We hear it every day like a broken record – wear your PPE and know what you are doing when you are working with hazardous chemicals in the workplace. Unfortunately, too many people don’t listen and they end up paying the ultimate price.
I’m reminded of this today as I read more about the janitor in an elementary school in Plymouth, Massachusetts who was apparently overcome and died from exposure from an as-yet unknown chemical on Monday morning.
If you’re just learning about this, 53-year-old Chester Flattery, the head custodian at Manomet Elementary School, was found dead by the school secretary at about 8 a.m. That employee and 12 other people – many of them police officers, firefighters and other first responders who were exposed – had to also be taken to the hospital for treatment.
The investigation is still ongoing, but reports say Flattery had been at work for an hour before anyone else and that he may have been applying a floor sealant at the time of his death. School is not in session and there is a lot of maintenance work that goes into getting the building ready for next year.
Now, we all in workplace safety world know he was supposed to be wearing a respirator, eye protection, and other protective equipment. I have been a teacher in an elementary school, and I have seen these guys hard at work getting the school ready, even as I was getting my own classroom ready for students.
Most of the time, they are in regular street clothes as they go about their duties and I am willing to bet Flattery was no exception. As someone who had been working there since 2007, he was probably just doing what he always did – this time the fumes were too much for him and no one was there to help him until it was too late.
It almost happened to me. Back in college, I worked as a pool director at a country club in Connecticut, responsible for maintaining the proper chemical levels. One morning, I went into the supply closet looking for chlorine pellets, not knowing that one of my lifeguards hadn’t tightened the cover of the bucket properly the night before, allowing rain water to seep in. When I took the cover off, I got hit with a cloud of chlorine gas that knocked me off my feet and burned my throat. Happily, I was able to get to fresh air quickly and was fine. But no one was around and I was not wearing any kind of protection. I was lucky, and I never made the same mistake twice.
In the healthcare field, you can take a lesson from this tragedy. Don’t assume that just because you have done a job for a long time, you can ignore the rules. OSHA has bloodborne pathogens and hazardous chemical standards for a reason. If you are working with patients, wear your gloves, use your safety sharps, and lift safely.
If you are in a lab and work with chemicals, make sure you know the hazards of what you are working with and how to handle it properly, as well as any first aid information – it’s why OSHA says you must have SDS safety sheets on site. And always be sure someone is around, because it may save your life.
The following is an occasional series of guest blogs by experts in the medical clinic safety field. If you would like to be featured in this blog as a guest columnist, please email Managing Editor of Safety John Palmer at firstname.lastname@example.org.
In some laboratories, the use of Personal Protective Equipment (PPE) may be confusing to staff. However, a look at OSHA’s Bloodborne Pathogens and Chemical Hygiene Standards should make clear the requirements for proper PPE selection and use.
Both standards speak clearly to the necessity of PPE when working in the laboratory. Different PPE is needed for different tasks. Lab coats are always necessary in the lab for protection against blood and body fluid splashes or chemical splashes. Plastic aprons may also be used as extra protection in areas where gross tissue work is performed. Lab coats should be buttoned, the sleeves should not be rolled up, and they should be knee-length.
Gloves are needed when handling blood, body fluids, or chemicals, but different gloves may be used for different tasks. Many labs are turning away from using latex gloves because of allergic reactions by staff. Nitrile gloves have become the norm in recent years. However, make sure you have the correct gloves for the duties being performed. Some manufacturers make nitrile gloves that act as a barrier against blood and body fluids, but they do not provide protection against chemicals. While these will be fine while running a CBC in hematology, they won’t provide enough protection when changing the stainer. Be sure to use chemical-resistant gloves for this and other tasks (gram stains, handling chemistry reagents, pouring acids, etc.). Check the package if you are not sure about the proper use of gloves.
Goggles or face protection is important PPE that is widely under-utilized. Do you carry open specimens in the lab? What about carrying a rack of specimen tubes to or from an analyzer? That is a task that creates a risk for exposure, and face protection should be used. Are you pouring a chemical? Protection is necessary. Help your staff avoid all exposures to the eyes or mucous membranes.
The OSHA standards mentioned above also require that PPE is removed before leaving the laboratory. Do not wear lab coats or gloves to another location outside the laboratory. Does a procedure need to be performed in another area that requires PPE? If so, bring fresh PPE with you for use in the treatment area and dispose of it before returning to the lab.
In a laboratory, all areas should be considered hazardous, bio-hazardous, or contaminated. Do you have a desk area in the lab where only paperwork is done? I have always said that if there is an area in the lab where there are no patient specimens or chemicals, then one could consider the area “clean.” However, that does not mean that food or drink can be consumed there or that no PPE is needed. Remember, you are still in the walls of a laboratory, and accidents may occur. It is acceptable to label the area as “clean” so that gloves are not needed for the computer or phone, but a lab coat would still be required.
Remember, if an OSHA inspector arrives, he will be looking to see that all aspects of safety regulations are being followed. Keep your employees safe and keep your facility from unnecessary fines by using PPE where and whenever needed.
Dan Scungio, MT (ASCP), SLS, also known as “Dan the Lab Safety Man,” is a Laboratory Safety Officer for Sentara Healthcare, a multi-hospital system in the Tidewater region of Virginia.
Q: I am trying to standardize and simplify the organization of the MSDS in our organization. Many products that we use have a constituent in them that may be hazardous. In a true emergency, the employee may not know what hazardous substance is in the product but should know to look it up in the MSDS manual. An example is laboratory test kits that may contain a diluent or extraction solution. In that case, do you organize the MSDS by the manufacturer’s brand name, or by the common name of the product? What are you suggestions/guidelines?
A: My recommendation is to organize alphabetically based on the common names, since in an emergency this is where staff members will look first for information. OSHA requires that the name on the actual container label match up with the name on the MSDS, so do a spot check of this, too. If you use an identical product from multiple manufacturers, you don’t have to file an MSDS for each company. A single representative MSDS is okay as long as the information is complete and your staff members know which product it’s for.
*This is an excerpt from The OSHA Training Handbook for Healthcare Facilities by Sarah E. Alholm, MAS.
Q: I’m planning safety meetings for our staff (not yearly retraining). Are clerical employees required to attend every meeting if only medical issues are being discussed? Is a quarterly meeting okay?
A: No, clerical employees do not need to sit through meetings solely on clinical safety items. Quarterly meetings are good, but don’t overlook all the opportunities you already have at your normal staff meetings. Take a couple of minutes to talk about a safety-related topic. Timely events and examples really hit home. You’d be surprised how many poeople in your office can’t describe where to find the fire alarms or how to operate the eyewash station. Just three to five minutes at the start of the meetings really reinforces a safety-first attitude. For maximum impact, keep these mini-presentations short and to the point. You may not even need another quarterly staff safety meeting!
*This is an excerpt from The OSHA Training Handbook for Healthcare Facilities by Sarah E. Alholm, MAS.
Q: How often does safety training (bloodborne pathogen, hazardous materials, respiratory, etc.) need to be done within a medical office?
A: Strictly speaking, the only education pieces with specific recurring frequencies are the bloodborne pathogens education and respiratory protection education, which are required to be provided prior to initial work assignment and then annually thereafter.
Also, if there’s an expectation that folks in your office would use fire extinguishers as part of the fire response plan, then there is an annual requirement for extinguisher education as well (OSHA doesn’t specify the nature of the education, so it could be hands or on by demonstration, which could include a video presentation).
Interestingly enough, there is no OSHA requirement for annual fire drills, but if your medical office operates under the auspices of a hospital, there is an annual requirement for fire drills (and to be quite honest, it would have to be considered an excellent practice to conduct fire drills at least annually).
Other education concerns such as hazard communications and emergency response are required prior to initial work assignment and then whenever there is a change to procedures. There are a number of other potential education concerns that are promulgated as a function of General Industry; to that end, you may find the information on the following webpage (http://www.osha.gov/Publications/osha3122.html) to be of use, depending on your circumstance.
- Answered by Steve MacArthur, consultant for The Greeley Company, a division of HCPro, and author of Mac’s Safety Space.
Q: Is an ambulatory surgery center required to keep an MSDS file for the medications that are used in the facility?
A: If a drug is identified as hazardous and there is potential for exposure under normal working conditions, then the Hazard Communication Standard (HCS) applies, including the requirement to have an MSDS.
OSHA’s Hazard Communication FAQ explains:
The HCS only applies to pharmaceuticals that the drug manufacturer has determined to be hazardous and that are known to be present in the workplace in such a manner that employees are exposed under normal conditions of use or in a foreseeable emergency. The pharmaceutical manufacturer and the importer have the primary duty for the evaluation of chemical hazards. The employer may rely upon the hazard determination performed by the pharmaceutical manufacturer or importer.
An OSHA letter of interpretation, however, provides an important exemption:
“Drugs, as defined in the Federal Food, Drug and Cosmetic Act, in solid, final form for direct administration to the patient (i.e., tablets, pills, capsules) are exempt from coverage under Section 1910.1200(b)(6)(viii) of the HCS. MSDSs are required for all other hazardous drugs.”
This applies to all businesses, including ASCs.
If you struggle with when you need an MSDS and when you don’t, download the “Determining when an MSDS is necessary” decision chart from the Tools page.
The “Ask the Expert” posts, which appear on this web site, in addition to being real questions posed by safety professionals in healthcare facilities, are some of the most popular features of the Medical Environment Update newsletter.
Readers tell us that the posts are also good as discussion starters for safety committee meetings or staff training session.
Here are the top ten most popular posts from 2011.
Q: If we already have a paper MSDS file, must we also have the list of hazardous substances?
Q: How soon must new employees receive training under the Hazard Communication standard?
Q: How often must we replace MSDSs in our MSDS file?
Q: We changed to a different manufacturer for the purchase of isopropyl rubbing alcohol in our practice. Is it okay to use the old MSDS, or do we have to request a new one?
Q: We are establishing a chemotherapy suite for our practice. Are the portable squeeze bottle eyewash units we already use okay for this new area?
A: Squeeze bottle emergency eyewash stations are usually not compliant because, used alone, they cannot provide the required flush time for exposures found on most MSDSs. They are mostly used as an emergency measure to get workers to a plumbed eyewash station.
Check the MSDS for the hazardous substances present in the new area, including hazardous drugs, to determine how long a flush is required for exposure to eyes and mucous membranes. That flush time is what the eyewash station is required to provide to be OSHA compliant.