OSHA | Mac's Safety Space

The Joint Commission posts even more new FAQs

Hi, it’s Scott Wallask checking in quickly. I was on The Joint Commission’s Web site earlier today and saw that three new and/or revised FAQs had been posted last week dealing with [more]

March 16, 2009 | Scott Wallask | Comments 1

Training for gun incidents, from the latest Briefings on Hospital Safety

Hi folks, it’s Scott Wallask logging on today. Given that most hospitals aren’t using metal detectors at the entrance, it’s not a surprise that some visitors enter the facility carrying guns.

In the p. 1 story of our March issue of Briefings on Hospital Safety [more]

February 13, 2009 | Scott Wallask | Comments 0

Use of safety vests by snow-clearing workers hinges on risk assessment

I was recently asked by a safety officer whether staff members who cleared snow from parking lots or mowed lawns need to wear reflective safety vests.

That is a very interesting question, and I do believe it provides me with yet another example [more]

February 11, 2009 | Steve MacArthur | Comments 0

House, Scrubs, and sharps containers

I spent a fair amount of time over the holidays watching the continuing TV adventures of my favorite misanthrope, Dr. Gregory House.

One of the curious things that I’ve noticed (which is clearly a manifestation of my own obsessive compulsive disorder, as well as my consultative nature) is that the sharps disposal containers located in each of the care environments represented in the various episodes of House appear to be mounted at an aperture height of about 72 inches.

And lo and behold, I “bumped” into an episode of Scrubs and the sharps containers appear to be mounted at the same height (unless it’s an optical illusion and everyone on each of the shows is really tiny).

Which makes me wonder–could they produce the risk assessment indicating that particular mounting height is appropriate? The Joint Commission talks of such a risk assessment in one of its official FAQs. Remember, the FAQs hold the same weight as the standards themselves.

January 05, 2009 | Steve MacArthur | Comments 0

Research contends PPE use may be vastly underestimated during a disaster

Hi everyone, it’s Scott Wallask. Hope everyone enjoyed their New Year’s celebrations, however loud or quiet they may have been.

One of HCPro’s free e-newsletters, Infection Control Weekly Monitor, recently published information about a study that surprised me.

The research, published in the Journal of Infection Control, made some stark conclusions regarding personal protective equipment use during a disaster. The study involved a 24-hour flu pandemic exercise in a British hospital.

According to researchers, in the worst-case scenario during the height of a flu pandemic, a ward with patients experiencing the same symptoms could expect to use:

5,250 plastic aprons per week (compared to normal use of 400)
8,400 pairs of gloves per week(compared to normal use of 850)
4,550 surgical masks per week(compared to normal use of less than 10)
100 respirators equivalent to an N99 model per week, a higher protection than common N95 respirators (compared to a normal use of 0)

The surgical mask use represents a 450-fold increase. “This has significant implications not only for cost and procurement, but also for storage. Accommodating supplies on the ward for the 24 hours of the exercise was difficult,” researches wrote in the Journal of Infection Control.

Why did this increase happen? One idea floated by researchers was that staff members lacked confidence in using personal protective equipment during a pandemic response and found the items uncomfortable to wear for long periods, which in turn dragged out the time needed to complete even basic duties.

January 02, 2009 | Scott Wallask | Comments 0

OSHA doesn’t require blood spill kits

Hi everyone, it’s Scott Wallask logging on this morning.

Someone asked me last week about OSHA requirements for blood spill kits under the bloodborne pathogens standard, and my recollection was that there was no such mandate.

But I was curious and researched the standard, and it turns out my gut feeling was correct. Under paragraph (d)(4)(ii)(A) of the standard, OSHA requires the following:

Contaminated work surfaces shall be decontaminated with an appropriate disinfectant after completion of procedures; immediately or as soon as feasible when surfaces are overtly contaminated or after any spill of blood or other potentially infectious materials; and at the end of the work shift if the surface may have become contaminated since the last cleaning.

There is nothing in the standard that specifically notes the need for a blood spill kit, and if you search for the term “kit” in the standard’s wording, nothing comes up.

I also double-checked OSHA’s compliance directive for the bloodborne pathogens standard, which is basically guideline for inspectors. The directive confirms that OSHA’s wording for (d)(4)(ii) represents minimum requirements and that there is no mandate for a kit.

That doesn’t mean you can’t have a spill kit ready to clean up blood, and in some cases it’s probably a best practice. But OSHA leaves that decision up to you.

December 23, 2008 | Scott Wallask | Comments 0

New Joint Commission FAQs posted

Hi everyone, it’s Scott Wallask. Just wanted to give you a quick heads-up that The Joint Commission has updated it’s FAQs page.

Many of the existing FAQs have simply been updated to stay current, but there are also new ones on the following topics:

Labeling of medical gas cylinders
Locking electrical panels
Locking soiled utility rooms
Mounting of sharps containers
Patient-owned equipment
Placement of alcohol-based hand rub dispensers
Smoke-free campuses
Computers-on-wheels in corridors
Sprinkler protection for wardrobe cabinets

FAQs–along with the actual standards and Perspectives newsletter–are the only “official” venues for Joint Commission changes and interpretations, so they’re worth checking out.

November 25, 2008 | Scott Wallask | Comments 0

A quick rundown of certified safety programs

Here are some good resources for certified safety officer training:

The Board Of Certified Hazard Control Management offers a program to become a Certified Healthcare Safety Professional (CHSP) among its slate of certification products. The CHSP designation is probably the one I run into most often (though it is by no means a constant).
The Board of Certified Safety Professionals (CSP) is more of a general safety designation than hospital-specific. The folks I’ve encountered in healthcare with CSPs have generally come from other industries.
The American Hospital Association offers the Certified Healthcare Facility Manager designation, of CHFM.
The International Association of Emergency Managers sponsors an emergency management certification program.
The ECRI Institute’s Center for Healthcare Environmental Management (CHEM) provides certification for healthcare environmental safety professionals.

Has anyone out there gone through other useful certification programs? Post a comment if you have.

November 19, 2008 | Steve MacArthur | Comments 0

The murky origins of CMS and OSHA provisions for fire drill participation

I have heard of inspectors from the Centers for Medicare & Medicaid Services (CMS), as well as some OSHA inspectors, who not only look for attendance records of fire drills, but also look for some sort of accounting on an annual basis of how many staff members actually participated in fire drills.

That said, I’m not exactly sure where the genesis of that particular notion might be.

Some time back, The Joint Commission “relaxed” its requirements for participation in drills to indicate it should be “to the extent called for in the facility’s fire plan” (see EC.5.30). Similar language will be retained in EC.5.30’s successor, EC.02.03.03.

The Life Safety Code doesn’t really get too far into the specifics of drill participation, and CMS’ Conditions of Participation are absolutely mum on the subject of fire drills, never mind participation in them.

Finally, I also checked the applicable OSHA standards and could find no mention of specific documentation or participation requirements.

My best advice would be to really look at who needs to participate in the drills, based on your plan, and develop strategies to get to as many of those folks as possible (I can’t imagine that weekends wouldn’t be in the mix for that).

November 14, 2008 | Steve MacArthur | Comments 0

Eyewash station use should tie into a risk assessment

When it comes to eyewash stations, the starting point really should be:

An assessment of where you currently have eyewash stations, and
A determination of whether the exposure risks warrant the continued presence of the eyewash stations

For instance, from an OSHA perspective, if there is a risk of exposure to caustic or corrosive materials (e.g., glutaraldehyde, acetic acid, etc.), then the use of an eyewash station as part of the first aid sequence is generally indicated.

A good place to check is on the MSDS of a material or substance. If the first aid section indicates flushing the eyes for 15-20 minutes, then that means you need an eyewash station.

On the other hand, with appropriate use of personal protective equipment (PPE) and engineering controls, exposures to bloodborne pathogens should be manageable without the need for eyewash stations.

In a broader sense, I recommend you focus your attention on the stuff that happens before you’d ever need an eyewash station: using less hazardous chemicals, enforcing the use of PPE, etc.

November 04, 2008 | Steve MacArthur | Comments 0

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