Archive for: September, 2016

Proper placement and compliance for eyewash stations

By: September 21st, 2016 Email This Post Print This Post

We get lots of reader mail from folks looking for information about eyewash stations, and what OSHA and other accreditation agencies require from healthcare facilities. Healthcare compliance consultant Brad Keyes, CHSP, attempts to explain the complex world of eyewash stations.

When and where are eyewash stations required in a healthcare facility? This is one of the more frequent issues with which healthcare professionals struggle. There is a tendency to place these stations nearly everywhere, but in reality there aren’t as many locations that require eyewash stations as one may think.

Eyewash stations are required wherever there is a possibility that caustic or corrosive chemicals could splash into an individual’s eye. It is important to note that blood and body fluids are not considered to be caustic or corrosive. It is also important to note that the use of personal protective equipment (PPE) such as face shields, glasses or goggles does not exempt a facility from its need for an eyewash station.

Here are some recommendations on evaluating your existing eyewash stations for compliance:

  • In a healthcare setting, eyewash stations are typically found where cleaning chemicals are mixed (such as housekeeping areas), where plant operations take place, and in kitchens, generator rooms, environmental services storage rooms for battery-powered floor scrubbers, in-house laundries, dialysis mixing rooms, and laboratories. Find out whether a risk assessment has been conducted to determine the need for eyewash stations.
  • All required eyewash stations must be the plumbed type, which can operate in one second or less. This means the faucet-mounted type that requires turning the hot water lever and the cold water lever and then pulling a center lever is not permitted.
  • Access to the eyewash station must be within 10 seconds (or 55 feet) of the hazard. The individual seeking an eyewash station may travel through one door to get to an eyewash station, provided the door does not have a lock on it and swings toward the eyewash station.
  • If an eyewash station is observed outside of an area where one is typically needed, ask the staff who work in the area why it is there. See if they have a risk assessment that requires it to be there. Advise them that if there is no valid reason for the eyewash station to be there, it can be removed, which may save them the time and resources spent in maintaining it.
  • Eyewash stations may need to have a mixing valve to maintain a flow of water in the 60 to 100 degrees Fahrenheit range. Ask to see the risk assessment to determine whether a mixing valve is required.
  • Every eyewash station needs to be tested weekly by flowing water to clear any sediment and bacteria. There is no requirement regarding how long the water must flow. Every eyewash station must be inspected annually to determine whether the eyewash station still conforms to the installation parameters. The weekly test and annual inspections must be documented.
  • The presence of eyewash bottles indicates someone in the organization decided it was needed. Investigate and ask why the bottles are located there. Determine whether they need a plumbed eyewash station within 10 seconds’ travel time (or 55 feet) of the perceived hazard. Check the expiration date on the bottles.

Always check with your state and local authorities to determine whether they have any additional requirements.

How to stay on top of OSHA compliance

By: September 8th, 2016 Email This Post Print This Post

OSHA fines these days have a bit more of a bite. In August, the agency increased its maximum penalty from $7,000 per violation to $12,471, plus an extra $12,471 per day each day past the abatement date. And fines for repeated or willful violations have also grown from $70,000 to a whopping $124,709 per violation.

Because of the relative rarity of OSHA inspections compared to other agencies such as CMS or The Joint Commission, some clinics have seen OSHA compliance a lower priority. However, the new costs of noncompliance may give clinics a reason to shore up their workplace safety program, fast. So how can a clinic, particularly one strapped for resources, become OSHA ready?

Rose Comstock, COHSM, risk manager at Southern Trinity Health Services, Scotia, California has worked for 25 years in safety and compliance. The key to OSHA compliance, she says, is making sure leadership supports and cultivates a safety culture. For safety officers, that means making sure the hospital executive understands why these regulations matter.

“Safety initiatives can be met with some resistance, but safety regulations are generally promulgated because someone, or many people, died or were seriously injured as a result of circumstances at a workplace,” she says. “If you read the history behind OSHA anyone would fully appreciate why workplace safety is where it is today.”

Comstock says the first step to achieving full OSHA compliance is conducting a full review of all policies and programs. Clinics need to know that their policies are all up-to-date with current state and federal OSHA regulations.

Chris Mancillas, CIH, is senior vice president of EPIC Insurance Brokers and Consultants in Boston and has been working in the health and safety field for over 20 years. He says that when it comes to OSHA compliance, the biggest issue that most clinics encounter is a lack of resources. Part of this is that clinics can’t always afford to hire someone to deal solely with OSHA requirements. Therefore, the work gets added to someone else’s plate within the facility to deal with. Still, he says there are ways to resolve this.

“Aside from the typical third party safety consultants, there’s also their insurance broker,” he says. “They may have access to certain services through the insurance company. Sometimes you can ask the insurance carrier for some logics control, but sometimes the logics control guy is only going to so the eyes and ears for the underwriter. So I think going to their agent, their broker, can help in getting some services. They may have some internal safety consulting services. That person is not the eyes and ears for the underwriter, but he works for them and can provide a perspective of what an OSHA inspector might look at.”

Along with annually scheduled safety training, Comstock says that employees will need to be trained every time changes are made to clinic policies or after there’s a safety incident. This goes for all employees, even temp or part-time workers.

Questions you should ask when evaluating your training program are:

  • When was the last time you gave your employees a copy of your Injury and Illness Prevent Program (IIPP?)
  • Do they know what’s in your IIPP and which rules apply to them?
  • Do they know how to report an illness or injury?
  • Do they know who the program administrator is?

Clinics should also ensure that facility inspections are both regularly scheduled and properly recorded. When OSHA comes, you need to show that hazards had been identified and mitigated using proper documentation.

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