Shared Lab Spaces in Pharma & Life Sciences: Know Your EHS Risks

Pharmaceutical, life science, and biotech incubators and accelerators are designed to assist with the growth and success of companies by providing various types of business support and resources. Specifically, incubators are companies formed in the "idea" stage and need assistance from the ground-up. Accelerators, on the other hand, need assistance in progressing their business. Both incubators and accelerators often require support from established companies such as a physical place to work, shared laboratory spaces, capital, and networking connections.

Shared laboratory spaces are a popular option for pharmaceutical and life science start-up organizations to allow them a physical space to work and provide various types of business resources, including environmental, health, and safety (EHS) support. EHS responsibilities fall to the employer, however, the tenant or the landlord may take ownership depending on each contractual agreement. This makes communication between the landlord and tenant crucial. All lease agreements will vary as an incubator or accelerator, but below are a few common EHS risks to consider when operating a shared laboratory space.

Emergency Preparedness
Regardless of responsibility, all tenants of a shared lab space should be aware of how to prepare for and respond to potential emergencies. Emergencies may include building evacuations, chemical/biological releases, fires, severe weather, medical emergencies, or other unplanned events. It is possible that the landlord, parent company, or investment firm provides the shared lab space with evacuation maps for the tenants to follow, but if not, conducting a building walkthrough and determining an evacuation route and associated muster point will ensure everyone will exit the building safely. Additionally, maintaining a list of all potential employees, contractors, and visitors for the company to conduct a headcount once everyone has evacuated to the designated muster point is essential. Landlords in certain jurisdictions may be required to conduct emergency evacuation drills. Required or not, it is a good idea to conduct these drills on a periodic basis to ensure employees are prepared in the event of a real evacuation.

A formalized Emergency Action Plan (EAP) will inform employees on how, where, and when to exit the building, shelter in place, and steps to take in the event of an emergency. Additionally, ensure procedures are in place for employees to shut down hazardous processes prior to evacuating the space.

It is important to discuss with the landlord who is responsible for supplying, inspecting, and maintaining emergency equipment including fire extinguishers, fire suppression systems, emergency eyewash stations/showers, and first aid kits. This will provide reassurance that employees working within these spaces are provided with adequate and working emergency equipment if they need it.

Chemical Labeling
Oftentimes, shared lab spaces may also share chemicals. As per the Occupational Safety and Health Administration (OSHA)’s Hazard Communication Standard (29 CFR 1910.1200) and the Globally Harmonized System (GHS), all chemicals must be labeled to inform employees of the product identifier, supplier information, hazard pictogram, signal word, hazard statements, and precautionary statements. Original containers from the manufacturer already have these components on the container label. Secondary containers require labeling as well, so it is crucial to maintain these labels with a system that everyone in the shared lab space will understand. This can be accomplished through an annual Hazard Communication training with all employees.

Ventilation and Lab Hoods
If the lab space uses lab hoods to ventilate chemical fumes, OSHA’s Occupational Exposure to Hazardous Chemical in Laboratories Standard (29 CFR 1910.1450) requires that these hoods and other protective equipment are functioning properly and that specific monitoring must be conducted to ensure adequate and proper performance of this equipment. Not only is this a regulatory requirement, but it is crucial to minimizing employee chemical exposure. Using a hood that does not provide sufficient ventilation has the potential of exposing employees to unhealthy hazardous chemicals. If lab hood testing falls to the tenant, it is in their best interest to secure a means to test the hoods to ensure adequate airflow.

Housekeeping
Shared lab spaces can become overcrowded very quickly. Many labs have equipment and materials that are cycled in and out due to the nature of the work being performed. As such, labs may receive shipments of consumables on a regular basis, and these shipments may block safety equipment such as exits, fire extinguishers, or electric panels. Shipments may also pose slip, trip, and fall hazards, especially in a shared lab environment where boxes may belong to one tenant. Working as a team and ensuring equipment and materials are not obstructing walkways, exits, and emergency equipment is key to preventing slips, trips, and falls, or other related incidents in the lab.

Equipment Licenses and Environmental Permits
Some lab equipment may require registration as per state or local (e.g. department of health) regulations, such as units with ionizing radiation (e.g. x-rays, etc.), air compressor tanks, devices with certain classifications of lasers (e.g. cell sorters), and more. Equipment registration can easily be forgotten about but is an important aspect of maintaining regulatory compliance. It is also important to maintain current with registrations as equipment may be removed from the lab space. Registration must be renewed at varying frequencies depending on the guidance set forth by the regulating agency. Some are set to just an initial registration while others may be set to an annual or biannual basis.

Environmental-related permits may be required if the operations entail the generation, handling, and/or disposal of biohazardous hazardous waste or regulated medical waste, production of air emissions as a byproduct from a process, or require the discharge of wastewater to a municipal water supply. Since liability regarding the lab space will likely fall to the tenant (owner of the operations), the tenant should discuss anticipated lab operations and required environmental permits prior to beginning the lease agreement to avoid potential conflicts.

Taking Ownership of EHS Responsibilities
As an operator of a shared lab space, it is essential to understand the EHS responsibilities and risks to ensure no items have been missed through the shared ownership of the space. This should be fostered through an open line of communication between the tenant and the landlord so that all responsibilities are understood and clearly communicated.

The topics outlined above are a great starting point in bolstering EHS compliance. While compliance is certainly important, ensuring employees remain safe and environmental exposures are properly managed is also key to a successful shared lab space. Obtaining employee buy-in to EHS compliance will help exhibit a strong EHS culture. To drive EHS culture within the shared office space, there should be a means for employees to communicate concerns both directly and anonymously, and they should have the opportunity to be engaged in EHS improvement projects. Engaging employees may be as simple as asking them for feedback, listening to concerns, or inquiring on ways they feel the work environment could be safer. This communication will empower workers to take ownership of EHS resulting in a collaborative and safe shared lab space.

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