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From the muddy banks of compliance

Let’s break from form a little bit and start with a question:

How often are you (and by you, I mean your organization) screening contracted staff, including physicians, physician assistants, nurse practitioners, etc.?

A recent TJC survey resulted in a finding under the HR standards because the process was being administered on a biannual cycle. The finding vaguely referenced OSHA guidelines in identifying this deficiency, but the specific regulatory reference point was not provided (though apparently a call to Chicago validated that this was the case). Now, anyone who’s worked with me in real time knows that I have an exhaustive (and, at times, exhausting) curiosity about such matters. The deficiency “concepts” are usually sourced back to a “they;” as in, “they told me I had to do this” “they told me I had to that.” I am always, always, always curious as to who this “they” might be and whether “they” were good enough to provide the applicable chapter and verse. The answer, more often than not, is “no.” Perhaps someday we’ll discuss the whimsical nature of the” Authority Having Jurisdiction” (AHJ) concept, but we’ll save that for another day.

At any rate, I did a little bit of digging around to try and locate a regulatory source on this and in this instance, the source exists; however, the standard is not quite as mandatory as one might first presume (If you’re thinking that this is going to somehow wrap around another risk assessment conversation, you are not far from wrong). So, a wee bit of history:

Back in 1994, the CDC issued their Guidelines for Preventing the Transmission of Mycobacterium tuberculosis in Health-Care Facilities, (http://www.cdc.gov/mmwr/pdf/rr/rr5417.pdf) which, among other things, advises a risk-based approach to screening (Appendix C speaks to the screening requirements for all healthcare workers, regardless of who they work for. The guidance would be to include contract folks. The risk level is determined via a risk assessment (Appendix B of the Guidelines is a good start for that). So, for a medium exposure risk environment, CDC recommends annual screening, but for a low exposure risk environment, they recommend screening at time of hire, with no further screening required (unless your exposure risk increases, which should be part of the annual infection control risk assessment).

But, in 1996, OSHA issued a directive that indicates annual screening as the minimum requirement , even for low-risk exposure risks, and even while referencing the CDC guidance: (http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=1586) with medium risk folks having semi-annual screening and high-risk folks being screened on a quarterly basis. So, friends, how are you managing folks in your environment, particularly the aforementioned contracted staff? Do you own them or is it the responsibility of their contracted employer? Does this stuff give you a headache when you think about it too much? It sure gives me one…occupational hazard, I guess. At any rate, it’s certainly worth checking to see whether a risk assessment for TB exposure has been conducted. The OSHA guidance document clearly indicates that if you haven’t, it’s the responsibility of the surveyor to conduct one for you, and I don’t know that I’d be really keen on having that happen.

I need to know – the re-rise of glutaraldehyde-based disinfectant

One of the developments of the last few years that pleased me most was the move away from glutaraldehyde-based disinfectants to safer alternatives. But now—and I am at a loss to understand what is prompting this—I am seeing a resurgence in the use of the glutaraldehyde-based disinfectants. As we are more or less familiar, glutaraldehyde is a fairly complicated environmental hazard to manage (not the most complicated, but up there on the list), with requirements regarding monitoring of conditions, ventilation, etc. For the big picture, the following link will do nicely: www.osha.gov/Publications/glutaraldehyde.pdf

So what is pushing us back toward a, oh I don’t know, certainly a more hazardous material? You’ll get absolutely no argument from me when it comes to the importance of properly disinfecting reusable medical devices; the rate of hospital-acquired infections is so much greater than we as safety professionals can live with. I had heard of some instances in which devices like endoscopes were stained following disinfection using OPA-like products, but my understanding was that any discoloring on the surface of devices was residue of proteinaceous materials that weren’t completely removed during the pre-disinfection process. (You can’t really call it staining as these devices are generally impermeable, so if it can’t sink in, it can’t stain.) So, I ask you: What up with this? I want to be able to help folks move in the right direction, and I’m not convinced that moving back toward glutaraldehyde is the right direction. If you folks are privy to something that allows this to make sense, please share. It is, after all, the time of the season. Hope to hear from you soon.

All we are is dust in the…

One of the critical processes when one embarks upon a program of construction and/or renovation is the management of infection control risks, particularly if the work is to be done in, or adjacent to, occupied patient areas. Now, I’m sure that you are all more than familiar with the infection control risk assessment (ICRA) matrix (you can find one in HCPro’s Infection Prevention Policy and Procedure Manual for Hospitals as well as in a number of locations on the Web). One question I’ve encountered recently is not so much about the risk assessment piece itself, but rather how one determines the amount of oversight (including how frequently IC rounds would be done in construction areas, and who would be qualified to conduct those rounds, etc.) and operational considerations like waste removal (i.e., frequencies and methodologies), cleaning floors (i.e., frequencies and methodologies), what types of walk-off mats to use, and stuff like that.

Now, if we know anything about anything, we know that there is not generally a great deal of guidance when it comes to the specifics of these types of things. And by now, we also know that there’s going to be some sort of risk assessment when it comes to making those decisions. So, the question I put to you folks in the field, in the spirit of sharing: How are you working through these types of operational decisions? Have you done anything that worked really well? Anything that worked so poorly that you get hives just thinking about it? The ICRA will help us determine what we have to do. How then do we take the next step to effectively implementing those identified strategies?

I look forward to hearing from you all, even if it’s to ask pointed questions. Operators are standing by…call now!

Mac’s Safety Space: Transporting blood and urine samples

Q: A question about transporting blood and urine samples. Do the samples need to be in a biohazard bag when transported either by hand, on a cart, or via a tube system that can go both to the lab and the pharmacy?

Steve MacArthur: I think the simple response to your question is yes, based on the requirements in the Bloodborne Pathogens Standard. First off, we start with the section on specimens on OSHA’s website:

1910.1030(d)(2)(xiii)

Specimens of blood or other potentially infectious materials shall be placed in a container which prevents leakage during collection, handling, processing, storage, transport, or shipping.

Now we could certainly discuss the merits of urine as a function of “other potentially infectious materials”, but in these days of Standard Precautions, the assumption we make is that it is presumed infectious until proven otherwise. We could also discuss the merits of the zip lock plastic bag as a function of leakage prevention, which will clearly depend on what the specimen is in; plastic would nominally be OK, while glass is probably a little less safe, depending on the method of transport, which would be another consideration.

So moving on to labeling, it seems pretty clear that some sort of unique identifier is in order and since the “standard” for that would be the biohazard symbol, I think we can safely identify that combination as the way to go.

1910.1030(d)(2)(xiii)(A)

The container for storage, transport, or shipping shall be labeled or color-coded according to paragraph (g)(1)(i) and closed prior to being stored, transported, or shipped. When a facility utilizes Universal Precautions in the handling of all specimens, the labeling/color-coding of specimens is not necessary provided containers are recognizable as containing specimens. This exemption only applies while such specimens/containers remain within the facility. Labeling or color-coding in accordance with paragraph (g)(1)(i) is required when such specimens/containers leave the facility.

In the interest of full disclosure, I’m including the items under paragraph (g)(1)(i) below, just in case there is something than clicks with your particular situation:

1910.1030(g)(1)

Labels and Signs –

1910.1030(g)(1)(i)

Labels.

1910.1030(g)(1)(i)(A)

Warning labels shall be affixed to containers of regulated waste, refrigerators and freezers containing blood or other potentially infectious material; and other containers used to store, transport or ship blood or other potentially infectious materials, except as provided in paragraph (g)(1)(i)(E), (F) and (G).

1910.1030(g)(1)(i)(B)

Labels required by this section shall include the following legend:






1910.1030(g)(1)(i)(C)

These labels shall be fluorescent orange or orange-red or predominantly so, with lettering and symbols in a contrasting color.

1910.1030(g)(1)(i)(D)

Labels shall be affixed as close as feasible to the container by string, wire, adhesive, or other method that prevents their loss or unintentional removal.

1910.1030(g)(1)(i)(E)

Red bags or red containers may be substituted for labels.

1910.1030(g)(1)(i)(F)

Containers of blood, blood components, or blood products that are labeled as to their contents and have been released for transfusion or other clinical use are exempted from the labeling requirements of paragraph (g).

1910.1030(g)(1)(i)(G)

Individual containers of blood or other potentially infectious materials that are placed in a labeled container during storage, transport, shipment or disposal are exempted from the labeling requirement.

1910.1030(g)(1)(i)(H)

Labels required for contaminated equipment shall be in accordance with this paragraph and shall also state which portions of the equipment remain contaminated.

1910.1030(g)(1)(i)(I)

Regulated waste that has been decontaminated need not be labeled or color-coded.

Hopefully, that helps answer your question; I think as long as you have something that is specifically identifiable to all who would be handling the specimens, you should be fine.

Mac’s Safety Space: Linens in the ENT clinic

Q: We have been having a discussion about the linens in our ear, nose, and throat (ENT) clinic. This clinic has an esthetician who uses spa wraps and smocks on the patients. Wouldn’t these linens have to be laundered the same as the hospital, as our clinics are under our hospital accreditation and license?

Steve MacArthur: I guess the question I’d have at this point is how are those items being laundered at the moment? It is possible to do a low-temperature wash (<160 degrees F) if appropriate chemicals are used. I’m thinking that we’re generally not dealing with an immune-compromised patient population in this context and maybe a risk assessment and a blessing from Infection Control would suffice.

The other thought I had is to either go with disposable wraps and smocks or perhaps the patients could keep their smocks, maybe as a marketing strategy. As I think about it, is the esthetician providing services under the auspices of the hospital’s accreditation or is it more like when they have hairdressers come in for patients in long-term care, which is sort of like a concession? I think the place to start is finding out what’s happening currently and working from there.

I think a credible risk assessment under the guidance of IC should be able to address any concerns that might come up during survey. Strictly speaking, this probably functions as an offshoot of palliative homeopathic care. I think as long as you approach the whole process in a thoughtful, methodical way, the surveyors will only be impressed at the level of service you are providing to patients. The IC standards all revolve around assessing risk and implementing prudent strategies for managing those risks, so why should this be any different. In fact, the acid test would be for you to submit the question to the SIG—and I bet you’ll get the same “figure it out for yourself” answer.

Mac’s Safety Space: Joint Commission standards on mop and rag laundering

Q: We’re concerned about whether the way our mops and rags are laundered are up to Joint Commission standards. At this point, we’re laundering them ourselves in bleach in our washer. The temperatures are hot, but not 160 degrees. Are these mops and rags considered “linen” and do they have to be washed up to the same standards as the rest of the linen?

Steve MacArthur: The quick and dirty response (small pun intended) is that The Joint Commission has no standards relative to the processing of mops and rags, and even the CDC Guidelines for Environmental Infection Control make no specific mention of these items, and as far as a time and temperature equation (temperatures greater than 160 degrees F for more than 25 minutes), they indicate that that applies only when hot-water laundry cycles are used.

They do make chemical detergents for warm-water laundry cycles (less than 160 degrees), so that might be a consideration as well. That said, as they nominally do not come into contact with patients, I don’t think that there would be a compelling reason to consider mops and rags as “linen,” so they could probably tolerate a somewhat lesser level of sanitization, but what that level is would have to be determined.

A couple of things spring to mind. One avenue would be to contact the vendor from whom you obtain mops and see whether there are manufacturer recommendations for laundering the mops. The rags, unless you are purchasing them as a specific consumable, are probably the vestiges of patient linens past their usefulness in that context.

Not being sure what type of washing machine you are using for this process, it might be of value to consider the purchase of a commercial-grade washer. From personal experience, few things “kill” a household-grade washing machine faster than washing mops, particularly in bleach. Also, with a commercial washer, you can probably provide a sufficient time and temperature mix that would perhaps even suspend the need for bleach (bleach is no friend to fabric, I can tell you). Certainly the commercial route is an expensive start-up, but you can probably figure out whether the return on investment is worth it.

Dust bunnies find their way into Missouri hospital

Calling all dust busters, feather dusters, and brooms: The University of Missouri Health Care needs you.

After a Centers for Medicare & Medicaid Services (CMS) five-day survey at the Columbia, MO, facility in November, 66 findings of dust were recorded in the 47-page survey report, according to Fierce Healthcare.

The report found dust collecting in a same-day surgery suite, a pre-op room, and on a portable ultrasound machine. In the same-day surgery suite, surveyors found 100 sticky spots on the floor and a dust layer on top of an anesthesia cart and a fluoroscopic camera located above the surgical table. In the pre-op room, sterile gloves and other supplies pulled from a storage bin had pieces of dust sticking to the packaging, reported Fierce Healthcare.

The hospital was visited by eight CMS surveyors after a past employee filed a complaint.

Take a look at the report given by the CMS surveyors.

How does your facility manage dust? Let us know in our comment section.