OSHA Guidance for Labs: 2024 and Beyond

“Hazards come in many forms in the laboratory setting,” says medical technologist and lab safety expert Dan Scungio. “These can vary depending on the type of lab: biological, chemical, radioactive, electrical, cryogenic, ultraviolet light, sharps… and the list goes on.”

The Occupational Safety and Health Administration (OSHA) agrees, laying out a broad set of standards and guidance that apply to clinical laboratories.¹ “Biological hazards are critically important to identify and address in clinical labs,” says OSHA spokesperson Kimberly Darby. “Following sound biocontainment practices and implementing appropriate engineering controls, administrative controls, and personal protective equipment (PPE) when working with potential biological hazards can prevent laboratory-acquired illnesses. There may also be chemical hazards, as well as safety hazards such as those associated with autoclaves, centrifuges, and compressed gases.”

OSHA guidance for labs

Darby outlines key OSHA requirements every clinical lab professional should know:

• The General Duty Clause: “Section 5(a)(1) of the Occupational Safety and Health Act of 1970 (OSH Act) requires that employers ‘shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or likely to cause death or serious physical harm to his employees.’² Therefore, even if an OSHA standard has not been promulgated that deals with a specific hazard or hazardous operation, protection of workers from all hazards or hazardous operations may be en­forceable under section 5(a)(1) of the OSH Act.”
• The Bloodborne Pathogens standard: “The principles and practices described in OSHA’s Bloodborne Pathogens standard (29 CFR 1910.1030)³ must be understood and followed by every clinical laboratory professional since they often handle human samples that may contain bloodborne pathogens. This standard is intended to prevent infections that can be acquired from human blood, serum, plasma, and other body fluids that contain visible blood.”
• Additional standards: “OSHA has several standards that apply to laboratory environments, such as the Occupational Exposure to Hazardous Chemicals in Laboratories standard (29 CFR 1910.1450),⁴ the Hazard Communication standard (29 CFR 1910.1200),⁵ the Respiratory Protection standard (29 CFR 1910.134),⁶ and the Personal Protective Equipment standard (29 CFR 1910.132),⁷ among others.”

Labs may not even realize that some of the more obscure OSHA requirements apply to them as well, says Scungio—offering standards like Permit-Required Confined Spaces (29 CFR 1910.146),⁸ which applies to confined spaces that contain serious safety or health hazards, and Machinery and Machine Guarding (29 CFR 1910.212),⁹ which applies to equipment with the potential to cause injury, as examples.

“OSHA encourages employers to implement safety and health programs,” Darby says. “These programs prevent workplace injuries, illnesses, and deaths, as well as the suffering and financial hardship these events can cause for workers, their families, and employers.”

Common failure points

Although clinical labs are generally aware of requirements related to bloodborne pathogens and PPE, Scungio notes that it’s easy to overlook the finer points of safe practices. “For example, the Bloodborne Pathogens standard forbids eating and drinking in labs, but that also includes actions like gum chewing,” he explains. “OSHA is trying to prevent any hand-to-mouth activity in the lab setting, but cannot list them all.”

Eye and face protection guidance is another area labs often fail to understand fully. “OSHA expects labs to conduct risk assessments to determine when PPE should be used, but face protection is necessary whenever staff handles open specimens or chemicals. The standards may not state that clearly, but it is necessary.”

A comprehensive workplace safety and health program can support better understanding of—and adherence to—safety standards and recommendations for the lab. Darby directs interested lab professionals to OSHA’s Recommended Practices for Safety and Health Programs, which include a step-by-step guide to developing and improving such programs.^10,11

Recent and forthcoming changes

Major changes to OSHA guidance are rare because Congress must pass each new standard. Minor changes and updates, however, take place every year. Most recently, OSHA updated the Hazard Communication standard¹² to align with the Globally Harmonized System of Classification and Labelling of Chemicals.¹³ “This update will provide a common and coherent approach to classifying chemicals and communicating hazard information on labels and safety data sheets,” says Darby. “It includes important updates to training requirements for workers to facilitate recognition and understanding of the information on safety data sheets.”

In the near future, the organization plans to increase efforts to protect workers from infectious diseases in healthcare and related settings, including biomedical laboratories.¹⁴ “OSHA is considering the need for a standard to ensure that employers establish a comprehensive infection control program and control measures to protect employees from exposures to infectious agents that can cause significant disease,” Darby says. “To date, the agency has published an Infectious Diseases Request for Information,¹⁵ held stakeholder meetings, conducted site visits, and completed the [Small Business Regulatory Enforcement Fairness Act] process. The next stage is the publication of a notice of proposed rulemaking, which would initiate a public process for stakeholders to provide input to the agency on the proposal.”

Resources and support

To stay up to date with the latest safety guidance, Scungio recommends visiting OSHA’s laboratory-specific website or subscribing to their newsletter. For more in-depth support with compliance, hazard identification, and safety program improvements, OSHA offers two free services:

• Compliance Assistance Specialists offer resources, outreach, and training to a variety of groups including employers, professional associations, and unions.
• On-Site Consultation, a program aimed at smaller businesses, works with employers to develop, implement, and improve safety and health programs and to identify and address hazards in their workplaces.

Overall, both Darby and Scungio encourage labs to explore the resources available to them and ensure that every member of the lab receives appropriate training with regular updates. Above all, labs must stay informed of changes that may affect the way they deal with risks to health and safety.

Although each lab has unique needs and concerns, Darby’s final advice applies across the board: “By understanding the hazards specific to their work settings and the practices that need to be implemented to control those hazards, employers and laboratory managers can proactively and systematically identify the practices that would be most appropriate for their work setting.”

References:

1. Occupational Safety and Health Administration. Laboratories. https://www.osha.gov/laboratories.
2. Occupational Safety and Health Administration. OSH Act of 1970: General Duty Clause. https://www.osha.gov/laws-regs/oshact/section5-duties.
3. Occupational Safety and Health Administration. Bloodborne pathogens. May 14, 2019. https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1030.
4. Occupational Safety and Health Administration. Occupational exposure to hazardous chemicals in laboratories. March 26, 2012. https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1450.
5. Occupational Safety and Health Administration. Hazard Communication. May 20, 2024. https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1200.
6. Occupational Safety and Health Administration. Respiratory protection. September 26, 2019. https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.134.
7. Occupational Safety and Health Administration. Personal Protective Equipment: General requirements. November 18, 2016. https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.132.
8. Occupational Safety and Health Administration. Permit-required confined spaces. December 27, 2011. https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.146.
9. Occupational Safety and Health Administration. Machinery and Machine Guarding: General requirements for all machines. https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.212.
10. Occupational Safety and Health Administration. Recommended Practices for Safety and Health Programs. https://www.osha.gov/safety-management.
11. Occupational Safety and Health Administration. Safety and Health Programs Step-by-Step Guide. https://www.osha.gov/safety-management/step-by-step-guide.
12. 29 CFR Part 1910. Hazard Communication Standard. Federal Register. May 20, 2024. https://www.govinfo.gov/content/pkg/FR-2024-05-20/pdf/2024-08568.pdf.
13. United Nations Economic Commission for Europe. Globally Harmonized System of Classification and Labelling of Chemicals (GHS Rev. 10, 2023). December 9, 2023. https://unece.org/sites/default/files/2023-07/GHS%20Rev10e.pdf.
14. Occupational Safety and Health Administration. Infectious Diseases Rulemaking. https://www.osha.gov/infectious-diseases/rulemaking.
15. Regulations.gov. Infectious Diseases. May 5, 2010. https://www.regulations.gov/document/OSHA-2010-0003-0001.