audit-laboratory-safety

Audit Laboratory Safety

Systematically evaluate a chemistry laboratory for regulatory compliance, hazard control, and emergency preparedness.

Why This Is Best Practice

Adopted by: OSHA (29 CFR 1910.1450 mandatory for US academic labs), EPA waste regulations (40 CFR 262), NFPA 45 fire protection standard, NIH/NSF grant compliance requirements, UK COSHH regulations.

Impact: OSHA laboratory standard reduced lab injury rates by 35% in the decade following its 1990 adoption; ACS survey found 60% of lab accidents attributed to inadequate training or PPE — both correctable by audit.

Why best: Systematic audit with checklist prevents omission of hazard categories; documented audits create accountability and track improvement over time; regulatory compliance prevents penalties up to $156,259 per willful violation (OSHA 2023).

Sources: OSHA 29 CFR 1910.1450; ACS "Safety in Academic Chemistry Laboratories" 8th ed. (2017); NFPA 45 (2019); EPA 40 CFR 262 (hazardous waste).

Steps

1. Review the Chemical Hygiene Plan (CHP) — verify the CHP is current (<3 years), accessible in the lab, and covers all chemical classes present. OSHA requires a written CHP; its absence is a citable violation.

2. Audit chemical inventory and SDS — confirm Safety Data Sheets (SDS, GHS format) are present and accessible for every chemical. Check that the inventory is current and quantities match storage limits (NFPA 45 MAQs).

3. Inspect chemical storage — verify: incompatible chemicals segregated (acids from bases, oxidizers from organics); flammables in rated cabinets; peroxide-forming chemicals dated and within expiration; cryogens stored in vented dewars.

4. Evaluate PPE compliance — check availability and condition of: nitrile/chemical gloves (correct grade per chemical), safety glasses/goggles/face shield, lab coat (cotton/flame-resistant as appropriate), closed-toe shoes. Verify personnel are trained in PPE selection.

5. Inspect engineering controls — test fume hood face velocity (target 80–100 fpm per ASHRAE 110); verify biosafety cabinets are certified (<12 months); check that ventilation systems have no blockages.

6. Check emergency equipment — verify: eyewash station flushes both eyes simultaneously, reachable within 10 seconds of hazard (<55 ft); safety shower delivers 20 gal/min for 15 min; fire extinguisher charged and inspected within 12 months; spill kit stocked for chemical classes present.

7. Review waste management — confirm: satellite accumulation containers labeled with "Hazardous Waste" + contents + accumulation start date; containers closed except when adding waste; waste not accumulated >55 days (large generator) or >180 days (small quantity generator).

8. Assess training records — verify documented training for: Lab Safety Orientation, CHP, specific chemical hazards (carcinogens, reproductive toxins, acutely toxic), emergency procedures. Training must be documented with date and signature.

9. Evaluate electrical and fire hazards — check: no extension cords as permanent wiring; circuit breakers accessible; no food or drink in lab; heating elements (hotplates, mantles) have automatic shutoff or supervision protocol.

10. Document findings and corrective actions — record each deficiency with: location, regulation citation, risk level (critical/serious/minor), responsible person, and target correction date. Re-audit corrective actions within 30 days for critical findings.

Rules

• Critical findings (missing SDS, non-functional eyewash, unlabeled hazardous waste) require immediate correction or work stoppage — do not defer.
• Audit findings must be documented and signed; verbal-only audits are unenforceable and provide no liability protection.
• Include lab personnel in the audit walk-through — this is also a training opportunity.
• Cross-reference against the most current local regulations; OSHA sets the floor, but state plans (Cal/OSHA, NYSDOL) may be more stringent.

Common Mistakes

• Checklist without follow-up — identifying deficiencies without assigned owners and deadlines results in no improvement.
• Ignoring peroxide-forming chemicals — ether, THF, dioxane form explosive peroxides; unlabeled/undated containers are a serious explosion risk.
• Fume hood sash left up — a fully open sash reduces face velocity by 50%; occupants frequently leave hoods open between uses.
• Treating SDS access as satisfied by a binder in the office — SDS must be immediately accessible at the point of use during the work shift.

When NOT to Use

• For radiological or biological safety audits — those require separate domain expertise (radiation safety officer, biosafety officer) and distinct regulatory frameworks
• For process safety management (PSM) in industrial facilities — PSM (OSHA 29 CFR 1910.119) applies to highly hazardous chemicals above threshold quantities and requires a different audit protocol
• For a general workplace safety audit unrelated to chemical hazards (use OSHA General Industry standards instead)