Laboratory health & safety…it’s elementary

Just what do those facts and figures in a safety report really mean? Nathan Watson invokes a familiar analogy to investigate the wider issue of compliance In the Sherlock Holmes short story Silver Blaze a prize racehorse is stolen in the night and Scotland Yard quickly apprehends a suspect. While following up on the investigation, the famous consulting detective takes note that when the horse was allegedly taken by the suspect in the middle of the night, the dog in the stable did not bark and wake the stable boys. This leads Holmes to deduce that whoever took the horse must have known the dog and could not have been the suspect in custody. The concluding wisdom that Arthur Conan Doyle leaves us with at the end of the story is that a good investigator collects and understands information, but a great investigator seeks the information that no one has thought to collect. Environmental, Health & Safety departments often face similar challenges due to the way in which safety and compliance record keeping and reporting requirements have evolved over the years. If you get your hands on almost any EH&S annual report from an academic institution, you'll see impressive numbers on how training courses delivered has increased, or how many inspections were conducted, or the extent to which personal protective equipment distribution has grown. Yet, an imaginative observer may realise that a statement like, "1,384 training courses were delivered this year, an increase of 11.5% over last year", lacks the important context to evaluate just how ‘compliant’ the institution has been. Yes, that sounds like a big number, and yes, we can see EH&S has delivered more training courses, but how many were in fact were needed? In this case, the missing denominator of how many courses were required is the dog that did not bark. Without the proper context, an EH&S department can't say with confidence that the job is being done effectively, let alone if their institution is above the bar with regards to regulations. The challenge goes beyond training as well. Without an organised and comprehensive database that begins with a complete list of laboratories, researchers, and laboratory hazards, neither academic research centres nor pharmaceutical companies can easily answer questions similar to the one above with respect to security, inspections, inventories and more. This should leave the organisation’s leadership feeling uncomfortably in the dark about exactly how well they are doing at providing a safe working environment for their researchers. So what should an organisation look for in its fundamental EH&S database? The easiest part is a comprehensive list of laboratories. This is often the only part of the required core dataset that organisations do seem to have in place. The next element that should be collected is a comprehensive list of researchers, with a reference to the laboratories in which they work. This information will give some indication of the kinds of work researchers are doing and hazards they are exposed to, which in turn will inform EH&S of possible compliance needs. However, getting an accurate and timely list of researchers can be oddly challenging, especially in academic settings where researcher turnover can dramatically change the working composition of a laboratory from year to year and all but completely change a roster in just a few years. To overcome this, organisations should seek ways to make their researcher directories as easy to update as possible. Some solutions include linking the EH&S database to an institutional directory such as the HR system via an LDAP. LDAP, which stands for Lightweight Directory Access protocol, can be a great way to provide your EH&S database with baseline user information. In order to keep the EH&S database even further up to date, it should be widely and securely accessible so that Principal Investigators, lab managers, and EH&S staff can quickly update the system as needs arise, such as during inspections when an inspector discovers a researcher that hasn't previously been associated to a laboratory. Laboratories and researchers aren't enough though. Organisations need to know something of the research and work being conducted in a laboratory and by a given laboratory worker in order to clearly understand their compliance and training needs. One might think job titles or registered protocols would be the answer, but a closer examination shows that protocols become out of date too quickly and do not tell enough about the individual work of each researcher. And job titles often do not tell much of the story around the varied and complicated work each researcher pursues each day, and thus it does little to inform anyone of the required safety and compliance tasks. In place of the traditional protocol, one might consider something like a project that more appropriately provides a set of categories of work that might be undertaken in a laboratory. Examples include categories such as "works with recombinant or synthetic nucleic acids" or "works with bloodborne pathogens." These categories elegantly suggest the kinds of compliance and training needed for every researchers working on those projects or every researcher working in the laboratories where those projects are being conducted. Furthermore, these categories can then be applied to individual researchers, giving even greater granularity and value to the researcher profile. What you end up with is a series of related records that might paint the following picture: The elegance of this model is that it creates a fuller picture of the research organisation with rich information that helps EH&S and research administration understand the context on which their safety and compliance status should be based. By building the institutional, laboratory, and researcher directory information from the bottom up, the context translates into numbers. In short, it establishes denominators. Now it is possible for the EH&S annual report to state, "1,384 training courses were delivered this year, an increase of 11.5% over last year. Currently the institution has an overall training compliance score of 92.8%.” Leadership can now ask questions such as, “how effective is the training at reducing accidents", and "do we provide enough funding for EH&S?" And beyond the value of adding needed context (including denominators) to existing compliance, inspection, and training reports, the database information described above creates a clear foundation from which other activities can be driven. Inspections can be planned with a clearer image of what inspectors should expect before entering each laboratory. And if what they find doesn't match the laboratory's profile, the inspectors can note the findings, speak to the Principal Investigator for more information, or update the database on the spot (if the interface is mobile friendly). Training can migrate from the one-size fits all model to one that’s more meaningful and appropriate. Each researcher can receive just the training that they need, reducing wasted time, effectively improving compliance and laboratory safety, and freeing researchers to devote more time to discovery in the laboratory. Author Nathan Watson is president and CEO of BioRAFT, a US-based provider of enterprise laboratory safety, compliance, and training software. Contact Media@BioRAFT.com