Archive for: OSHA – General
If you are a clinic attached to a hospital system, my money is that you already have a pretty solid smoking policy in place. For one, it’s unhealthy and encouraging your visitors and staff to kick the habit sets a good example for everyone. Plus, it’s a fire hazard: many despite the strictest of rules, many patients are still injured or killed every year because someone had to sneak a smoke.
But like enforcing any rule, no-smoking policies are not always easy to monitor as there will always be someone who tries to skirt the rules. Well, get ready, because it looks you’ll be breaking out the rule book again to revise your smoking policies.
The Joint Commission, in an article published in the February 11 edition of its monthly Joint Commission Online newsletter, issued a recommendation that hospitals review their smoking policies to make sure the rules are clear that they include electronic cigarettes as well as traditional tobacco cigarettes.
The changes being recommended are based on the Joint Commission’s Environment of Care (EC) standard EC.02.01.03, which says that hospitals shouldn’t allow smoking on facility grounds, while allowing certain exceptions for smoking in specific circumstances. In other words, you should be doing the best you can to encourage people not to smoke, but most facilities still set aside separate rooms away from treatment areas—an outside visitor’s lounge, for example—to allow for those who need to find a place to smoke.
Smokers—like anyone with a vice—will always find ways to get around the rules. The Joint Commission’s recommendation comes on the heels of a recent CDC ad campaign warning that the use of electronic cigarettes are no safer than regular cigarettes, and that adolescents who “vape” are more likely to try to the real thing. In fact, the latest CDC claims show that teen use of e-cigarettes has tripled in just one year, despite a general decline in smoking.
The devices work by using a small battery to send an electric current to atomizer, which then vaporizes a liquid nicotine solution to be inhaled by the user. Although considered safer than regular cigarettes, there have been a small number of cases in which the devices have exploded because the batteries were overcharged or put in wrong.
Banning smoking altogether from hospital grounds has historically been a difficult thing to do. It’s hard to tell people what to do, especially those who are addicted to nicotine, and a hospital can be a stressful place. Smokers may need to find a place where they can find solace in an occasional smoke.
If you are looking to make your hospital smoke-free, the Joint Commission published a 28-page booklet, Keeping Your Hospital Property Smoke-Free: Successful Strategies for Effective Policy Enforcement and Maintenance that could be helpful—and may help you follow their recommendations that could look good during the next survey. Among other recommendations, TJC suggests:
- Make your non-smoking campaign more about general wellness, as opposed to another strict rule
- Get the support of all your leaders
- Allow for a phase-in of the rule; it won’t happen overnight
- Let smokers have a say in how the policy is implemented
- Make sure you have your wording straight. Do you want to have a “smoke-free” hospital, or a “tobacco-free” hospital?
- Monitor areas that could become places where visitors and employees might “sneak” a smoke. Alleyways, parking lots, and hidden areas should be kept clean and clear of butts and other debris to send the message that smoking is not allowed without being confrontational.
At the end of the day, you will have to decide as an institution whether smoking will be allowed your facility’s grounds, but as far as the Joint Commission is concerned, the better a job you can do to keep a non-smoking environment, the better you will look at survey time.
June 1, 2015 is the deadline that OSHA set for all employers to be in compliance with the new GHS chemical labeling regulations, which have been phased in over a three-year period to make the transition to the new system easier, especially for manufacturers, many of whom still have large stocks of inventory with old labels.
But for employers—and that means you as the laboratory or medical clinic—it’s a different story. By now you should have your books in order and your employees should know what an SDS is, and why it’s so different than what it used to be. If not, you’ve got a lot of work to do. We’ve put together a quick answer sheet for you to review, and to make sure you’ve made the right moves to be in compliance with the new GHS system.
What is GHS? Unless you really haven’t been doing your job as a safety officer (and you have, right?), this is a review for you. But the new GHS requirements were introduced by OSHA in 2012 that will require manufacturers of chemicals to switch from the traditional Material Safety Data Sheets (MSDS) to the new SDS system. The idea is to make identification of hazardous chemicals universally easier around the world, in any language, which at least theoretically, makes it safer for workers to handle and work with.
A major component of the new system is the updated Safety Data Sheets, or SDS, which replaces the older Material Safety Data Sheets (MSDS) that OSHA requires employers to have on record at job sites.
The sheets, which identify the chemicals and hazards associated with them, are divided into 16 sections, each dedicated to information about firefighting and first aid, storage, hazards, and what to do in the event of exposure to the substance. In addition, eight visual guides to workplace hazards called “pictograms” consist of a black hazard symbol on a white background with a red background, and are designed to be identified at a glimpse. They clearly identify hazards such as flames, carcinogens, corrosives, explosives, and environmental hazards.
What do my employees need to know? OSHA gave employers until December 1, 2013 to complete training with their employees on the new SDS system and pictograms. To be safe, employees need to recognize both sheets, and how to find information about handling chemicals safely as well as first aid information should there be an exposure in the workplace.
What are some training ideas I can use? Even if you did the proper training with your employees two years ago, if you don’t make the training an ongoing part of your safety program, your employees can forget the information.
Most safety experts suggest hosting a series of in-service trainings, to start. Get some donuts and coffee and introduce the new information such as pictograms to your employees. Make a fun quiz, or have your employees team to complete a scavenger hunt that requires them to identify pictograms on the new SDS. This also gives you a written record of their training you can then use to show to OSHA inspectors as proof of training.
Why are my chemical suppliers still sending old labels? In this case, chemical manufacturers had large stores of product that still had the old labels on them, along with original MSDS sheets corresponding to those products. If manufacturers had to change everything immediately, it would cost them a lot of money and waste a lot of chemicals, so OSHA gave them an extra two years to make the transition. That’s why your employees need to be trained to recognize both systems. Manufacturers have until June 2016 to complete their own transitions.
I can’t find SDS labels for the chemicals we use on the manufacturer’s web site. What’s next? Many manufacturers have been forward thinking enough to make sure they are providing the updated documentation for their products, even making them available on their website for easy download. But some safety managers who have been trying to update safety records have complained that they can’t find the proper SDS information for the chemicals they have in the workplace. In this case, you can wait for your suppliers to provide the updated documentation, but many safety folks have decided to take matters into their own hands and call vendors and suppliers to get the right information.
What if I don’t comply? OSHA’s GHS requirements are a law, so you really don’t have a choice. At best, you are opening your facility open to a major OSHA citation and fines. You also open yourself and your employees to injuries caused by not being up to date on information about the hazards associated with chemicals they are working with, as well as the first aid necessary to help out in an emergency.
For more information about the GHS requirements and ideas to help your facility comply, check out the following link on the OSHA website: https://www.osha.gov/Publications/OSHA3695.pdf
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 email@example.com.
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.
According to the Leapfrog Group, U.S. hospitals are only incremental progress when it comes to dealing with accidents, errors, injuries and infections that hurt or kill their patients.
The national, independent non-profit assigns letter grades to about 2,500 hospitals across the nation, a grade known as the Hospital Safety Score, based on hospital safety data and reviewed by a panel of eight hospital safety professionals.
Maine edged out Massachusetts in the 2013 survey as the state with the safest hospitals, as 80 percent of that state’s hospitals received a grade of “A.” Completing the top five states were Minnesota, Virginia, and Illinois.
Read the entire article:
OSHA has released a new resource to help keep emergency responders and facility workers safe when handling emergencies involving combustible dust. The booklet, titled Firefighting Precautions at Facilities with Combustible Dust, explains the associated hazards of combustible dust and outlines best practices for preparations to make prior to a response, as well as the effect of these preparations during incidents, according to an OSHA press release.
The booklet notes that “just about any solid material that burns can be explosible when finely divided into a dust” and states that a flash fire will occur when combustible dust that is dispersed in a cloud in proper concentrations is ignited. This flash fire can cause an explosion when confined in an enclosure such as a dust collector, processing equipment, conveyor, room, or building. According to the booklet, responders can inadvertently increase the chances of combustible dust explosions by using tactics that cause dust clouds to form, introducing air to create an atmosphere for explosions, applying the incorrect or incompatible extinguishing agents, or using tools and equipment that can become an ignition source.
More than 130 workers have been killed and nearly 800 workers have been injured in combustible dust explosions in the past three decades, according to OSHA. Many of these incidents may have been avoided with proper training and preparation for responding to such emergencies. OSHA’s newest resource should help facilities to avoid future worker injuries and deaths by providing the information necessary for safe practices with regards to combustible dust.
Access the OSHA booklet titled Firefighting Precautions at Facilities with Combustible Dust here.
Q: Does our annual bloodborne pathogen training have to happen exactly one year to the day later? We are low-staffed right now and scheduling is a concern, and an extra month would really help.
A: Your annual training doesn’t need to take place on the exact anniversary date of the preceding training but should be provided on a data “reasonably close” to the anniversary date. OHSA allows for you to take into account the company’s and the employees’ convenience in scheduling, but if the annual training cannot be completed by the anniversary date, you’ll need to write down why it’s been delayed and when the training will be provided.
*This is an excerpt from The OSHA Training Handbook for Healthcare Facilities by Sarah E. Alholm, MAS.
Q: What guidance does OSHA give on recapping fill needles?
A: OSHA is pretty blunt about recapping needles – they don’t recommend it!
Let me address the recapping of needles into categories:
A) Contaminated needles
The Bloodborne Pathogens standard section (d)(2)(vii): “Contaminated needles and other contaminated sharps shall not be bent, recapped, or removed…” The violation of the OSHA standard could not only injure staff members but also cost it as much as $7,000 as a serious fine, as classified by OSHA. If an employer continues this practice, it could become a willful fine, which ups the ante to $70,000.
B) Non-contaminated Needles
The standard strictly prohibits bending, recapping, or removal of contaminated sharps unless the employer can demonstrate that no alternative is feasible or that such action is required by a specific medical or dental procedure. [29 CFR 1910.1030(d)(2)(vii)(A)] The standard does not focus on the recapping of non-contaminated needles. However, the health and safety of both the clinician and the patient are important. It would be important not to recap the needle and risk the health care worker being contaminated with the medication that is in the fill syringe. It is equally as important not to contaminate the needle with the healthcare worker’s skin, because this would provide risk to the patient.
The standard requires each employer to establish an exposure control plan “designed to eliminate or minimize employee exposure.” If the medical practices require recapping or removal of sharps or if no alternative, such as immediate discarding into an approved sharps container, is feasible, the exposure control plan must include a provision for the use of mechanical devices in these circumstances. Although OSHA cannot, of course, approve or endorse particular products, there are a number of acceptable mechanical recapping devices.
Editor’s note: This Q&A was answered by Ron Stoker, executive director of the International Sharps Injury Prevention Society (ISIPS), Harriman, UT. www.isips.org
Q: Is it OK to store food and medications, such as vaccines, in the same fridge?
A: It is not acceptable to store medications, including vaccines, in the same refrigerator. In fact, there should be a separate refrigerator for meds and for food, and each should be clearly labeled on the door as to the contents.
Also, as a reminder, eating, drinking, smoking, and the application of cosmetics should not be allowed in a laboratory or an area where medications are prepared, mixed, etc.
–Kenneth S. Weinberg, BA, MSc, PhD, consultant in environmental health, safety, and toxicology; Safdoc Systems.
Usually the only fireworks that one equates with workplace safety is of the interpersonal type, but with Independence Day coming up, OSHA reminds employers, employees, and regular consumers of the danger inherent in fireworks displays, both public and private.
The National Safety Council (NSC) reminds that week 3 of June National Safety Month is Preventing Slips, Trips and Falls (STF) week.
Here is a list of the Council’s STF tips to share with your co-workers.
Week #3 of National Safety Council (NSC) Safety Month is Preventing Slips, Trips and Falls week. According to the NIOSH workbook, Slip, Trip, and Fall Prevention for Healthcare Workers, the incidence rate of lost-workday injuries from slips, trips, and falls (STFs) in hospitals was 90% greater than the average rate for all other private industries combined.
NIOSH recommends conducting regular walk throughs using an STF check list to identify hazards, keeping a file of hazard photographs or descriptions, identifying staff members responsible for fixing the hazard and a targeted completion date. Compared to NIOSH recommendations, how thorough are you or staff members with regular STF walk-through inspection.
Take the OSHA Healthcare Advisor Weekly Poll and let us know.