{"id":801,"date":"2018-11-08T12:08:43","date_gmt":"2018-11-08T02:08:43","guid":{"rendered":"http:\/\/paulyeatman.net.au\/?p=801"},"modified":"2020-07-29T14:32:32","modified_gmt":"2020-07-29T03:32:32","slug":"review-of-draft-standard-as-2243-1-safety-in-laboratories-planning-and-operational-aspects","status":"publish","type":"post","link":"https:\/\/paulyeatman.net.au\/index.php\/2018\/11\/08\/review-of-draft-standard-as-2243-1-safety-in-laboratories-planning-and-operational-aspects\/","title":{"rendered":"Review of Draft Standard: AS 2243.1 Safety In Laboratories \u2013 Planning and Operational Aspects"},"content":{"rendered":"<p>One way I keep myself up to date with developments within laboratories and related areas is by reviewing draft standards.\u00a0 This keeps me appraised of the current state of affairs, keeps my documentation audit skills fresh and potentially allows me to contribute to the content of standards.<\/p>\n<p>Here I step through the draft standard making comments.\u00a0 Where a comment is answered later in the standard, I go back to my original comment and make notes.\u00a0 An uncommented comment is potentially worthy of becoming an official comment on the standard.<\/p>\n<p><em><strong>Update 20190103:<\/strong> page nubmers added.<\/em><\/p>\n<p><strong>Section 1<\/strong><!--more--><\/p>\n<p><em>1.4.19- page 4<br \/>\n<\/em><\/p>\n<p>Defines an incident (unplanned risk to safety):<\/p>\n<p>Do we need to spell out what a planned activity that could have a potential for injury, ill-health, damage or other loss is?\u00a0 <em>Section 3.1.3.6 part c<\/em> details recording and maintaining a record of incidents.<\/p>\n<p><em>1.4.34 Working in isolation: &#8211; page 6<br \/>\n<\/em><\/p>\n<p>How isolated is isolated?\u00a0 Long corridors? Afternoon or night shift based on day shift and reduced staffing?\u00a0 <em>NOTE: Section 3.1.2 Risk Assessment (f) discusses the differences between normal and outside normal working hours<\/em>.\u00a0 <em>3.4.4 Working in isolation<\/em> provides further detail.<\/p>\n<p><strong>Section 2<\/strong><\/p>\n<p><em>2.2.4 Eating facilities &#8211; page 7<br \/>\n<\/em><\/p>\n<p>States should be outside of lab.\u00a0 The obvious (do not store or consume food\/drink INSIDE THE LAB) is not stated.\u00a0 This is stated in <em>4.1 Requirements for safe conduct sub section i <\/em>and<em> j<\/em>.\u00a0 No Caf-pow for you!<\/p>\n<p><em>2.2.6 Write-up areas &#8211; page 7<br \/>\n<\/em><\/p>\n<p>States write-up areas should be separated but does not define what a write up area is (eg, is recording data a write up function, or is writing a report or reviewing data a write up function).\u00a0\u00a0 Could a potentially contaminated pen be used in a write up area?\u00a0 Can lab coats used in non write up areas be used in write up areas?\u00a0 I recommend segregation of items such as these. (an official comment would need suggested text)<\/p>\n<p><em>2.5.3 Labelling &#8211; page 9<br \/>\n<\/em><\/p>\n<p>Should there be a statement regarding disposal or non-labelled liquids and unidentifiable solids?\u00a0 Treat as if contaminated or dangerous chemicals?\u00a0 This is covered in <em>4.1 Requirements for safe conduct sub section l: <\/em>\u201cregard all substances as hazardous unless there is definite information to the contrary.\u201d<\/p>\n<p><strong>Section 3<\/strong><\/p>\n<p><em>3.1.3.2 Training and induction page 17<br \/>\n<\/em><\/p>\n<p>States training needs to be performed.\u00a0 Says nothing about assessing effectiveness of training, nor about retraining.<\/p>\n<p>Suggestion:<\/p>\n<p>\u201c[e] Training should be periodically reassessed on a schedule and records of such reassessment shall be maintained.\u201d<\/p>\n<p><em>3.1.3.3 Safe operation &#8211; page 18<br \/>\n<\/em><\/p>\n<p>I like that section (g) states \u201cSuggestions for improvements\u2026made by the staff and&#8230;action taken\u2026shall be recorded.\u201d<\/p>\n<p>Suggestion:<\/p>\n<p>\u201c [k] (or as a note) \u201cAll reviews arrangements or developed procedures should be documented and maintained\u201d.\u00a0 Alternately add to each section [a..l] where not present.<\/p>\n<p><em>3.1.3.5 Safety Equipment &#8211; page 18<br \/>\n<\/em><\/p>\n<p><em>Sub section c<\/em>: \u201cNOTE The requirement for visitors may vary depending on the activities and risk exposure.\u201d\u00a0 Here I would argue that the PPE worn should match that of the highest risk within that section of the lab, regardless of what the visitor is doing in that section of the lab.\u00a0 At the very least, such an assessment should be documented, preferably by a standard procedure and the presence of visitors recorded and such logs maintained.\u00a0 Recording visitors is essential when combined with <em>3.2.3 Evacuation of the building<\/em> to ensure everyone is accounted for.<\/p>\n<p>Note: section 4.2.1 states training is required in the use of PPE so here I suggest:<\/p>\n<p>\u201c[d] Visitors should be recorded along with training in the use of PPE as per Section 4.2.1 General use of personal protective equipment (PPE).<\/p>\n<p>[e] In the event of an evacuation, refer to Section 3.2.3 Evacuation of Building for additional actions.\u201d<\/p>\n<p><strong>Section 4<\/strong><\/p>\n<p><em>4.1 Requirements for safe conduct &#8211; page 20<br \/>\n<\/em><\/p>\n<p><em>Sub section g:<\/em> \u201cdo not indulge in reckless behaviour\u201d.\u00a0 Presumably that means immediate risk, not conducting something that might be seen as a reckless experiment in 10+ years.<\/p>\n<p>Sub section u: Disposal of specialised wastes.\u00a0 When using \u201cbuckets\u201d these have a maximum fill line.\u00a0 Perhaps state that this line should not be exceeded.<\/p>\n<p>Suggestion:<\/p>\n<p>[u] \u201c\u2026where waste bins have a maximum fill line, this should not be exceeded.\u201d<\/p>\n<p><em>4.2.1 General (use of PPE) &#8211; page 21<br \/>\n<\/em><\/p>\n<p>States training shall be provided to all users, so keep this in mind when a visitor to the lab is required to wear PPE. Suggestion added to section 3.1.3.5.<\/p>\n<p><em>4.2.2 Clothing &#8211; page 22<br \/>\n<\/em><\/p>\n<p>The recommendation of wrap around, back opening laboratory coats with quick release textile fasteners is interesting as the traditional front opening buttoned (or stud pin) lab coat is what is seen in the media and used traditionally.<\/p>\n<p>Perhaps for chemical labs, traditional coats could be used as they are faster to remove (marginally and subjectively) than the specified type of clothing.\u00a0 That could be important in the event of an incident.<\/p>\n<p><em>4.5.1 Handling of glass &#8211; page 25<br \/>\n<\/em><\/p>\n<p>\u201cManipulation of glass is the cause of many injuries in laboratories.\u201d\u00a0 No reference.\u00a0 No definition of many.\u00a0 Possibly redundant sentence. Suggestion: remove this statement.<\/p>\n<p><em>4.5.7 Operations involving cryogenic liquids &#8211; page 26<br \/>\n<\/em><\/p>\n<p>Contains the sentence \u201cOxygen depletion through displacement of air released by gas can cause asphyxiation\u2026\u201d\u00a0 Seems redundant since the same sentence appears in <em>Section 4.5.6 Operations involving compressed and liquefied gases<\/em>.\u00a0 Suggestion: remove this statement.<\/p>\n<p><em>4.5.10 Handling of human biological material &#8211; page 27<br \/>\n<\/em><\/p>\n<p>Suggestion: rename to \u00a0\u201cHandling and testing of human biological material\u201d as people are the main source of biological material so unless this section also deals with sick or infected laboratory staff, or people shedding in general, the title needs to be specific to its subject matter.<\/p>\n<p><em>4.5.12 Temperature measurement &#8211; page 27<br \/>\n<\/em><\/p>\n<p>The use of thermometers is proscribed. However, there is no requirement for such equipment to be calibrated or validated.\u00a0 This creates risk with regards to product and the validity of results coming out of laboratory ovens and incubators.<\/p>\n<p>Suggestion:\u00a0 Add the following statement \u201cTemperature measurement devices should be validated and routinely calibrated and records of such activities maintained.\u201d<\/p>\n<p><em>4.7.3 Use of traps &#8211; page 28<br \/>\n<\/em><\/p>\n<p>Seems to be a lot of explanation rather than direction.\u00a0 Justification for direction in each section should be provided in order to make this document consistent. \u00a0Alternately leave all explanations out of the standard and state directives only (or put them in an appendix).<\/p>\n<p>Suggestion: leave out explanations.<\/p>\n<p><em>4.10 Handling, labelling and disposal of laboratory wastes<br \/>\n<\/em><\/p>\n<p><em>4.10.2 Collection &#8211; page 30<br \/>\n<\/em><\/p>\n<p>Chemical waste is singled out as needing to be clearly identified and segregated.\u00a0 Biological and cytotoxic waste and sharps and broken glassware should also be clearly identified and potentially segregated. This is covered in <em>Section 4.10.3 Segregation<\/em>.<\/p>\n<p>\u201cEach waste category should be clearly labelled with the identity and source (department of laboratory) of the waste.\u201d\u00a0 This is not something I remember as needing to be done up to at least 6 years ago, so it may be new.\u00a0 If new, then the additional administrative burden on labs which may or may not impact on business processes.\u00a0 From a practical standpoint, adding a sticker\/label to each waste bin, bag or container stating the source would be sufficient.<\/p>\n<p><strong>Did you find this informative or useful? Please consider a small donation so I can expand and improve on what I deliver.<\/strong><\/p>\n<p><input title=\"PayPal - The safer, easier way to pay online!\" alt=\"Donate with PayPal button\" name=\"submit\" src=\"https:\/\/www.paypalobjects.com\/en_AU\/i\/btn\/btn_donateCC_LG.gif\" type=\"image\" \/><img loading=\"lazy\" decoding=\"async\" src=\"https:\/\/www.paypal.com\/en_AU\/i\/scr\/pixel.gif\" alt=\"\" width=\"1\" height=\"1\" border=\"0\" \/><\/p>\n","protected":false},"excerpt":{"rendered":"<p>One way I keep myself up to date with developments within laboratories and related areas is by reviewing draft standards.\u00a0 This keeps me appraised of the current state of affairs, keeps my documentation audit skills fresh and potentially allows me to contribute to the content of standards. Here I step through the draft standard making [&hellip;]<\/p>\n","protected":false},"author":1,"featured_media":0,"comment_status":"open","ping_status":"open","sticky":false,"template":"","format":"standard","meta":{"footnotes":""},"categories":[7,5,17,2],"tags":[29,42,35],"class_list":["post-801","post","type-post","status-publish","format-standard","hentry","category-commentary","category-documentation","category-how-i-benefit-you","category-the-regs","tag-documentation","tag-regulations","tag-standards"],"_links":{"self":[{"href":"https:\/\/paulyeatman.net.au\/index.php\/wp-json\/wp\/v2\/posts\/801","targetHints":{"allow":["GET"]}}],"collection":[{"href":"https:\/\/paulyeatman.net.au\/index.php\/wp-json\/wp\/v2\/posts"}],"about":[{"href":"https:\/\/paulyeatman.net.au\/index.php\/wp-json\/wp\/v2\/types\/post"}],"author":[{"embeddable":true,"href":"https:\/\/paulyeatman.net.au\/index.php\/wp-json\/wp\/v2\/users\/1"}],"replies":[{"embeddable":true,"href":"https:\/\/paulyeatman.net.au\/index.php\/wp-json\/wp\/v2\/comments?post=801"}],"version-history":[{"count":8,"href":"https:\/\/paulyeatman.net.au\/index.php\/wp-json\/wp\/v2\/posts\/801\/revisions"}],"predecessor-version":[{"id":1199,"href":"https:\/\/paulyeatman.net.au\/index.php\/wp-json\/wp\/v2\/posts\/801\/revisions\/1199"}],"wp:attachment":[{"href":"https:\/\/paulyeatman.net.au\/index.php\/wp-json\/wp\/v2\/media?parent=801"}],"wp:term":[{"taxonomy":"category","embeddable":true,"href":"https:\/\/paulyeatman.net.au\/index.php\/wp-json\/wp\/v2\/categories?post=801"},{"taxonomy":"post_tag","embeddable":true,"href":"https:\/\/paulyeatman.net.au\/index.php\/wp-json\/wp\/v2\/tags?post=801"}],"curies":[{"name":"wp","href":"https:\/\/api.w.org\/{rel}","templated":true}]}}