OSHA | Mac's Safety Space

Fit-testing woes may trace back to financial aloofness

As a function of the respiratory protection standard, OSHA requires annual fit-testing for folks whose occupational exposure risks indicates the use of respirators. In the past, OSHA was prohibited from enforcing that aspect of the standard, largely in response to pleas to Congress from the various and sundry state, regional, and national hospital groups.

So, effectively, there was a grace period for hospitals. This did very little, if not nothing, in the way of preparations for 2008’s change of position, when OSHA and Congress decided to start enforcing the fit-testing requirements.

Hospitals are absolutely struggling with this. Some continue to struggle with initial fit-testing requirements, never mind having to deal with any recurring frequencies. In analyzing the financial impact of this requirement on hospitals (and, to be honest, I don’t recall the exact figure), there is some sense that perhaps the data used was more modest in nature than practice would bear out.

I suspect it has a lot to do with the fact that hospitals weren’t really in compliance to start with, so when these same hospitals were surveyed by the government and associations to determine likely increases in financial burdens, it seems very possible (maybe leaning all the way over into probable) there was an assumption that they were already in compliance with the incoming testing.

September 15, 2008 | Steve MacArthur | Comments 0

Surveyors thinking beyond a standard

I was thinking more on my last post about surveyors incorrectly citing folks for not having eyewash stations in all patient care areas.

As far as surveyors looking for these eyewash units and not quite getting the citation going in the right direction, I think we can say, without much fear of repudiation (or retribution), that every once in a while, surveyors develop their own interpretive algorithm for those instances in which there is no clear cut regulatory guidance.

By the way, the survey results for eyewash station citations that I have seen generally fall under EC.1.10, EP 5 (implementing procedures in response to risk assessment findings).

However, I feel the “most correct” home for this citation would be EC.3.10, EP 9 (implementing emergency procedures for hazardous materials and waste spills or exposures).

I suppose the interest on the part of the surveyor cadre is also derived, at least tangentially, from the pas de deux that The Joint Commission has been engaged in with OSHA.

That said, from an empirical standpoint, when you look at the limited number of education days allotted to Joint Commission surveyors, is it really any wonder that the points get blurred over time?

May 23, 2008 | Steve MacArthur | Comments 0

Responding to a reader’s comment about eyewash station citations

I read a comment posted by one of you to a blog entry of mine a while back dealing with OSHA requirements for eyewash stations. The poster asked whether anyone else had ever been cited by The Joint Commission for not having eyewash units installed in locations where staff members could be exposed to bodily fluids.

This person’s organization received a supplemental recommendation several years ago for not providing eyewash units in all patient care areas. The given reference was OSHA’s bloodborne pathogens standard, which was an erroneous reference, the commenter said.

That’s an interesting situation, to which my general response (or perhaps it’s really a specific response) is that I haven’t run into anyone who’s been cited for not having eyewash stations where there are blood and body fluid exposure risks.

However, I have seen folks getting cited for not inspecting eyewash stations according to their policy and for not having them in areas where there is a demonstrable risk of chemical exposures.

At any rate, if anyone out there does get cited for not having emergency eyewash stations in the event of blood and body fluid exposures, it would certainly be an opportunity to try out the post-survey clarification process.

The surveyors are not presumed to be infallible, nor should they be (they’re only human). If there’s a lack of understanding, either as a global concept or merely a function of how one operationalizes the results of risk assessments (did you really think that I would go on for this long without invoking the mighty risk assessment?), then it becomes our professional responsibility to point out that understanding gap to surveyors and Joint Commission powers that be.

By the way, thanks to the reader for posting his comment. Keep ‘em coming, this blog is for everyone.

May 21, 2008 | Steve MacArthur | Comments 0

Hospital Safety Symposium coverage: Safety training with a smile

Hi again, it’s Scott Wallask writing from Vegas. I’m not sure I expected to see shoulder massages being given by audience members today, but that’s exactly what happened during Terry Jo Gile’s presentation.

Gile, a safety expert from North Fort Myers, FL, offered “stretch breaks” during her discussion about new developments in laboratory safety, and at point encouraged participants to rub the shoulders of the colleagues sitting next to them.

Yes, the activity was worth a few laughs, but Gile’s take-home message was that safety training with an element of fun or humor is more likely to get people involved.

May 08, 2008 | Scott Wallask | Comments 0

Start your stopwatch to help measure eyewash station needs

The topic of eyewash stations comes up a lot.

In general, OSHA requires eyewash stations in locations in which there is a risk of accidental exposure to corrosive or caustic materials.

There are definitely specific environments-including the food services, boiler rooms, high-level disinfection-where I would be looking for eyewash stations, but only after looking at the chemicals involved.

The need to have an eyewash station in close proximity can be ascertained by looking at the chemical’s first aid instructions, either on the container or on the MSDS. If the first aid information indicates that an exposure to the eyes requires flushing for 15 or more minutes, then you need to have an eyewash station.

If the first aid instructions do not indicate a 15-minute or longer flush after exposure, then you do not “need” to have an eyewash station–though nothing’s stopping you from installing one.

By the way, those lovely little wall-mounted plastic bottles do not meet the standard for emergency eyewash as would be required for conditions noted above.

April 01, 2008 | Steve MacArthur | Comments 0

A quick reminder about our Hospital Safety Symposium

I’ve been working on my slide presentations for the Second Annual Hospital Safety Symposium, so our upcoming show has been on my mind.

I hope to see many of you at the symposium, which will return to Las Vegas on May 8-9. During my sessions, I’ll be discussing risk assessments, clarifying EC survey citations, and what’s on the horizon for the EC standards in 2009.

You can click this link for our full agenda and registration info.

February 05, 2008 | Steve MacArthur | Comments 0

PAPRs, TB fit-testing, and your take

Now that OSHA can enforce annual fit-testing provisions for TB respirators, there’s been a lot of talk about increased use of PAPRs, which don’t require fit-testing because of their design.

But here’s one disadvantage of PAPRs: From a sensitivity to patients standpoint, I think in an emergency, “hooding up” to deal with patients might fly for a bit, but I think ultimately the “comfort level” for patients in isolation will be strained if there’s too much care in the hood.

Imagine if you’re a patient and every time the nurses come in, they have full hoods on-it’s not a cozy image.

Have you considered a more pervasive use of PAPRs to ensure appropriate levels of protection?

January 29, 2008 | Steve MacArthur | Comments 0

Looking for someone who recently posted a TB comment to this blog

Hi everyone, it’s Scott Wallask at HCPro checking in.

I’ve got a quick question: We got a comment posted to Steve Mac’s item about TB fit-testing last week, and the comment from our end appears to be plagued by a software bug. We can’t tell who it was who posted the comment.

If you posted to the blog about the TB fit-testing requirement, could you email me privately?

It’s a problem more on our end, we’re not trying to bust anyone’s chops.

Thanks,

Scott W.

swallask@hcpro.com

January 25, 2008 | Scott Wallask | Comments 0

What are your thoughts about the costs of annual TB fit-testing?

So I see that OSHA–thanks to President Bush signing off on the federal budget–now has the ability to enforce its annual fit-testing requirements for tuberculosis (TB).

This one is going to have some hidden costs. The fact of the matter is, compliance even with initial fit-testing is certainly (based on my observations) inconsistent at best, so some folks are going to have to come at annual fit-testing basically from ground zero.

At any rate, it seems to me that somewhere in the regulatory language (maybe in the post-TB standard stuff) there was some sort of cost estimate that was fairly minimal. And, as I think about it, this isn’t even getting into the issue of fit-testing staff members who are going to be using PAPRs in the event of a decon event.

It’ll be interesting to see if OSHA actually goes after this with any gusto–could get ugly.

What do you think? Is this a big deal? You can click on the comment links below to post your thoughts.

January 16, 2008 | Steve MacArthur | Comments 0

Ban on TB fit-testing is now officially over

Hi everyone, it’s Scott Wallask checking in from HCPro.

It appears the dissolution of the annual tuberculosis fit-testing prohibition is now official, as President Bush signed the fiscal year 2008 budget for labor and health and human services in late December. A record of the bill–numbered H.R. 2764–indicates it is now public law.

OSHA’s budget falls under this bill. In prior years, it was within this area of the budget that you’d find the prohibition of OSHA enforcing annual TB fit-testing. But that prohibition isn’t in the current budget’s wording, which brings to an end a several-year ban on such fit-tests.

Let us know what you think by clicking the comments link below.

Thanks,

Scott Wallask

swallask@hcpro.com

January 08, 2008 | Scott Wallask | Comments 0

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