What Is a Laboratory Safety Inspection?A Laboratory Safety Inspection is a planned review of the laboratory to identify hazards, verify compliance with established safety procedures, and determine whether existing controls are adequate.
The inspection should consider both conditions and behaviors.
For example, an inspector should not simply verify that a chemical fume hood exists. The inspection should also determine whether the hood appears to be functioning properly, whether employees are using it correctly, whether its airflow is obstructed, and whether required testing and maintenance have been completed.
Likewise, finding a pair of chemical splash goggles in a cabinet does not establish that employees are adequately protected. The inspection should consider whether the correct PPE has been selected for the hazards and whether employees actually use it when required.
A good laboratory safety inspection therefore asks:
What hazards are present?
What controls should be in place?
Are those controls present and functioning?
Are employees actually following the established procedures?
Have previously identified deficiencies been corrected?
Laboratory hazards can develop gradually. Containers deteriorate. Chemicals accumulate. Labels become damaged. Equipment is moved. Fume hoods become cluttered. Emergency equipment becomes obstructed. Procedures change. New chemicals are introduced.
Without periodic review, these changes can create unsafe conditions even in laboratories that were originally well designed.
Regular laboratory inspections can help identify:
OSHA’s nonmandatory laboratory guidance specifically assigns the Chemical Hygiene Officer a role in conducting regular inspections and recommends formal chemical-hygiene and housekeeping inspections, including routine inspections of emergency equipment.
There is not one OSHA regulation requiring every laboratory to conduct the same standardized inspection at the same frequency.
However, laboratories may be subject to numerous OSHA requirements involving inspection, maintenance, testing, hazard assessment, employee protection, and safe operating conditions.
For laboratories covered by 29 CFR 1910.1450, OSHA requires a written Chemical Hygiene Plan that includes criteria for engineering controls, PPE, and hygiene practices. The plan must also require that chemical fume hoods and other protective equipment function properly and establish measures for ensuring their proper and adequate performance.
OSHA’s Appendix A to the Laboratory Standard is explicitly nonmandatory guidance, but it recommends regular inspections as an important part of an effective chemical hygiene program.
Inspections are therefore an effective way to help verify that required laboratory safety systems are actually being implemented and maintained.
The appropriate laboratory safety inspection frequency depends on the laboratory’s hazards, activities, regulatory requirements, equipment, previous findings, and rate of change.
A laboratory handling highly hazardous chemicals or frequently changing experiments may need more frequent inspection than a relatively stable, lower-hazard laboratory.
Rather than relying on one inspection frequency for everything, laboratories should consider several levels of review:
Before or during use: Employees inspect their immediate work area, equipment, PPE, and chemical conditions as part of normal work.
Routine inspections: Supervisors or laboratory personnel periodically review housekeeping, storage, equipment, emergency access, waste, and work practices.
Formal laboratory safety inspections: A more comprehensive documented inspection is conducted according to the organization’s established schedule.
Specialized inspections: Fume hoods, emergency equipment, fire-protection systems, biological safety cabinets, compressed-gas systems, radiation equipment, and other specialized systems may have their own testing or inspection frequencies.
Follow-up inspections: Significant deficiencies should be reinspected to verify that corrective actions were completed.
OSHA’s Appendix A recommends regular inspections but does not prescribe one universal inspection interval for all laboratory conditions.
The frequency should therefore be based on the hazards and applicable requirements rather than choosing an arbitrary schedule and assuming it satisfies every inspection obligation.
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The person conducting the inspection should understand the hazards being evaluated and be capable of recognizing unsafe conditions and practices.
Depending on the laboratory, inspections may involve:
OSHA’s nonmandatory Appendix A identifies conducting regular laboratory, preparation-room, and chemical-storage-room inspections among recommended Chemical Hygiene Officer activities. It also recommends that laboratory supervisors conduct regular chemical-hygiene and housekeeping inspections.
For complex laboratories, a team inspection can be particularly useful because no single inspector may have expertise in every chemical, biological, electrical, mechanical, radiation, or specialized hazard.
A good inspection begins before entering the laboratory.
The inspector should become familiar with the laboratory’s operations and known hazards. Depending on the scope of the inspection, useful information may include:
Previous findings are especially important. A recurring deficiency may indicate a weakness in the underlying safety system rather than an isolated housekeeping problem.
Laboratory safety inspections should not consist solely of walking through the laboratory with a checklist.
Employees performing the work are an important source of information.
Ask employees questions such as:
What are the primary hazards of this procedure?
What would you do if the fume hood stopped working?
Where is the Safety Data Sheet for this chemical?
What PPE is required for this procedure?
What would you do if this chemical spilled?
Are there any safety problems with this equipment?
Are there procedures that are difficult to follow in actual practice?
Have you noticed any recurring safety concerns?
The objective is not to test or intimidate employees. It is to determine whether written procedures and actual laboratory practices match.
When possible, observe normal laboratory operations.
An inspection conducted when no work is occurring can identify physical conditions, but it may miss important work-practice hazards.
Observe how employees:
A laboratory can appear excellent when everything is shut down but still have unsafe operating practices.
Inspect the overall laboratory first.
Look for:
Housekeeping problems can contribute to slips, trips, contamination, fire loading, blocked emergency response, and chemical-storage problems.
Review the chemicals present in the laboratory.
Look for:
OSHA’s Appendix A recommends maintaining an accurate chemical inventory and disposing of or returning chemicals that are no longer needed.
Inspect chemical containers for adequate identification.
Original manufacturer labels should remain legible and should not be removed or defaced. OSHA’s Laboratory Standard specifically requires employers to ensure that labels on incoming containers of hazardous chemicals are not removed or defaced.
Also review secondary containers, solutions, mixtures, samples, reaction vessels, and other laboratory containers according to the laboratory’s labeling procedures.
Pay particular attention to containers marked only with unexplained abbreviations or containers with no identification at all.
An unknown chemical is not merely a paperwork problem. It can create serious hazards during normal use, emergency response, spill cleanup, and waste disposal.
Determine whether employees can readily access applicable Safety Data Sheets (SDSs).
OSHA’s Laboratory Standard requires employers to maintain SDSs received with incoming hazardous chemicals and ensure that they are readily accessible to laboratory employees.
Employees should know where SDSs are located and how to obtain them during their work shift.
Chemical storage deserves particular attention during an inspection.
Look for:
OSHA’s Appendix A recommends separating chemicals according to hazard category and compatibility and keeping incompatible materials separated during transport, storage, use, and disposal.
For additional information, see Chemical Storage and Compatibility.
A laboratory safety inspection should determine whether chemical fume hoods appear to be properly maintained and used.
Look for:
OSHA requires the Chemical Hygiene Plan to ensure that fume hoods and other protective equipment function properly. Its Appendix A recommends that chemical hoods be maintained, monitored, and routinely tested for proper performance.
For additional information, see Chemical Fume Hood Safety.
Inspect both the availability and actual use of laboratory PPE.
Consider:
The inspector should determine whether PPE is appropriate for the hazard—not merely whether PPE is present.
Glove selection deserves special attention because different glove materials provide different levels of chemical resistance. OSHA’s Appendix A specifically recommends careful glove selection based on the chemicals being used.
For additional information, see Laboratory PPE.
Verify that required emergency eyewashes and showers are:
Employees should know where the equipment is and understand that immediate flushing is critical following certain chemical exposures.
OSHA’s Appendix A recommends adequate placement of safety showers and eyewash units and regular testing of emergency equipment.
Inspect emergency preparedness, including:
Employees should understand what to do during a fire, chemical spill, uncontrolled reaction, chemical exposure, ventilation failure, gas release, or other laboratory emergency.
Where compressed gases are present, inspect:
OSHA’s Appendix A specifically includes compressed gas safety among recommended CHP topics.
For additional information, see Compressed Gas Cylinder Safety.
Where cryogenic liquids are used, inspect:
For additional information, see Cryogenic Safety.
Look for:
Laboratory equipment frequently combines electricity with chemicals, water, heat, vacuum, pressure, or other hazards, making apparently minor electrical deficiencies potentially significant.
Inspect laboratory equipment according to the types present.
This may include:
Look for damage, missing guards, unauthorized modifications, overdue maintenance, unsafe electrical connections, and evidence that employees are using equipment differently from the manufacturer’s instructions or established SOP.
Inspect laboratory waste for:
Waste areas should not become long-term storage locations for unidentified or unwanted chemicals.
Where applicable, inspect:
Sharps containers should be appropriately located and replaced before they become overfilled.
Laboratory inspections should also consider security.
Look for:
OSHA’s Appendix A identifies chemical security as part of a comprehensive chemical hygiene program.
Inspection is also an opportunity to verify whether employees have received appropriate training.
OSHA requires employees covered by the Laboratory Standard to receive information and training at initial assignment to an area where hazardous chemicals are present and before assignments involving new exposure situations. Employees must also be trained on applicable details of the written Chemical Hygiene Plan.
Review:
For additional information, see Laboratory Safety Training.
A formal inspection should be documented.
At a minimum, the inspection record should identify:
Laboratory or Department: ___________________________
Location: _________________________________________
Inspection Date: __________________________________
Inspector(s): _____________________________________
Laboratory Supervisor: _____________________________
Chemical Hygiene Officer: __________________________
For each deficiency, document:
Finding: What was observed?
Location: Where was it found?
Hazard: Why does it matter?
Corrective Action: What needs to be done?
Responsible Person: Who will correct it?
Target Date: When should it be completed?
Completion Date: When was it actually corrected?
Verification: Who confirmed the correction?
Photographs can be useful for documenting physical conditions, particularly when the person responsible for correction was not present during the inspection.
Not every inspection finding presents the same level of risk.
A simple classification system can help prioritize corrective actions.
Immediate / Critical: A condition capable of causing serious injury, significant exposure, fire, explosion, or another major event. Work may need to stop until the hazard is controlled.
High Priority: A significant deficiency requiring prompt correction but not necessarily immediate shutdown of the laboratory.
Routine: A deficiency that should be corrected within a reasonable established timeframe.
Observation / Improvement: A condition that may not constitute a violation or immediate hazard but provides an opportunity to improve laboratory safety.
The classification system should be simple enough that employees understand what each category means.
Finding a hazard is only the first half of an inspection program.
The laboratory should have a system for ensuring identified deficiencies are corrected.
A useful process is:
Identify → Document → Prioritize → Assign → Correct → Verify → Close
A deficiency should not be considered closed merely because someone says it has been corrected.
Significant corrective actions should be verified.
For example, if an inspection identifies a failed fume hood, closing the finding may require confirmation that the hood was repaired and its performance verified—not simply that a maintenance request was submitted.
Repeated findings deserve special attention.
Suppose three consecutive laboratory inspections identify chemical containers being stored on the floor.
Moving the containers onto shelves each time addresses the immediate condition, but it does not explain why the problem keeps returning.
The laboratory should ask:
Is there enough storage space?
Are employees ordering excessive quantities?
Is shelving inadequate?
Are storage responsibilities unclear?
Are employees trained?
Is the laboratory layout contributing to the problem?
This moves the inspection process from repeatedly correcting symptoms to improving the underlying safety system.
A Root Cause Analysis may be appropriate for significant incidents, recurring inspection findings, repeated control failures, or serious near misses.
For example:
Finding: Chemical waste containers are repeatedly found open.
Rather than simply closing the containers, ask why they continue to be left open.
Perhaps employees are using funnels that cannot be conveniently removed. Perhaps the waste process is poorly designed. Perhaps employees misunderstand the requirement. Perhaps appropriate closed-system waste funnels were never provided.
The corrective action should address the underlying reason whenever practical.
Significant findings should be followed until correction is verified.
Follow-up may involve:
A corrective-action tracking system should identify open findings and prevent them from disappearing simply because the original inspection report has been filed.
A Laboratory Safety Checklist and a Laboratory Safety Inspection are related but different.
The checklist is the tool.
The inspection is the process.
A checklist provides consistency and helps prevent important subjects from being overlooked. But an effective inspector must look beyond the form.
For example, a checklist might ask:
“Are chemicals properly stored?”
An experienced inspector still needs to recognize an oxidizer stored next to an organic solvent, a peroxide former with crystallization around its cap, or a corrosive container deteriorating on a high shelf.
The checklist guides the inspection; it does not replace knowledge, observation, or professional judgment.
For a ready-to-use inspection tool, see Laboratory Safety Checklist.
A written Laboratory Safety Inspection Report should provide management and laboratory personnel with a clear record of what was reviewed and what needs attention.
A useful report can contain:
This makes the inspection report useful as a management tool rather than simply a record that an inspection occurred.
The strongest inspection programs are continuous rather than isolated events.
Employees identify hazards during daily work. Supervisors perform routine reviews. Formal inspections provide a broader evaluation. Specialized equipment receives required inspection or testing. Corrective actions are tracked. Significant or recurring problems receive additional investigation.
Inspection findings can also reveal broader trends.
If several laboratories have the same chemical-labeling problem, the issue may be training or procedure-related.
If multiple fume hoods are failing, the problem may involve the ventilation maintenance program.
If emergency equipment is repeatedly obstructed, the laboratory may have inadequate storage space.
Looking at inspection results collectively can therefore help identify weaknesses that may not be apparent from any single inspection.
OSHA’s Appendix A describes chemical hygiene as a continuing program involving oversight, safe facilities, planning, training, emergency preparedness, security, and regular inspection activities.
Use a comprehensive Laboratory Safety Inspection Checklist to review chemical storage, labeling, fume hoods, PPE, emergency equipment, compressed gas cylinders, cryogenic materials, laboratory equipment, electrical safety, waste management, housekeeping, employee training, and other common laboratory hazards.
The inspection form should also provide space to document deficiencies, assign corrective actions, establish completion dates, and verify that hazards were corrected.