It is time to conduct annual safety refresher training for your staff.
Download the memo for instruction and forms to guide you through the process. We encourage you to review these materials with your staff and post hard copies of both documents in conspicuous areas of your laboratory(s) as a reminder of these requirements.
|To:||Principal Investigators (PIs) and Permit Holders|
|From:||Deona Willes, MPH/Interim Executive Director|
|Subject:||Annual Laboratory Safety Refresher Training Reminder|
It is time to complete the annual refresher training for all your staff as well as update your chemical inventory online. Please select all suggested safety topics on the following pages that are relevant to your research and operations. Use the table on the following pages to check off the safety topics you cover and use the attached Site-Specific Training Record (SSTR) to document attendance. Submit both table and SSTR to EH&S via email email@example.com. Please complete within 60 days of this notice.
We also recommend that you and your research staff: (a) review emergency procedures; (b) walk the building exit routes and report any obstructions to EH&S; and (c) identify emergency equipment locations (e.g., fire extinguisher and eyewash/shower station) in your lab/building.
We are pleased to announce the launch of the EH&S Assistant (EHSA) web application. EHSA will provide you with information on your approved permits and an area to update your chemical inventory and check your training records.
Recently, four safety manuals were developed to support the continued safe operation of USC research laboratories and other facilities containing hazardous materials. Please familiarize yourself and your staff with the information.
The Office of Environmental Health and Safety (EH&S) has also updated its website. Visit ehs.usc.edu to find valuable safety information and resources.
Please be reminded that the action items on the following page have regulatory compliance components that need to be satisfied as well.
- PPE Training for Laboratories through Trojan Learn. The USC PPE Standards are now in effect. Anyone working in or occupying USC research laboratory areas must wear full-length pants and fully closed shoes. Depending on the activity, appropriate lab coat type, appropriate gloves, and eye protection must also be worn when handling any hazardous chemical, biological or radiological material. To determine appropriate PPE for the lab, complete a hazard assessment using the Lab Hazard Assessment Tool (LHAT). Staff that have access to machine shops or in-lab shop areas, should consult the Shop Safety Risk Assessment tool (SSRA) to determine appropriate PPE. Submit a copy of the completed LHAT and/or SSRA to EH&S at firstname.lastname@example.org.
- A PPE Inspection Checklist will be used by EH&S Inspectors to evaluate research staff adherence to the USC PPE Standard during unannounced visits. Research groups are encouraged to use the checklist for self-auditing purposes.
- Annual BBP Refresher training. This is an OSHA-required training for all personnel that handle human or non-human primate blood, organs, tissues, primary cells, and cell lines or other potentially infectious human or non-human primate materials. Initial training is provided by EH&S (see http://www.localendar.com/public/USCEHS for class schedule).
Subsequent annual refresher training will be available on USC Trojan Learn soon.
Alternatively, PIs or Lab Managers may provide the annual refresher BBP training for their staff and themselves; training must cover all elements of the Bloodborne Pathogens Standard (see Annual Bloodborne Pathogens Refresher Training section). Submit completed Site-Specific Training Record to email@example.com. Include qualification of Trainer (e.g., PI, MD, Nurse, or Lab manager).
- Controlled Substances
- Registration: PIs who engage in use of controlled substances for research purposes must retain an individual DEA Registration and enroll in the Controlled Substances Use Authorization (CSUA) Program. Additional information regarding controlled substances may be obtained at Controlled Substance Program.
- Physical Inventory: PIs must complete and submit a physical inventory of their controlled substances on hand to EH&S annually. Please complete CS Form C and submit to EH&S via email firstname.lastname@example.org. Please complete within 60 days of this notice.
- Radiation Use Authorization (RUA) and Biohazard Use Authorization (BUA) Registration. Register protocols for the RSC and IBC through iSTAR (http://iSTAR.usc.edu).
- Laser Registration/Laser Safety Program. All Class 3B and Class 4 lasers need to be registered with EH&S. Registration forms are available on the laser safety webpage (see Laser System Registration). Review your laser SOP(s) and keep your training up-to-date. Review hazard sign, safety equipment, and safety requirements for all labs that have lasers. Contact email@example.com with any questions.
On-going Safety Programs
Please take a moment to acquaint yourself with the many services EH&S provides by reviewing the EH&S Services Guide Sheet. The guide sheet and relevant Fact Sheets that cover the range of topics under environmental, health, and safety are available at the EH&S Fact Sheets web page.
EH&S’ laboratory inspection program that features: greater scrutiny of hazardous lab operations and processes, assessment of adherence to the USC PPE Standards; and, closer evaluation of chemical storage compatibility to name a few. Information on the inspection program may be found on the web at https://ehs.usc.edu/research/lab/inspections/.
Depending on the type of safety finding, research groups will have either five (5) or twenty (20) business days to remediate it. Findings not corrected within the allotted time period will be noted on a follow-up inspection and the subsequent report will then be disseminated to deans, department heads, and oversight committees as needed. Inspection Process Flow Charts are available for Laboratory Safety, Biosafety, and Radiation Safety. Please review the flowchart(s) to acquaint yourself with the overall inspection cycle, timelines, and consequences.
In fall 2017, EH&S launched the USC Eye Protection Initiative for USC researchers. There have been many near misses and injury reports in years past, so an initiative was launched to combat this issue. The focus of the campaign was to educate all lab personnel on proper eye protection based on the risk assessment of their work. The eye protection initiative included a survey, educational materials, and distribution of eye protection to labs. For more information, please contact EH&S at firstname.lastname@example.org.
Lab coat laundering and other services are available to PIs and their respective research groups. Visit the Lab Coat Services web page for more information. The Lab Coat Loaner Program provides research staff and faculty with appropriate lab coats on a temporary basis until permanent lab coats can be purchased and delivered. For details about the program, consult the Lab Coat Loaner Fact Sheet.
Your efforts in continuing high safety standards within your laboratory: encourages a strong safety culture; supports employee health and well-being; limits or removes disruptions in research and productivity due to injury and illness; and, secures a competitive edge.
Thank you again for your continuing efforts to protect the health and safety of the campus community.
|No Food/Drink/Gum in Lab||Food, drinking water, powdered milk, cosmetics, smoking materials, etc. are not allowed in any laboratory containing hazardous materials (including at writing desks in labs). Automatic suspension of a radioactive materials permit can be enforced if evidence of food is found where radioactive materials are used. Food, beverages, or water intended for research purposes must be labeled: “Not For Human Consumption.” Refer to Food and Drink in Laboratories Fact Sheet.|
|Controlled Substances||Per DEA regulation 1301.12, “A separate registration is required for each principal place of business or professional practice where controlled substances are stored, administered, or dispensed by a person.” Therefore, the address on your DEA license should correspond to the address where you store and use controlled substances. If you move labs, always update your address information. You may do this by applying for a modification to your current license. Also, if you add new personnel to your lab, please update your CSUA Form A-1 and ensure they complete the required controlled substances training.|
|Housekeeping||Stress good housekeeping practices. Remember, “A Clean Lab is a Safe Lab.” Trip hazards and poor housekeeping are estimated to be a factor in six out of ten injuries in laboratories.|
|Laboratory Hazard Assessment||Review all potential chemical, biological, radioactive and physical hazards used in your laboratory(s) and the tasks performed by lab staff that may cause exposure to these agents; use the Lab Hazard Assessment Tool (LHAT) as a guide. Review protective measures in terms of engineering, administrative, and PPE controls.|
|Laboratory Inspections||Review recent findings from EH&S safety inspections/audits of your laboratory(s) with your research group. Develop a self-inspection plan and discuss ways of improving overall lab safety. Researchers are encouraged to consult the General Lab Inspection Checklist to implement self-inspections.|
|Safety Data Sheets (SDS)||Review the SDS for a particular hazardous substance with staff. Include discussions on hazards, safe handling, PPE, emergency information, etc. For access to SDS, visit our website at https://ehs.usc.edu/research/lab/sds/.|
|General Epidemiology||Explain the modes of transmission of the hazardous agents in your lab (respiratory, absorption, ingestion, injection). Please review your exposure control plan for biohazards used in the lab.|
|Standard Operating Procedures (SOPs)||Develop, review, and train on SOPs for hazardous materials; lab-specific operations; and specialized equipment. NOTE: The PI and/or Lab Manager must retain training records for all internal training.|
|Radioactive Material Transfer||Discuss protocols for transfer(s) of radioactive material either to another campus location or to another institution. Note that this requires prior written approval by Radiation Safety.|
|Radioactive Material Order||Review how to order radioactive materials using the USC Radiation Paperless Requisition Entry Process (eMarket – make sure to check the “Radioactive Material” box). See our fact sheet for more information: http://tiny.cc/usc-ehs-RAM-buy. All deliveries must be made to the HSC Environmental Health & Safety Office at 2001 N. Soto St, SBA 329 Los Angeles, CA 90032.
|Radioactive Material Inventory Control||Review your specified locations and procedures for radioactive material use/storage. Stress the requirement for accurate and timely entries in the online EHSA system and placing the inventory number on all stock vials, tubes, etc.|
|Radioactive Material Use Permit Changes||Discuss any changes or amendments to your Use Permit in the last 12 months (e.g., new research protocols; new authorized users; addition of new radionuclides; changes in possession or procedure limits, or authorized locations).|
|Radioactive Material Personal Dosimeters||Emphasize the proper use and care of personal dosimeters (Whole Body & Ring badges). Review how to return badges to Radiation Safety, how to report lost/damaged badges, personnel changes, and any exposure concerns.|
|Radioactive Material Survey Instruments||Review the proper use of survey instruments (portable, LSC, gamma counters, etc.) to detect possible contamination, and the need to monitor hands with disposable gloves before, during and after handling radioactive material.|
|Radiation Contamination Control||Review the defined work areas in your lab that are required for radioactive materials, carcinogens, reproductive toxicants, and other high-hazard materials; selection of appropriate instrumentation and survey methods; and the need for frequent monitoring, visual indication of area boundaries, and prompt decontamination and documentation of spills. Each lab must document monthly contamination checks for all rooms on the Radiation Permit on EHSA. Remind laboratory personnel that potentially contaminated items, including PPE and laboratory samples, are not permitted in offices.
|Security for Substances of Interest||Discuss your procedures for assuring that Radioactive Material, Select Agents, Controlled Substances, and highly acutely toxic substances are securely stored and security precautions are in place when used.|
|Registration of Biohazardous Substances||Review the guidelines for using biological materials at USC and ensure there is an up to date Biohazard Use Authorization (BUA) in iStar (http://iSTAR.usc.edu) for the use of microorganisms, recombinant biologicals, toxins of biological origin, and chemicals used in biology.
|Biohazard Reporting Guidelines||Review the procedures and policies for reporting incidents, accidents, spills, and losses including incidents with recombinant DNA (r-DNA). Review the Fact Sheet titled “rDNA Incident Reporting”, http://tiny.cc/usc-ehs-rDNA-rprt.|
|Post-Exposure Follow Up||Explain what to do if someone is exposed to a hazardous material, the post-exposure evaluation, and follow-up that will occur following an exposure incident.|
|Laser Safety Requirements||If your lab uses Class 3b and Class 4 open laser setups, make sure lab doors are properly posted, all lab personnel are aware of lab-specific laser standard operating procedures and beam alignment procedures and have appropriate eye protection available. The lab should maintain copies of these procedures signed by laser users.|
|Engineered sharps and safe sharps disposal||Use safety engineered sharps whenever possible. Emphasize that users recap a needle only when absolutely necessary. Never leave a needle or other sharp unattended, or place a needle or other sharp in trash or biohazard bag!|
|Fact Sheets||Select pertinent fact sheets for group discussion.|
|Waste Disposal||Review hazardous waste disposal procedures, including waste segregation, labeling, appropriate use/placement of containers (see Page 2 of the Hazardous Waste Disposal Fact Sheet), placing lids on bio-cans and table top containers when not in use, and record keeping. Only appropriate, properly labeled containers can be picked up. Chemical waste containers must be labeled with the official “Hazardous Waste” label, and the accumulation start date clearly marked. The label must also include: (a) composition (NO abbreviations or chemical formulas); (b) solid/liquid; (c) hazardous properties (e.g. flammable); (d) PI name; and (e) lab location. Review biohazardous and pathological waste disposal procedures, and sharps disposal. Please use EHSA for any type of hazardous waste pickup such as biological, chemical, radiological or universal.|
|Record Keeping||Review record-keeping procedures, such as Disposal Record forms, Controlled Substance Logs, Radioactive Material Usage Records, Transfer of Radioactive Material forms, and Wipe Test results (if required).|
|Emergency Response and Notification||Discuss reporting accidents and incidents that involve hazardous materials (including biologicals), and what to do following an exposure, including how and where to obtain medical attention, and what documentation is required. See Emergency Notification Protocol web page.|
|Non-Emergency Injury and Illness Reporting and Treatment Locations||Review the fact sheet.|
|Emergency Equipment||Ensure all personnel are aware of the location of fire extinguishers, emergency showers, emergency eyewashes, drench hoses, first aid kits, spill kits, HF burn kits, and phenol first-aid kits. Inspect the items in first aid kits, HF burn kits, and phenol first aid kits and replace any which are past the expiration date.|
|Phenol Safety||If your lab uses phenol or phenol-containing reagents (e.g. phenol-chloroform, TRI Reagent®), please review the Phenol Safety Fact Sheet. Ensure phenol users employ appropriate PPE (as detailed in the Fact Sheet). It is strongly recommended that labs which use phenol are provided with a phenol first aid kit, as described in the Fact Sheet.|
|HF Safety||If your lab employs hydrofluoric acid, review safety information (http://www.calgonate.com/safety_info.php) and fact sheet. Ensure your lab is provided with HF first-aid supplies (calcium gluconate gel). Procedures employing HF should be covered by a written SOP. All HF users should be trained in safe use, and the training recorded.|
Use the table to check off the safety topics you cover and use the attached Site-Specific Training Record (SSTR) to document attendance. Submit both table and SSTR to EH&S via email email@example.com. Please complete within 60 days of this notice. 
Bloodborne Pathogen Training Requirements
|1. An Accessible Copy of the Standard||Inform personnel of where to find the Cal/OSHA Bloodborne Pathogens Standard and an explanation of its contents (www.dir.ca.gov/title8/5193.html).|
|2. Epidemiology & Symptoms||Explain general epidemiology & symptoms of bloodborne pathogens.|
|3. Modes of Transmission||Explain the modes of transmission of bloodborne pathogens.|
|4. Risk Identification||Explain the appropriate methods to recognize tasks and other activities that may involve exposure to blood and other potentially infectious materials (OPIM).|
|5. Exposure Control Plan||Explain your lab’s Exposure Control Plan and how employee(s) can obtain a copy of the written plan. Review what to do in case of exposure.|
|6. Methods of Compliance||Explain the use and limitations of methods to prevent or reduce exposure, including appropriate engineering (engineered sharps, biosafety cabinets), administrative or work practice controls, and personal protective equipment (gloves, safety glasses).|
|7. Decontamination and Disposal||Review proper decontamination and disposal procedures.|
|8. Personal Protective Equipment||Discuss selection, proper use, location, removal, handling, decontamination and disposal of personal protective equipment for work in your lab.|
|9. Hepatitis B Vaccination||Remind personnel about the Hepatitis B vaccine, its efficacy, safety, benefits of being vaccinated, and that it is provided free of charge to employees through the USC Medical Surveillance Program at (323) 442-2200 or Biosafety@usc.edu.|
|10. Emergencies||Provide information on appropriate actions and persons to contact in an emergency involving blood or OPIM – USC BBP Exposure Procedure.|
|11. Exposure Incident, Post-Exposure Evaluation, and Follow-Up||Explain exposure incident procedures, including how to report an incident, location of medical facilities, and that medical follow-up that will be available. Note: If a Sharp is involved, the Sharps Injury form must be completed for OSHA recordkeeping in addition to the Supervisor’s Report of Injury.|
|12. Signs and Labels||Explain all signs, labels and/or color coding required in the lab.|
|13. Interactive Questions and Answers||Provide an opportunity for interactive questions and answers.|
The above are minimum required training topics. View www.osha.gov/SLTC/bloodbornepathogens and the USC Bloodborne Pathogen Program for more information. NOTE: Additional training is required for employees of HIV, HBV and HCV Research Laboratories. Contact EH&S at Biosafety@usc.edu for information.
Complete above checklist and Site-Specific Training Record. Send both to firstname.lastname@example.org. Include qualification of Trainer (e.g., PI, MD, Nurse, or Lab manager). Please complete within 60 days of this notice.
 The Institutional Biosafety Committee (IBC) and the Radiation Safety Committee (RSC) will delay approval of research protocols if refresher training is not current for listed staff. Radioactive material and controlled substances deliveries will be withheld after March 1, 2018 to labs whose authorized staff have not completed training.
 The Institutional Biosafety Committee (IBC) and the Radiation Safety Committee (RSC) will delay approval of research protocols if refresher training is not current for listed staff. Radioactive material and controlled substances deliveries will be withheld after March 1, 2017 to labs whose authorized staff have not completed training.