Notes from the Field: Who gave you that bad advice?

By: August 5th, 2011 Email This Post Print This Post

In the past year I have performed over 100 mock OSHA inspections. I have heard every excuse in the book for not complying with OSHA regulations and CDC guidelines applicable to healthcare settings.

Many times the excuse for noncompliance is that someone told them to do/not to do whatever it is we are discussing. I am going to share some of the bad advice that physician offices have been given by consultants, experts, and even colleagues.

Safety needles for some; not for others
Recently an office manager told me they had safety needles available to use only on patients that have HIV, hepatitis B (HBV) or hepatitis C (HCV); otherwise they did not need to use safety devices. An OSHA speaker had given her this erroneous information.

The use of safety needles is not contingent upon a disease process of the patient. That is counter to the whole concept of universal precautions. You must use safety needles for all patients, regardless of their known/unknown diseases. This is not optional. (Editor’s note: See “Ask the Expert—Safety needles in small healthcare facilities.”)

Wipe, rinse, and use it
In another instance, a staff member was told to decontaminate their laryngoscope with a disinfecting wipe and then rinse it in water. After my initial shock wore off, I reminded the staff that this instrument was classified as semi-critical. This category of instrument use requires high-level disinfection, such as glutaraldehyde or an OPA solution. Never use a disinfectant-impregnated wipe as the sole means of decontamination for semi-critical instruments.

Any wipe will do
Here’s another one. A safety officer told her staff it was okay to use any type of bleach wipe to clean counter tops in the Lab/Nursing Station. The office was using those commonly used in homes to clean sinks and appliances. Use of an EPA-registered antimicrobial product—a hospital grade disinfectant with specified contact time for HIV, hepatitis, or TB—is required for compliance with the Bloodborne Pathogens standard.

Eyewash stations are for the birds
I attended an OSHA seminar several years where the speaker told the audience it did not need an eyewash station of any type in a physician’s office. All we needed was a squeeze bottle to fill with water if needed to rinse our eyes. She did not preface this statement with cautions on toxic drugs and hazardous chemicals, which under the OSHA 1910.151–Medical Services and First Aid standard usually requires “suitable facilities for quick drenching or flushing of the eyes…”

A squeeze bottle must not be a substitute for an emergency eyewash station if you have hazardous chemicals or cytotoxic drugs in your office. Always read the MSDS for any cautions about exposure to the eyes and the recommended flush time eye for first aid.

Each situation, each office, has individual requirements depending on drugs, chemicals, and procedures performed in the office.

By the way, even though OSHA does not require a plumbed eyewash station for blood and OPIM exposure to the eyes, eyewash stations are helpful in responding to this type of exposure. (Editor’s note: See “Aye-aye on eyewash station compliance.”)

Staying on top of things
Finally, contrary to bad advice given by a well known waste management company, you are required to annually update your OSHA manual whenever you introduce new hazards, add/change procedures, and create/revise job descriptions that affect the health and safety of the workplace. Not only does this especially apply to the bloodborne pathogens exposure control plan section of your OSHA manual, but is required by most other OSHA standards, too.

Read the Federal Register or subscribe to updates from a reputable resource such as HCPro’s Medical Environment Update newsletter to document any changes you make to your OSHA manual.

As an OSHA consultant, I constantly check in with the OSHA and CDC, NIOSH websites, or confer with OSHA experts, and ask questions.

What bad OSHA or infection prevention advice have you received or hear in your practice? Let us know in the comment section below.


By Bruce Cunha on August 9th, 2011 at 9:12 am

According to OSHA, Bleach is an acceptable disinfectant.

Q35. What type of disinfectant can be used to decontaminate equipment or working surfaces which have come in contact with blood or OPIM?

A35. EPA registered tuberculocidal disinfectants are appropriate for the cleaning of blood or OPIM. A solution of 5.25 percent sodium hypochlorite, (household bleach), diluted between 1:10 and 1:100 with water, is also acceptable for cleaning contaminated surfaces.

So if the wipes are at the correct concentration, wouldn’t they be acceptable to OSHA?

By Mary Gracey_White on August 9th, 2011 at 11:03 am

Question is similar to above: as a nursing home provider orginization we have told members to disinfect glucometer machines with EPa registered wipes btwn use- however many have purchased wipes containing bleach( 1:10 hypochlorite). Is this insufficient infection control practice?

By Kathy Rooker on August 10th, 2011 at 8:21 am

The household “bleach wipes” that I have found in offices,are not tuberculocidal. They are simply for home use.
Yes, a 1:10 solution of bleach is an approved surface disinfectant. Keep in mind, you MUST contact your state EPA office to confirm the contact time, The OHIO EPA, requires a 30 minute contact time for bleach. Other states may be 3 minutes. Also, when you pour the bleach into a secondary container, that container MUST be labeled identical to the primary bleach bottle AND it is only effective for 24 hours. You have to make a fresh solution every day.
Bottom line, most offices don’t want to bother with the bleach, and use another surface disinfectant; or an EPA registered wipe or solution.

I joined a LinkedIn group on OSHA support. I found people down-playing OSHA regulations on barricading, respirators, first aid, battery safety and even OSHA’s warrant-less search rights. LinkedIn is supposed to be a group of professionals. I belong to several LinkedIn groups. That group is the most arrogant and ignorant bunch of all, blatantly disregarding OSHA’s own regulations I posted website and court case links to. No wonder the safety industry is so pathetic getting safety and legal advice from people like this.


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