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.
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.
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 firstname.lastname@example.org.
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.
The following is a guest blog by Dan Scungio, MT (ASCP), SLS, a Laboratory Safety Officer for Sentara Healthcare, a multi-hospital system in the Tidewater region of Virginia.
I don’t watch sports often, but I must confess I enjoy watching the Olympic Games when they come around. This year there was a heated rivalry between swimmer Michael Phelps and South Africa’s Chad le Clos that ended with Phelps defeating le Clos in a 200m butterfly final meet. In one particularly good photograph of the event, the two rivals are side by side. Michael Phelps is staring straight ahead while le Clos is watching Phelps. On social media, the caption on that picture often read, “Winners focus on winning, losers focus on winners.” I don’t know if I agree with that philosophy in general, but it definitely does not apply to laboratory safety.
I was a lab manager for 11 years when I decided to apply for the role of Lab Safety Officer for the hospital system that was my employer. I did not have a strong lab safety background. I managed a lab in which the staff food refrigerator was located near hematology (yes, right in the lab), and many of the staff did not wear lab coats regularly. When our hospital integrated with the larger system, I met the Lab Safety Officer and over time learned more about the importance of lab safety. When I took over the safety role, my goal was to continue learning about lab safety and to improve the culture in the lab system. I wanted to be a winner. Who would I look to in order to make that happen?
Even though my role as a Lab Safety Officer was full-time (something that is very rare in the field), I knew I would need help to learn more and to know how to make a measureable difference in the safety culture. The first step was learning to look to the many resources available to me. I met with my internal references- Occupational (Employee) Health, Infection Prevention, Facilities, Environmental Services, and Security. Then I began meeting some external references- the chemical waste handlers, the hood service company, the vapor monitor contractors, and the PPE vendors. All of these people had much they could tell me, and over time they have provided a great deal of lab safety knowledge regarding regulations and best practices. I also became familiar with other external references such as the EPA, OSHA, and the CDC.
Now let’s go back to that Olympic swimming – what does that have to do with safety resources? I have found over the years that because of the myriad regulations and guidelines it is very difficult for a safety professional to stay current without help. As a group, we need to rely on each other as sources of information, or as a support network. Networking is important so that safety professionals can focus on the best practices and successes we are achieving in our labs regarding safety. While it is important to concentrate always on improving our lab safety cultures- to focus on winning- it is also necessary to look at each other, and to learn how to apply those safety best practices in our own labs. If you are focusing on other labs and how they are winning the lab safety Olympics, that doesn’t make you a loser- it makes you smart. Not everyone is able to find the answers they need in their own back yard…or swimming pool.
If you are not part of a lab safety network, I highly recommend becoming a member of one. The Safety Academy group I host every year is a great group of people who help each other out all the time. Try a Linked In® group or maybe a Facebook page on lab safety and ask your questions. Subscribe to my free monthly newsletter and be connected to over 1500 others who are focusing on lab safety across the nation. No matter how you swim the race of lab safety, you don’t have to swim alone, there are other winners out there who can help you win that race in your laboratory.
If you’re looking for training ideas for your staff, it might be time to train them on how to properly use a respirator.
NIOSH will offer a webinar, “The Science Behind Respirator Fit Testing in the Workplace: Past, Present, and Future,” on N95 Day, Sept. 6, 2016.
In this three-part webinar, participants will first learn the initial science behind the OSHA requirements to better explain why they are what they are, including why initial respirator fit testing is so important.
Next, findings of a recent NIOSH study that supports the need for annual fit testing will be discussed, and lastly, recent NIOSH developments toward improved headforms used for studying respirator fit of N95 filtering facepiece respirators will be presented.
For more information, register at the NIOSH website here.
Learn everything you need to know to stay ahead of Joint Commission surveyors.
If you missed expert Brad Keyes, CHSP, owner of Keyes Life Safety Compliance on July 21 for his discussion of the most commonly cited life safety and environment of care violations found when Joint Commission surveyors inspect hospitals, you’re not too late!
Joint Commission officials have expressed public frustration with what they say are repeated violations of crucial items such as fire safety, maintaining a sterile environment, means of egress, and proper documentation.
At the conclusion of this program, participants will be able to:
- Identify and eliminate life safety issues such as stained ceiling tiles, improperly stored medical gas cylinders, and potential ligature issues in behavioral health units
- Properly use CMS categorical waivers to help stay in compliance
- Eliminate corridor clutter in hospital suites
- Manage common infection control violations such as air pressure relationships, air exchange rates, temperature and humidity issues, and inappropriate workflow in central sterile processing departments
- Maintain proper means of egress for emergency evacuations. Provide proper documentation to surveyors, including thorough life safety drawings and complete inventories of testing documentation
Don’t miss this opportunity to hear practical advice and have complex regulations simplified in this program suitable for your whole organization. To order the webcast on demand, call HCPro customer service at 800-650-6787 or visit the HCPro Marketplace.
Too often healthcare organizations find themselves unprepared for a hazardous situation or patient. It is in these tense moments that proper PPE training is put to use in order to protect staff and patients while minimizing risk. The only way to ensure your staff is ready for such a situation is through awareness and training on an organization-wide level. The PPE Handbook for Healthcare Facilities, sold in packs of five, is the perfect tool to give staff the knowledge and know-how of proper PPE usage. This handbook clarifies confusing PPE situations as well as when and how to properly implement PPE best practices. Don’t wait to train your staff after a hazardous situation has already occurred. The time for training and best practices is now!
The handbook is authored by Marjorie Quint-Bouzid, MPA, RN, NEA-BC, vice president of nursing at Parkland Hospital and Health System in Dallas, Texas, and formerly vice president of patient care services/chief nurse executive at Fort Washington Medical Center (FWMC). Quint-Bouzid has more than 30 years of experience as a registered nurse and more than 16 years of progressive experience in hospital administration.
This handbook offers front-line staff:
- The proper techniques involved with using personal protective equipment (PPE)
- Detailed diagrams that clearly demonstrate how to don and doff, as well as identify different kinds of PPE, and in what situations each type would be used
- Multiple government resources, such as the CDC and OSHA to help facilities decipher information in an easy-to-use, one-stop reference tool
For more information and to purchase the handbook, call HCPro customer service at 800-650-6787 or visit the HCPro Marketplace.
The following is a guest blog by Dan Scungio, MT (ASCP), SLS, a Laboratory Safety Officer for Sentara Healthcare, a multi-hospital system in the Tidewater region of Virginia.
Many years ago I worked in a lab that often received dry ice in boxes with our blood product deliveries. The habit in the lab was to dump the excess frozen carbon dioxide into one of our stainless steel sinks. The staff would get excited each time there was a delivery because they liked to run tap water onto the ice to make a “waterfall” of smoke flow onto the floor when they were bored. Before too long, this repeated incorrect placement of dry ice resulted in severe damage to the sink and pipes below. The stainless steel basin cracked and the sink fell down onto the broken pipes below. That particular plumbing is not designed to handle such a low temperature, and the repair was not cheap. Luckily, no one was injured.
Dry ice sublimates at room temperature. That means it transforms from a solid state directly into a gas. Too much of this gas in a small space will reduce the normal oxygen levels in the area potentially causing dizziness and asphyxiation. Letting dry ice sublimate in the work place is a dangerous practice. If you have dry ice to dispose of, the best practice is to set it outside (where other could not have access to it) so it can dissipate into the open air.
Dry ice is often used in the transport of specimens, blood products, and certain lab reagents. The Department of Transportation considers it a dangerous good, and it must be used and labeled specifically if it is to be shipped by land or by air. If dry ice is used in shipping, an additional Class 9 miscellaneous hazard label also must go to the right of the Class 6.2 infectious substance label. In addition to the Class 9 label, the outer box must be labeled with the net quantity of dry ice used.
Another common use of dry ice is with the transport of outreach or clinic lab samples in courier vehicles. Certain samples must be kept frozen for testing, and the use of dry ice provides a convenient method for maintaining the necessary temperatures. Dry ice is placed in a cooler in the courier vehicle, and samples are placed until delivery to the reference laboratory. With that, there are specific safety practices that should be adhered to when using dry ice for this purpose. Couriers are often overlooked when considering safety training, but they are an important piece of the lab sample and testing process. Be sure couriers have complete safety training, including training for the proper handling of dry ice.
Couriers should limit the amount of dry ice placed inside the cooler that will rest in the vehicle. No more than three pounds of dry ice should ever be placed in that cooler. The cooler should never be completely sealed (remember the ice sublimates to gas, and the volume of the gas in the cooler will expand). Also, if dry ice is kept inside of a vehicle, the windows should be left opened, even a tiny bit. There have been incidents where too much dry ice in a closed vehicle has caused a driver to become dizzy or even become unconscious. Obviously this is a potentially dangerous or even deadly situation and should be avoided completely.
In the laboratory or outreach settings, employees are asked to work with many dangerous substances, bloodborne pathogens, chemicals, and sometimes dry ice. Inherently, these departments are not safe, but OSHA requires that employees be able to work safely in those places, and it can be done. Proper training and oversight of safety are the keys to ensuring your employees can collect, transport, and process lab samples in such a way in which all involved in these processes are kept safe.
In case your July 4 barbecues have been taking your attention away from OSHA matters, the agency announced that minimum fines for violations will increase on August 1 for the first time in 25 years.
Healthcare facilities should take note, as the maximum fines will increase by 78%.
For a serious violation, the maximum fine will go up more than $5,000 from the current $7,000 fine. A serious violation will now cost you $12,471 per incidence. If you fail to fix it, your fine gets increased by $12,471 per day past the abatement date.
For willful or repeated violations, maximum fines will go up more than $50,000. Currently, a willful violation will run you $70,000, and after August 1, it will go up to $124,709 per violation.
State OSHA plans will be required to adopt a fine schedule at least as effective as the federal OSHA.
See more at the OSHA website here.
The National Safety Council, a safety advocate group that promotes safety in homes, workplaces, and communities across the country, has designated the month of June as National Safety Month. Specifically, the group has dedicated Safety Month 2016 to several safety subjects relevant to healthcare, including emergency planning and response in the workplace, medication safety, worker wellness and health, and reducing hazards in the workplace such as distractions and improperly secured furniture that can lead to falls and other injuries.
We’re celebrating Safety Month by offering giveaways, raffles, and discounts on all your favorite safety products. Win a $100 gift certificate good for any Safety product on the HCPro Marketplace by answering the following five trivia questions correctly.
Send your responses to Managing Editor John Palmer at email@example.com by Friday, July 1. Winners will be chosen randomly from the responses received.
- List three injury reporting requirements, according to OSHA’s website.
- Name two things OSHA says employers must train workers required to use personal protective equipment to know.
- Name three components of a compliant chemical label, according to the OSHA GHS labeling requirements for hazardous materials.
- How many facility inspections were conducted by OSHA in 2015?
- Name three risk factors in healthcare facilities that can lead to workplace violence.