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Critical Safety & Compliance Factors

In order to protect the health and safety of laboratory workers and foster a culture of safety within laboratories, Environmental Health & Safety’s laboratory inspection procedures will be changing in FY07.  Failure of certain items during the inspection will result in an automatic failure of a laboratory or clinic inspection.  These items have been termed Critical Safety and Compliance Factors (CSCF; “Deal Breakers”) and are listed below:

1.       Handling of hazardous chemicals must be done with care, especially when large volumes or amounts are involved.  When handling any hazardous chemicals, appropriate personal protective equipment (e.g. gloves, eye protection, face shields, lab coats or gowns, closed-toe shoes) and engineering controls (e.g. fume hood) must be used.  Disregard for personal protective equipment (PPE) will result in an automatic failure of the lab inspection.

2.       Consumption of food and beverages in the lab presents a risk for ingestion of hazardous chemical, biological, and/or radioactive materials.  To eliminate this risk, consumption and storage of food and beverages outside of approved locations (“Clean Areas”) is not allowed and will result in an automatic failure of the lab inspection.  As of January 1, 2007, there will be no approved areas for food and beverage consumption and storage within laboratories.

3.       Improper disposal of metal sharps in the regular trash presents a risk to laboratory and custodial workers, while disposal into a biohazard waste container not specifically designed and approved for sharps disposal poses a risk to laboratory workers and waste handlers.  Improper disposal of metal sharps into either of these containers will result in an automatic failure of the lab inspection.

4.       Regulatory agencies place great importance on the proper disposal of hazardous waste.  To assist labs in maintaining compliance in this area, EH&S has highlighted the following hazardous waste management areas of our lab inspection.  Failure of any of these items will result in an automatic inspection failure.

5.       Improper disposal or management of hazardous waste, including:

a.       Uncapped hazardous waste or hazardous chemical containers.

b.       Improper labeling of hazardous waste containers (e.g. missing yellow EPA waste label, label not completely filled out, failure to add start date to label).

c.       Hazardous waste containers with a start date greater than one year.

Please call Environmental Health and Safety at 362-6816 if you have any questions.