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And you may find yourself in another part of the survey process (more HazMat fun)

And you may ask yourself, well, how did I get here?

As is sometimes the case, I like to respond to questions from the “studio” audience and last week I received a question from the field that I think is worth a few inches of verbiage here. The question, as luck would have it, relates to the ascendancy of EC.02.02.01 (with 63% of the hospitals being surveyed taking hits), the management of hazardous materials and wastes.

While it may seem a little incongruous, with a side order of daunting, I think that the primary reason for the ascendance of EC.02.02.01 is that there are any number of things that can generate findings, particularly from the clinical surveyors (not that the LS surveyor couldn’t find stuff, but from what I’ve seen in recent survey reports, a lot of the HazMat findings are being generated during “regular” tracers). So, in no particular order:

  • emergency eyewash equipment (availability/accessibility/documentation of testing & maintenance)
  • availability and use of personal protective equipment (PPE) in accordance with product Safety Data Sheets (SDS)
  • management of hazardous energy sources, particularly as it relates to managing lead PPE;
  • labeling of secondary containers
  • management of hazardous gases and vapors (particularly as a function of ventilation, but also monitoring if you happen to have folks still using glutaraldehyde and/or cadmium-based products)
  • ensuring appropriate staff education is in place, particularly Department of Transportation education for staff signing manifests
  • with the odd issue relating to staff being able to competently access SDS

We’ve certainly spent our fair share of time talking about eyewash equipment (surveyors are as prone to over-interpretation as anyone, so you better have a clearly articulated risk assessment in your back pocket), and, interestingly enough, on May 31 (my birthday!), the folks at HCPro are hosting a webinar on the evergreen topic of eyewash stations, so you may want to give that look-see (listen-hear?).

I think the stuff surveyors are kicking folks on is pretty straightforward. I mean, just think about unlabeled or inappropriately labeled secondary containers—what’s the likelihood that you’ve got one out there somewhere in your organization? An unlabeled spray bottle; a biohazard container for which the label was washed off—lots of opportunities for the process to come up short.

At any rate, the list above is representative of what I’ve seen (in consulting practice and in actual survey reports). Anybody have any other potential findings that they’ve seen?

What it is ain’t exactly clear: Hazardous materials management and the SAFER matrix

I was recently asked to ponder the (relative—all things are relative) preponderance of findings under the Hazardous Materials and Wastes Management standard (EC.02.02.01 for those of you keeping track). For me, the most interesting part of the question was the information that (as was apparently revealed at the Joint Commission Executive Briefings sessions last fall) findings under EC.02.02.01 frequently found their way to the part of the SAFER matrix indicating a greater likelihood of causing harm (the metric being low, moderate, and high likelihood of harm) than some of the other RFIs being generated (EC.02.06.01, particularly as a function of survey issues with ligature risks, also generates those upper harm-level likelihood survey results). Once upon a time, eyewash station questions were among the most frequently asked (and responded to in this space), so it’s almost like replaying a classic

Generally speaking, the findings that they’ve earmarked as being more likely to cause harm are the ones relating to eyewash stations (the most common being the surveyors over-interpreting where one “has” to have an eyewash station the remainder pretty much fall under the maintenance of eyewashes—either there’s a missing inspection, access to the eyewash station is obstructed during the survey, or there is clearly something wrong with the eyewash—usually the protective caps are missing or the water flow is rather anemic in its trajectory). All of those scenarios have the “potential” for being serious; if someone needs an eyewash and the thing doesn’t work properly or it’s been contaminated, etc., someone could definitely be harmed. But (and it is an extraordinarily big “but”) it’s only when you have an exposure to a caustic or corrosive chemical, which loops us back to the over-interpretation. OSHA only requires emergency eyewash equipment when there is a risk of occupational exposure to a corrosive chemical (the ANSI standard goes a bit further by indicating eyewash equipment should be available for caustic chemicals as well as corrosives). A lot of the findings I’ve seen have been generated by the clinical surveyors, who are frequently in the company of hospital staff that aren’t really clear on what the requirements are (you could make the case that they should, if only from a Hazard Communications standard standpoint, but we’ll set that aside for the moment), so when the clinical surveyor says “you need an eyewash station here” and writes it up, the safety folks frequently don’t find out until the closeout (and sometimes don’t find out until the survey report is received). The “problem” that can come to the fore is that the clinical folks don’t perceive the eyewash finding as “theirs” because it’s not a clinical finding, so they really don’t get too stressed about it. So, the surveyor may ask to see the SDS for a product in use and if the SDS indicates that the first aid for eye exposure is a 15- or 20-minute flush with water, then they equate that with an eyewash station, which in a number of instances, is not (again, strictly speaking from a regulatory standpoint) “required.” Sometimes you can make a case for a post-survey clarification, but successful clarifications are becoming increasingly rare, so you need to have a process in place to make your case/defense during the survey.

The other “batch” of findings for this standard tend relate to the labeling of secondary containers (usually the containers that are used to transport soiled instruments); again, in terms of actual risk, these conditions are not particularly “scary,” but you can’t completely negate the potential, so (again) the harm level can be up-sold (so to speak).

In terms of survey prep, you have to have a complete working knowledge of what corrosive chemicals are in use in the organization and where those chemicals are being used (I would be inclined to include caustic chemicals as well); the subset of that is to evaluate those products to see if there are safer (i.e., not corrosive or caustic) alternatives to be used. The classic finding revolves around the use of chemical sprays to “soak” instruments awaiting disinfection and sterilization—if you don’t soak them, then the bioburden dries and it’s a pain to be sure it’s all removed, etc.; generally, some sort of enzymatic spray product is used—but not all of them are corrosive and require an eyewash station. Then once you know where you have corrosives/caustics, you need to make sure you have properly accessible eyewash equipment (generally within 10 seconds of unimpeded travel time from the area of exposure risk to the eyewash) and then you need to make sure that staff understand what products they have and why an eyewash is not required (strictly speaking, there really aren’t that many places in a hospital for which an eyewash station would be required) if that is the case—or at least make sure that they will reach out to the safety folks if a question should come up during survey. Every once in a while there’s a truly legit finding (usually because some product found its way someplace where it didn’t belong), but more often than not, it’s not necessary.

You also have to be absolutely relentless when it comes to the labeling of secondary containers; if there’s something of a biohazard nature and you put it in a container, then that container must be properly identified as a biohazard; if you put a chemical in a spray bottle, bucket, or other container, then there needs to be a label (there are exceptions, but for the purposes of this discussion, it is best managed as an absolute). Anything that is not in its original container has to be labeled, regardless of what the container is, the reason for doing it, etc. The hazard nature of the contents must be clear to anyone and everyone that might encounter the container.

At the end of the day (as cliché an expression as that might be), it is the responsibility of each organization to know what’s going on and to make sure that the folks at the point of care/point of service have a clear understanding of what risks they are likely to encounter and how the organization provides for their safety in encountering those risks. We are not in the habit of putting people in harm’s way, but if folks don’t understand the risks and (perhaps most importantly) understand the protective measures in place, the risk of survey finding is really the least of your worries.

Take an ‘M’ down, pass it around—now you’ve got SDS

In case you missed it, OSHA’s Hazard Communications Standard has been revised to align with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS) and the first important “to do” date is rapidly approaching (you’ve got a little less than six months—December 1, 2013 is the target). Lots of information can be found here, including an OSHA FactSheet on the topic.

The expectation before us regarding the December deadline is to provide education to our staff on the new label elements and the Safety Data Sheet (SDS) format. Ultimately, this process will result in a much more standardized “look” for the hazard information folks will access to determine how best to manage the risks in their workplace.  The training must include information on the standardized format, including the information contained in the various sections as well as how the information on the product label(s) relates to the SDS.

As a gentle reminder as you embark on this education journey, always remember that OSHA requires you to present information to staff in a manner and language that your employees can understand (this likely represents different types of challenges for each of you). The OSHA page above has links to educational information in English and Spanish, but some of you may have to come up with materials in other languages. I believe that this will be beneficial in the long run, but it represents change, so there will be barriers to be managed. Funny how change erects all sorts of interesting challenges.

As a final note (for the moment) in this regard, the “other” things on the to-do list are to continue to update safety data sheets as new ones become available; continue to provide education on the new label elements; and (this is an important one) update your hazard communications program if new hazards are identified. I’m hoping that any changes to your HazComm plan will be minimal, but you definitely want to start thinking about those updates (June 1, 2016 will be here before you know it).

Between the sheets…the Safety Data Sheets!

Every once in a while I like to take questions from the studio audience and today I’d like to address the question of where one has to have copies of their Safety Data Sheets (in the interest of history, I’m going to resist using the “old” term Material Safety Data Sheets) in each department.

So, the short answer is “no,” there is no specific requirement to have copies of the SDS in each department. But there is some contextual stuff that requires a bit of diligence, so I think a quick review of the language in the Hazard Communications Standard may be useful (the section of the Standard dealing with SDS is 1910.1200(g) – we’re just looking at the portion that discusses how employers are expected to manage them):

1910.1200(g)(8)  The employer shall maintain in the workplace copies of the required safety data sheets for each hazardous chemical, and shall ensure that they are readily accessible during each work shift to employees when they are in their work area(s). (Electronic access and other alternatives to maintaining paper copies of the safety data sheets are permitted as long as no barriers to immediate employee access in each workplace are created by such options.)

1910.1200(g)(9) Where employees must travel between workplaces during a workshift, i.e., their work is carried out at more than one geographical location, the material safety data sheets may be kept at the primary workplace facility. In this situation, the employer shall ensure that employees can immediately obtain the required information in an emergency.

1910.1200(g)(10) Safety data sheets may be kept in any form, including operating procedures, and may be designed to cover groups of hazardous chemicals in a work area where it may be more appropriate to address the hazards of a process rather than individual hazardous chemicals. However, the employer shall ensure that in all cases the required information is provided for each hazardous chemical, and is readily accessible during each work shift to employees when they are in their work area(s).

So, basically it all really boils down to that last statement. You need to have SDS information for each hazardous chemical and that information has to be readily accessible to employees when they are in their work area(s). As I think we’ve discussed in the past (but if we haven’t, we’re going to, starting now), the Hazard Communication Standard is a performance standard (much like many of the Joint Commission standards). The HazComm Standard does not specify much in the way of compliance strategies, but rather focuses on establishing certain expectations and then each organization has to figure out how to meet those expectations from an operational standpoint. You can go about this pretty much any way that you want—as long as you can effectively provide access to SDS information for employees. If you can effectively provide access without having copies of SDS at the department level, then that’s what you can do. And if you can’t, then you have to come up with a strategy that does—which for the department-level access means copies of the SDS in the department.  And to keep things on a front and center kind of standing, I might suggest that the effectiveness of the process for providing access to SDS information would make a very good performance measure upon which to evaluate the effectiveness of your Hazardous Materials and Waste Management program. Test the process—see if folks can retrieve the information they need without too much difficulty. If it’s a web-based program, ask them to show you how they work the process. Fax on demand? Same thing—have staff show you the process works. That way you “know” that you have an effective process.