthly training session instead of two (60 minutes on specialized topics), prepare one-tenth the training materials and tracking efforts are greatly reduced," the white paper says.
To download the white paper, click here.