Our experts answer your OSHA questions
Editor’s Note: We get a lot of questions and reader comments from folks just like you looking for answers to everyday questions that a healthcare safety professional comes upon, and every so often we print some of our favorites for your reference. We will do the best we can to get you the right answers as soon as possible from our network of OSHA experts. To submit a question, feel free to email Managing Editor John Palmer at email@example.com.
Q: Are we required to have a contract with a medical waste disposal provider for our physician practice? We have virtually no waste and I want to either be on a “will call” basis or place our practice waste in with our surgery center waste for disposal. The surgery center has a contract and waste is picked up every week. Both entities share common ownership. It just makes sense to save money and not have service that we do not use enough to justify the annual expense.
A: While there is no requirement to have a contract to remove medical waste, the site is responsible for that waste in the eyes of the EPA from generation to final disposal. It might work to send the waste to the surgery center, but it will be important to know the volume of waste generated by the office itself (if it’s at a separate address). Keeping waste manifests is the best way to keep track of this.
Q: I work at an endoscopy ambulatory care center and work as the infection control professional. I am having a difficult time finding answers about the exposure time for 10% bleach solutions to clean items such as eyewash caps at our eyewash station. The OSHA book says to follow local state guidelines thru the EPA for exposure time. The EPA for our state had no idea and referred me back to the local health department and they were not sure. No one seems to be able to direct me, and I have looked at multiple sites, with no answers. Could you help direct me, please? Also, at the eyewash station, how do we measure the gallons per minute ratio?
A: 10% bleach is just one way to disinfect the eyewash station covers. It is not a requirement, just a suggestion. since one would not expect the covers to be contaminated with blood and body fluids, a few minutes may be adequate. this was a statement from the original edition of the manual. The industry trend is to clean everything according to the manufacturer’s recommendations. They may want to review the literature of their brand for directions.
To calculate gallons per minute, one would need to collect all the water for 15 minutes to ensure the minimum flow of .4 gallons per minute. One could estimate gallons per minute by collecting water for several minutes and dividing the total gallons by the minutes collected for an estimate if the water pressure does not change much. Again, the manufacturer’s directions should be consulted.
Q: What are the stipulations of needing a Respiratory Protection plan if we work in an office with very little exposure? Of course, we train on transfer of possible contagious patients.
A: You need to do a TB risk assessment of your area, consider adding screening intake questions for TB and then write a policy for rooming potentially infectious patients and letting the room sit after the patient has been seen or transferred. Ensure the training includes who will decide infectious patients are transferred out and what PPE providers will be wearing when this decision is being made.
A: Respirators are required for employees to protect them from harmful dusts, fogs, fumes, mists, gases, smokes, sprays, or vapors. A written program is required if there is potential exposure where a respirator would be needed. Once that determination or respirator use is made using a risk assessment, then the employer can decide on what is needed to implement the necessary elements of the program.
Q: If I have employees with no/low exposure, do I have to administer the same OSHA annual retraining and documentation? These are billing employees that come in after facility hours, they never go into the areas where they may be exposed to anything except the billing files and office section.
A: There are different OSHA trainings required. Bloodborne pathogens is just one. If they come after hours, the employees with no exposure may not need annual training. they do need emergency and fire training.
Make sure there is a risk assessment performed for all job categories so you can document that these folks would not be exposed.
Q: Is it true that fit testing is no longer an annual requirement? Also, I have been told that our hospitals that receive government funding [i.e.: tax dollar support] are not bound by the same OSHA standards as for privately owned. Do you have any information related to either question above?
A: Fit-testing is still an annual requirement, as things can change in a year such as weight, facial shape, etc. OSHA is still requiring annual fit-testing. OSHA standards cover any U.S. employee, government or not.
Q: I have been looking though our OSHA manual and do not really see a clear picture of recommended cleaning schedules. More specifically, regarding our waiting room, chair handles, door handles, tables and reception counter? Any thoughts? I think our staff had been doing this at the end of the day, but it was suggested perhaps we do this at noon as well? Any OSHA guidance on this?
A: There is no OSHA guidance on specific cleaning times for the areas mentioned. It would be up to your facility to determine risk. If there was a patient with contact precaution issues, additional cleaning might be in order but it’s up to the facility to identify what that process would look like.
Q: Are staff members allowed to use products such as hand sanitizer from Bath and Body Works and body sprays in the office if the product is kept in their desk and used only by that specific person? We have hand sanitizers and air fresheners that are used throughout the practice in public areas. We have SDS forms for all company-purchased products. We do not have SDS forms for personal products. What is the correct protocol?
A: In the clinical settings, the issue with personal lotions, sanitizers and sprays are the following:
- Certain lotions and personal hand sanitizers may cause reactions to employee skin, particularly when used with latex or nitrile gloves. Also, some lotions can even cause premature breakdown of glove material. In the clinical settings, you should only use employer-purchased and approved lotions and sanitizers.
- Sprays or perfumes can cause allergic and/or respiratory issues for co-workers or patients, and they should be avoided.
OSHA does not require a SDS for these products. In office settings, refer to your personal hygiene policy. Often sprays and perfumes that create strong odors are forbidden for the issues mentioned above.
Q: Can you please let me know if the Portex Point-Lok is still an acceptable safety device for use in a clinic setting. I have heard yes and no. I am updating my sharps policy and would like to educate my staff one way or the other as this device is one of several others that they request for use.
A: This device meets OSHA’s definition of an engineering control, but it cannot or should not be a substitute for an attached needle safety device. I am not sure of the value of this device since sharps containers are supposed to be located near the area where sharps are used.
Q: Do you interpret the new hazard communication ruling to mean that every free standing health center/clinic under the umbrella of a hospital health system has to have a chemical inventory list along with SDS on site? Or, can there be a master list on file with instructions posted.
A: Individual sites should keep a chemical inventory as part of the hazard communication program. Safety data sheets may be paper, or sites may access them via an electronic system such as MSDSonline.