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