From: Kim Auletta <kim.auletta**At_Symbol_Here**STONYBROOK.EDU>
Subject: Re: [DCHAS-L] food and drinks in lab areas
Date: September 26, 2012 7:53:04 AM EDT
Reply-To: DCHAS-L <DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU>
Message-ID: <E0B74F9D-B10B-4930-BCE9-7812FBAD2586**At_Symbol_Here**ppeppro.com>


Our architect & I put together this list of food & drink in labs regulations to provide to people when they want to know why they need to design in a kitchenette or why they can't eat/drink in a lab. BMBL is only 1 of the requirements.


FOOD AND DRINK IN LABS =97 REGULATIONS & STANDARDS OF CARE
REGULATIONS:
OSHA's Sanitation Standard - 29CFR1910.141
"(g) Consumption of food and beverages on the premises. . . .
(2) Eating and drinking areas. - No employee shall be allowed to consume food or beverages in a toilet room nor in any area exposed to a toxic material."

OSHA's Bloodborne Pathogens Standard - 29CFR1910.1030
"(d) Methods of Compliance.- . . .
(ix) Eating, drinking, smoking, applying cosmetics or lip balm, and handling contact lenses are prohibited in work areas where there is a reasonable likelihood of occupational exposure.
(x) Food and drink shall not be kept in refrigerators, freezers, shelves, cabinets or on countertops or bench tops where blood or other potentially infectious materials are present.

LICENSING REQUIREMENT(S):
Radioactive Material User's Guide =97 Rules for Use of Radioactive Material
"Eating, drinking, smoking, the application of cosmetics or other similar activities which could lead to the uptake of radiation contamination are prohibited n areas where unsealed radioactive materials are being used".
NOTE: These rules must be followed by all users of radioactive materials due to a condition in our broad license.

STANDARDS OF CARE:
National Research Council's Prudent Practices in the Laboratory, 1995.
"5.C.2.2 Avoiding Ingestion of Hazardous Chemicals Eating, drinking, smoking, gum chewing, applying cosmetics, and taking medicine in laboratories where hazardous chemicals are used should be strictly prohibited. Food, beverages, cups, and other drinking and eating utensils should not be stored in areas where
hazardous chemicals are handled or stored. Glassware used for laboratory operations should never be used to prepare or consume food or beverages. Laboratory refrigerators, ice chests, cold rooms, ovens, and so forth should not be used for food storage or preparation. Laboratory water sources and deionized laboratory water should not be used for drinking water.

5E-1 Biohazardous Materials
Never eat, drink, smoke, handle contact lenses, apply cosmetics, or take or apply medicine in the laboratory.
5E-2 Radioactive Materials
Never eat, drink, smoke, handle contact lenses, apply cosmetics, or take or apply medicine in the laboratory, and keep food, drinks, cosmetics, and tobacco products out of the laboratory entirely so that they cannot become contaminated.
CDC/NIH Biosafety in Microbiological and Biomedical Laboratories "Standard Microbiological Practices" for ALL Biosafety Level 1- Level 4 labs include the following:
3. Eating, drinking, smoking, handling contact lenses, and applying cosmetics are not permitted in the work areas where there is reasonable likelihood of exposure to potentially infectious materials. Food is stored outside the work area in cabinets or refrigerators designated for this purpose only.

OSHA's Occupational exposure to hazardous chemicals in laboratories - 29CFR1910.1450
Appendix A - National Research Council Recommendations (1981) Concerning Chemical Hygiene in Laboratories (Non-Mandatory)
"E. Basic Rules for Working with Chemicals
1. General Rules
(D) Eating Smoking, etc.: Avoid eating, drinking, smoking, gum chewing, or
application of cosmetics in areas where laboratory chemicals are present; wash hands before conducting these activities.
Avoid storage, handling, or consumption of food or beverages in storage areas,
refrigerators, glassware or utensils which are also used for laboratory operations.

Kim Gates Auletta
Laboratory Safety Specialist
Environmental Health & Safety
Stony Brook University
Stony Brook, NY 11794-6200
kim.auletta**At_Symbol_Here**stonybrook.edu
631-632-3032
FAX: 631-632-9683
EH&S Web site: http://www.stonybrook.edu/ehs/lab/



On Tue, Sep 25, 2012 at 7:55 PM, Steve Crooks <scrooks**At_Symbol_Here**ppeppro.com> wrote:
Kathy,

If it gives you any comfort, even the safety professionals in giant institutions with titles like director, VP, Vice Chancellor, etc, should only be advisors. You're taking the right approach.

I see another plug for Dan Petersen being in order.

http://books.google.com/books/about/Techniques_of_safety_management.html?id=JJJgAAAAMAAJ

Sent from my iPhone

On Sep 25, 2012, at 5:03 PM, Kathy Rusniak <krusniak**At_Symbol_Here**NANOINK.NET> wrote:

Thank you for the information and insightful comments. My company is small and there is little support even for issues which seem relatively clear to me. Also, as coordinator, my position is advisory only so my opinions tend to be creatively interpreted unless department managers and upper management actively enforce the regulations within their groups.

Kathy Rusniak

R&D Engineer & Safety Coordinator

NanoInk, Inc.


IMPORTANT NOTICE: This email contains information from the sender that may be CONFIDENTIAL, LEGALLY PRIVILEGED, PROPRIETARY or otherwise protected from disclosure. This email is intended for use only by the person or entity to whom it is addressed. If you are not the intended recipient, any use, disclosure, copying, distribution, printing, or any action taken in reliance on the contents of this email, is strictly prohibited.

From: DCHAS-L Discussion List [mailto:dchas-l**At_Symbol_Here**MED.CORNELL.EDU] On Behalf Of Eric Clark
Sent: Tuesday, September 25, 2012 1:07 PM
To: DCHAS-L**At_Symbol_Here**MED.CORNELL.EDU
Subject: Re: [DCHAS-L] food and drinks in lab areas

The BMBL-5 under B 10 Special Practices states "All procedures involving the manipulation of infectious materials that may generate an aerosol should be conducted within a BSC or other physical containment devices."

But as we know, spills and other unexpected things can happen - even in a BSL-2 area - despite our best efforts to keep the micro-organisms contained. That's why, e.g., the microbiologists working with rabies have all the recommended immunizations as well as ppe, even though the work is done in biosafety cabinets. Sawing through an animal skull to retrieve a brain tissue specimen will definitely produce aerosols. [BTW, not only is there an aerosol risk, but saws and scalpels are sharp tools.]

Plus there's the possibility that someone's forgotten moldy lunch could cross-contaminate lab work. BMBL-5 under B 9 Special Practices states "Animal and plants not associated with the work being performed must not be permitted in the laboratory."

Stay with the program. Don't try to justify relaxing the industry standard because some employees find certain laboratory policies inconvenient. Would we be having this same discussion about BSL-3 (or 4?!) containment practices?

Bottom line ==> Keep food, animals, and plants out from within the high solid walls of the lab area.

Eric Clark, MS, CCHO, CHMM

Safety & Compliance Officer

Los Angeles County Public Health Lab

The interesting thing here is that the boundaries are drawn by the employees based on their convenience rather than any valid hazard or risk assessment procedure.

Dan Crowl
Michigan Tech

On Sep 25, 2012 12:28 PM, "Steve Crooks" <scrooks**At_Symbol_Here**ppeppro.com> wrote:

If there are aerosolized microorganisms of concern then the space inside even a hard-walled lab has to be questioned.. My experience is that in cases where lab design has unfortunately allowed for the "open concept", an administrative barrier or demarcation can be acceptable so long as PPE "wandering" is rigidly enforced from happening, hand washing after lab work occurs and airflow is supplied over cube spaces and exhausted from w/in actual lab space. That said, I wouldn't give in unless you have to and preferred is what Eric states. However, picking your battles and having credibility when you really need it is also at play. Requiring hand washing before eating is better control than a wall and I'd start with that skirmish then move to the battle for money to segregate spaces better. Remind your local "lab architect" that we prefer leaving open concepts to the homes on DIY network.

Steve Crooks, MS, CIH, CSP

People, Property & Env. Protection, Inc.


Sent from my iPhone


On Sep 25, 2012, at 11:46 AM, Eric Clark <erclark**At_Symbol_Here**PH.LACOUNTY.GOV> wrote:

Kathy,

Consult the Biosafety in Microbiological and Biomedical Laboratories 5th edition for specifics on how to run a BSL-2 lab. These policies were developed and fine tuned over the years to keep people safe. You can Google it to get the CDC on-line PDF version.

Under the BSL-2 section in Part A 3 it states "Eating, drinking, smoking, handling contact lenses, applying cosmetics, and storing food for human consumption must not be permitted in laboratory areas. Food must be stored outside the laboratory area in cabinets or refrigerators designated and used for this purpose."

An administrative barrier such as a half wall (or sign, or brightly painted yellow line on the floor)does not prevent aerosolized micro-orgasms from crossing over onto someone's food.

Eric Clark, MS, CCHO, CHMM

Safety & Compliance Officer

Los Angeles County Public Health Lab

Hi all,

I'm hoping to get some advice regarding an ongoing issue in some areas of my company…

It seems straightforward enough that food and drinks are not allowed in lab areas, but the problem keeps cropping up. A BSL2 lab has cube space between two BSL2 work areas. The walls are only half-walls but the residents of these desks want their food and drinks and the manager of the lab put tape down to say the BSL2 areas are outside of the cube area and that it is reasonably safe to have food and drinks in the cubes. I thought the rule was that the dividing walls had to be floor to ceiling. Anyone else have a similar situation in conjunction with a BSL2 work area?

Another lab used to not have chemicals, and people would drink/eat while at computers. Now there are chemicals stored and used in the lab, and of course people are trying to still eat/drink. We (safety) put a stop to that, but then they put tape down and made an area that is =91no chemicals or work materials' allowed and they put a table, chairs and a mini-fridge. My opinion is that food and drinks should not be allowed in this lab at all, although maybe there is some way to permit closed drink containers in a designated area? But the mini-fridge seems out of my scope of allowable items in a lab that also stores/uses toxic chemicals. Of course I've reviewed the regulations and they support no food/no drinks in at least the case of the chemical laboratory. But are there allowable exceptions? Right now my views are being considered employee unfriendly, and while I'm not worried about that, I want to make sure I've researched the situation thoroughly so that I'm not being overly strict. (Note: my company safety officer is "new" to safety…)

Any information or specific instances/experiences you can share with me would be most helpful and appreciated.

Best regards,

Kathy Rusniak

R&D Engineer & Safety Coordinator

NanoInk, Inc.

(847) 745-3605 direct

(847) 679-8767 fax

(847) 679-NANO main

NanoInk, Inc.

8025 Lamon Ave.

Skokie, IL 60077

krusniak**At_Symbol_Here**nanoink.net

www.nanoink.net


IMPORTANT NOTICE: This email contains information from the sender that may be CONFIDENTIAL, LEGALLY PRIVILEGED, PROPRIETARY or otherwise protected from disclosure. This email is intended for use only by the person or entity to whom it is addressed. If you are not the intended recipient, any use, disclosure, copying, distribution, printing, or any action taken in reliance on the contents of this email, is strictly prohibited.


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