A monthly newsletter to help organizations create safety savvy laboratories.

Question:

A manufacturer seems to have a supply issue with plastic blood culture bottles. If the lab is switching to glass bottles in the interim, what are some safety/infection prevention issues that may need to be addressed?

Dan the Lab Safety Man says:

The biggest safety concern with switching to glass bottles will be disposal. The plastic bottles can be disposed of into red bag (biohazard) trash bins since they cannot be broken to create sharp edges.

Glass bottles should definitely be disposed of into sharps containers.

(Some microbiology labs do place positive plastic bottles into sharps containers to make sure they are incinerated.)

Question:

Is hand cream and its use prohibited in laboratories?

 Dan the Lab Safety Man says:

Hand cream is allowed in a lab, but it should be limited to a brand that is approved by the hospital/laboratory. Some creams can cause allergic reactions or even break down glove material (especially petroleum-based creams). Check with Infection Prevention or even Materials Management to see what brands may be used in the facility.

Question:

Can tape of any type be used to hang items in a laboratory? Would a lab be cited by TJC for using tape? Is cardboard allowed in the laboratory? Many lab products come in cardboard boxes, and paperwork is being placed in cardboard boxes for storage. Does a lab need to remove all cardboard?

Dan the Lab Safety Man says:

Most hospital accrediting organizations (TJC, DNV, etc.) do not have specific standards preventing tape or cardboard. If a hospital seeks a special Infection Prevention certification, stricter rules may apply. It is also possible that the hospital will create its own rule based on interpreting (or mis-interpreting) a standard. (One unrelated example of this is the misunderstanding that TJC does not allow anything to be stored under hospital sinks.) In certain Infection Control guidelines, tape is prohibited because it leaves a residue that attracts bacteria and other contaminants thus creating a potential infection issue. In place of tape you can use velcro, tacks, etc. In other guidelines, corrugated cardboard is not permitted in hospitals because it is a source of insects (particularly cockroaches) and their eggs. Cardboard used for storage should be replaced with plastics and other options. Supplies that come in cardboard should be removed and placed into bins or other storage containers. Some cardboard cannot be eliminated (such as in reagent or chemical cubes), but most can and should be for infection control purposes.

Question:

It has always been laboratory procedure to wear lab coats on the units when performing venipuncture to minimize the risk of splashes. However, staff members argue that nurses/CNAs do not wear such PPE and are not required to, yet their risk of splashes is arguably similar. In the interpretation of OSHA standards regarding PPE, it would seem that all need to wear some type of non-permeable gown for blood/body fluid collection. What are your thoughts on this issue and possible guidance on addressing the difference in guidelines between nurses and lab?

Dan the Lab Safety Man says:

Through a letter of interpretation about the Bloodborne Pathogens standard, OSHA clearly states that lab coats are not required for phlebotomists UNLESS you perform a risk assessment and determine that there is a risk for blood splash/spatter above the wrist during venipuncture procedures. Some hospitals require the use of lab coats for phlebotomists, others do not. It is not a matter of what other unit employees (i.e. nurses) wear, it has to do with the assessment of risk for lab employees performing these procedures in patient rooms or in draw rooms. OSHA would require other personnel who collect blood to perform their own risk assessments. In my experience, there is very little risk of splash above the risk, but others have seen different results.

While I do not feel it is necessary to have phlebotomists use lab coats, you are perfectly justified in making that decision if your risk assessment determines it is necessary.

Question:

A bottle of concentrated bleach did not have any GHS symbols on the individual bottle. However, the pictograms were on the SDS for the bleach. Is it required to have symbols on the container which match the SDS? 

Dan the Lab Safety Man says:

In general, it is required for primary chemical containers to have a pictogram (as well as the SDS). However, some manufacturers bypass (via an FDA regulation) the requirement for products that are sold at stores or used in homes. You can add the pictogram to the container for use in the laboratory.

Question:

Does a sharps container have to have a lid on it at all times? It should have one if it is going to be moved from the original work area, but what if is on or next to a work bench (on the floor) without a lid? If and when it is moved, still within the dept, it must have a lid (but lid does not have to be closed) -the lid can still be “open” at this point with the opening used for the addition of other items. Once the container is moved out of the dept, for disposal, it must have a CLOSED lid. Is all of this correct? 

Dan the Lab Safety Man says:

While the wording of OSHA's Bloodborne Pathogens standard matches closely with what you state, OSHA also says that sharps container should have an opening on the lid that is large enough only to accommodated the items being deposited. That certainly implies that a lid should be in place. In an OSHA letter of interpretation regarding this topic, OSHA says "The disposal opening on a sharps container should be of a size and design that would permit safe disposal of sharps." They also use information from NIOSH which states, "In situations where the small opening on the lid of the container is of sufficient size to accommodate all sharps requiring disposal, there should be no need for the entire lid to be opened. If the employer is finding the need to open the entire lid, perhaps further evaluation is needed to assure that the container selected is suitable to accommodate sharps of all types and sizes that require disposal. It is likely that a container of a different size, type or design configuration would be more appropriate in the specific situation of use." Given that, it is clear lids on containers is a better, safer practice.

Question:

What do you think about service dogs in the clinical lab? What are "reasonable accommodations" and is this something labs should be preparing for in new design models?  

Dan the Lab Safety Man says:

The topic of service animals in the lab is a complicated one. I have dealt with a service animals in labs before, and we made it work - in part because we had to. One main concern in this lab was the dog's safety, and we worked to make sure the lab was a safe environment for the animal. All trash containers had lids, the floors were cleaned regularly, and the dog went outside the department for water and food. It worked in that situation, but it was also a small lab where there was only one technologist. Things could get stickier with a larger lab. I noticed in an article on the topic that the dogs wore PPE! That would be useful if the dog is willing and able to wear it. Labs need to accommodate for the employee if there is a need for a service animal, in many cases we are required to do so by law. I don't necessarily think that labs need to be designed differently in case a service animal will be used in the future. There should not be safety issues with other employees (unless allergy issues exist), the bigger issue is the animal's safety in an environment with chemical and biohazards.

Question:

In the Histology lab, xylene is used on an instrument. The lab safely (and correctly) transfers the contents of a 5 liter bottle into a smaller glass containers that are used on the instrument. Staff are having difficulty with the labels and GHS decals becoming stained, unreadable, and destroyed with random drips. Do you have any recommendations on how we can label our bottles without them becoming defaced? 

Dan the Lab Safety Man says:

OSHA's Hazard Communication standard states that you can also identify secondary chemical containers using signs or placards. As long as the container is positively identified by the placard or the sign is placed next to the container, that can be used as a labeling option. You could create a permanent label and laminate it so it does not become wet. Some labs will also place clear tape over a secondary container label provided the information on the label does not change.

Question:

There is a room in one of the labs that was used for receiving outpatient specimens. One of the leaders would like to convert that room to an office for a new supervisor. Is it possible to convert a “dirty” lab area to a “clean” one, and if so, what would need to be done? 

Dan the Lab Safety Man says:

To convert a room to a clean space, it simply needs to be cleaned and disinfected, and you need to make sure it is separate from any lab spaces, that is, separated from ceiling to floor and has a door.

 Question:

It was noted that the vendors hooked up a surge protector to an analyzer and have multiple plugs plugged in. Do you consider this acceptable? 

Dan the Lab Safety Man says:

Yes, a multi-plug adaptor with a surge protector is acceptable as part of your analyzer set up.

Dan's Calendar

NSH Annual Meeting - New Orleans, LA

September 20-24, 2024

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Biotech Lab and Facilities Conference & Exhibition - Lisbon, Portugal

October 24-25, 2024

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Future Labs Live - Philadelphia, PA

October 30-31

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The 2024 -2025 calendar is open and I am booking consultations and presentations. If you are interested in hiring Dan the Lab Safety Man for your event (live or virtual) or for on-site training and consulting, call 877-894-7004 to check available dates. 

Does your staff need lab safety training? I can provide that as well.

Looking for something different?  Give me a call and see what other presentations are available!