Back to Basics: EHS Fundamentals for Laboratories

Environmental, health, and safety (EHS) regulations may seem annoying and complex to managers who must interpret and comply with them. The rules are rigid, complex, and require time and effort to understand thoroughly. Ignoring these guidelines is not an option: They are crucial—in fact, essential—for laboratory safety and success.

In a recent presentation, I covered some of the basic EHS fundamentals labs require to succeed—and why they need them in the first place. Read on for some key takeaways from my presentation.

1. Modern EHS regulation has its roots in worker and environmental protection.

The Environmental Protection Agency (EPA) and the Occupational Safety and Health Administration (OSHA) were formed out of ecosystem considerations and human health concerns, respectively. This was spurred from several EHS-related disasters that, if regulations existed and were followed, may not have happened:

• Cuyahoga River Fire: Over an 80-year period, this Ohio river blazed a recorded 13 times due to a surface oil sheen—making it clear that pollution was creating unsafe incendiary conditions for citizens. Though river pollution was not new to the country, this high-profile example of a particular fire on the river in 1952 helped ring proverbial alarm bells across the nation—and triggered a series of protective legislative responses.
• Triangle Shirtwaist Factory Fire: This infamous fire of 1911 in New York City claimed the lives of 146 people—and exposed how manufacturers nationwide all too frequently imposed eminently unsafe working conditions on their employees. Despite the event’s horrific death toll, legislators took years to pass regulations to improve factory safety. That interim period offered plenty of time for even more workplace disasters.
• Texas City Disaster: In 1947, a ship carrying ammonium nitrate exploded in the harbor of Texas City, Texas—causing the United States’ single greatest worksite disaster in history. The initial blast occurred while the vessel was docking, causing a ripple effect (quite literally) across the bay. The force of the explosion carried fire to countless other ships and docks, ultimately claiming as many as 600 lives and leaving thousands more injured.
• Northeast Syringe Tide: In the 1980s, thousands of used syringes washed up on the beaches of New Jersey, New York, and Connecticut. Public outcry spurred these states to quickly create tighter regulated medical waste (RMW) laws.

These are just four examples of the inherit risks of potential workplace hazards. Horrific disasters can occur when workplace hazard precautions are not closely followed.

It took until the 1960s and 70s for the Nixon administration to establish major federal enforcement bodies (the EPA and OSHA). Now, many organizations, at both the state and federal levels, have taken a hand in EHS regulatory oversight. The various enforcement bodies also have the power to impose penalties, which can take the form of fines (per instance, per day), warnings, Notices of Violation (NOVs), or even shutdowns.

• The EPA focuses on upholding federal environmental regulations, like:
  • Resource Conservation and Recovery Act (RCRA)
  • Toxic Substances Control Act (TSCA)
  • Clean Water Act (CWA) and Clean Air Act (CAA)
  • Permitting
• OSHA handles the creation and enforcement of nationwide US workplace safety standards
• The Centers for Disease Control (CDC) provides protocols for biological lab work, mostly through Biosafety in Microbiological and Biomedical Laboratories (BMBL) practices
• The National Institutes of Health (NIH) offers rules for labs receiving NIH funding
• State and local authorities implement and enforce federal regulations—and, as needed, craft their own guidelines

The world of EHS compliance can change in a moment, with new legislation or according to other factors.

2. When operating normally or scaling operations, labs need to consider safety, health, the environment, and waste—as well as how to go above and beyond.

Many protocols, programs, and resources are available to assist labs in evaluating EHS programs and improving upon them—making them more proactive, efficient, and adaptive. For even the most basic EHS programs:

• Safety considerations include:
  • National Fire Protection Association (NFPA) and fire code compliance
  • OSHA compliance
  • Emergency Action Plans (EAPs)
  • Chemical Hygiene Plans (CHPs) and inventory management
  • Exposure Control Plans (ECPs)
  • Biosafety Plans (BSPs)
  • Radiation safety
  • Department of Homeland Security (DHS) and Department of Transportation (DOT) compliance
  • Emergency Planning and Community Right-to-Know Act (EPCRA) compliance
  • RCRA compliance
• Health considerations include:
  • OSHA compliance
  • CWA
  • CAA
  • CHP
  • Exposure controls
  • Industrial hygiene
  • Employee exposure monitoring
  • Medical surveillance
  • Occupational healthcare provisions
• Environmental considerations include:
  • RCRA compliance, including waste management plans, EPA ID numbers, and training
  • CWA compliance, including SPCC and wastewater permits
  • CAA compliance, including Title V permits
  • DOT compliance, including training and manifests
  • EPRCA compliance, including Tier II and Toxics Release Inventory (TRI) reports
• Scaling considerations include:
  • Manufacturing space entrance status (contract manufacturing organization (CMO) or contract development and manufacturing organization (CDMO))
  • How will shifting chemical and waste inventories be managed?
  • EHS permitting, plan updates, and inspections
  • Point of contacts
  • Potential construction activities
  • Employee chemical contact tracking
  • Executive team EHS buy-in
• Waste can be:
  • Hazardous (RCRA) waste
  • Special waste (an Illinois-specific designation)
  • Biohazardous waste, like RMW or Potentially Infections Medical Waste (PIMW)
  • Non-hazardous waste
  • Universal waste
  • Animal and Plant Health Inspection Service (APHIS) waste
  • Drug Enforcement Administration (DEA) waste, like controlled substances
  • Recyclable waste
  • General trash

All of these wastes are regulated at some capacity. As such, waste factors for consideration include:

• RCRA compliance
• What materials do you need for EHS operations, and which do scientists want?
• What waste will your organization’s processes generate?
• EPA registration and generator status
• Spill and release plans
• Facility waste exit routes
• Waste reduction

3. Prioritizing efficient EHS initiatives may lead to a cost savings of about 5-20% during the first year of implementation.

Sophisticated methodologies and specialized partner assistance can help you not only meet but exceed your EHS goals. Such efforts go beyond routine operational competence and incorporate environmental sustainability for maximum success and impact.

To take advantage of this savings, you should:

• Develop sustainability metrics and set environmental goals
• Implement a sustainability plan to achieve those environmental goals, including by finding a recycling or waste management partner and working with them to reduce or reuse waste, where possible
• Attain third-party accreditations to access global networks of environmental professionals and share best practices
• Regularly audit EHS programs, and request actionable input from all employees

The idea of “improvement” is generally a big, abstract, and long-term goal for lab EHS programs; small steps in the right direction are better than stagnation. Everyone and anyone can be an innovator—to help you achieve not only EHS regulation success, but also to put you above and beyond your competitors.

It can help to have a dedicated and capable EHS partner with fresh ideas and the skillset you need to help you focus on core organizational success—beyond just the basics. Contact us today to learn more.