The Massachusetts State Sanitary Code, 105 CMR 480, requires generators of medical and biological waste to maintain a Medical/Biological Waste Record-keeping Log with various information related to the biological waste handling practices.
There seem to be more and more facilities operating with shared laboratory space these days. Some facilities have very clearly defined and distinct lab space for each company, and some facilities offer the opportunity to share bench space and equipment.
As companies evolve, relocations seem almost inevitable for many facilities. Relocating an entire facility, expanding to additional space, and downsizing all require involvement from EHS personnel early in the process.
As we are experiencing the third Nor’easter in a short period of time, this should serve as a good reminder to keep emergency planning documents up to date. Various regulations stipulate requirements for emergency planning, including OSHA regulations, the Massachusetts Comprehensive Fire Safety Code, and hazardous waste regulations.
On February 7, 2018, the Plumbing Board enacted a policy that adopts the ANSI Z-358.1 Standard for Emergency Eyewashes and Shower Equipment. The MA Uniform State Plumbing Code, 248 CMR 10.00, ANSI Z-358.1 standard, and OSHA regulations present several inconsistencies with requirements for the installation, operation, and maintenance of emergency eyewashes and safety showers.
OSHA’s Bloodborne Pathogen Standard, 29 CFR 1910.1030, applies to all occupational exposure to blood or other potentially infections material as defined in the standard. Employers that have covered employees are required to develop and implement an Exposure Control Plan to minimize employee exposure.
In accordance with 105 CMR 120.210(C), facilities licensed to work with radioactive materials must review the radiation protection program content and implementation at intervals not to exceed 12 months. This should be a formal process that is documented to demonstrate compliance with this requirement.
OSHA is strongly encouraging employers to join the trend towards incident prevention by identifying and addressing hazards before they lead to injury or illness. While employers are reviewing their OSHA 300 logs, they are asking companies to use these logs as a road map to finding and fixing hazards.
Happy New Year to everyone! Wishing you all a very safe, healthy, and happy 2018! Consider taking time now to organize your EHS records and start the new year off headed in the right direction. Ensure your records are clearly organized, and key personnel are well aware of the organizational structure.
I hope everyone is enjoying a wonderful and safe holiday season! Everyone is busy this time of year, and many people are rushing to complete tasks as quickly as possible. Remember that even researchers with extensive experience can have incidents and accidents, and in fact expertise can lead to complacency.
OSHA has announced the date for the second annual safe and sound week, which will be held August 13-19, 2018. This national event is intended to promote the value of workplace health and safety programs. Employers are encouraged to hold events and activities that highlight the elements of their health and safety program during this week.
What would happen if a regulator showed up at your doorstep this afternoon? Would personnel working at the entrance to your facility be prepared, know who to contact, and how to proceed in order to get the inspection started off on the right track?
