OSHA: A Personal Experience I am the Surgical Services Clinical Coordinator at a small rural hospital in Arkansas. In July of 2002 we had an unannounced visit from OSHA, following up on an employee complaint that sharps disposal units were overfilled and too heavy to lift. After checking in with Administration, the OSHA inspector began visiting with the clinical coordinators in nursing (we do not have nursing directors) and the directors of other non-nursing hospital departments. OSHA wanted to see anything and everything dealing with sharps. The inspector informed us that the name of the employee who sent in the complaint would not be revealed at anytime (beware of disgruntled employees). In the surgery area she requested to see all scalpels and blunt suture needles that we used and all engineering and work practice controls. (See figure 1)
Figure 1: Items Displayed for OSHA Inspector At the time of the OSHA visit were using the standard stainless steel scalpel handles with disposable non-shielded B-D blades. Physicians were evaluating three disposable shielded-blade scalpels. For various reasons, the surgeons did not like the disposable scalpels, but we required them to fill out an evaluation form for our files. We also stocked four of the many available blunt-point suture needles. I was extremely pleased at how prepared we were to respond to the inspector’s requests. We had attended seminars on OSHA preparedness, and I felt sure we were in compliance. The inspector toured all areas of the hospital. In the surgery department she looked at our syringe stock, I.V. catheters, I.V. tubing, hypodermic needles, sutures, and wall-mounted sharps containers. She also conducted a one-on-one visit with all available surgical employees. See Figure 2 for a sample of questions asked.
Figure 2. Sample Questions Asked of Staff The operating room was given a serious violation for using the standard stainless steel scalpels. The same serious violation was given to the rehab unit and the E.R. for using the disposable non-shielded scalpels. An additional citation for a serious violation was given to the operating room because they did not have blunt suture needles to use “where appropriate.” Our sterile needle counters had a built-in blade remover that did not meet standards; nor did the sterile sharps pass tray. I showed the inspector the disposable scalpel evaluation file documenting that the physicians had found the scalpel unsuitable. The inspector stated, It does not make any difference what the surgeons like. You must use the shielded disposable scalpels”. I was further informed that we must have all blunt needles in stock whether they were used or not. (What a waste!) See figure 3 for other citations given to the hospital. We were given 15 working days from the receipt of the written report to take corrective action and pay the imposed fines which, of course, we did.
Figure 3. Other OSHA Citations Given to the Hospital As a result of the OSHA visit, we have removed all stainless steel scalpels, disposable non-shielded blades from our surgical suites. We have stocked one box of each blunt-point suture available on the market and converted all possible syringes to safety type. We are offering our surgeons two different shielded disposable scalpels. OSHA Patient Safety Exception forms are filled out by individual surgeons on each specific surgical procedure in which they use the standard unshielded scalpels because the disposable shielded scalpels are not available or acceptable due to possible injury to the patient. We realize that different inspectors interpret the law in different ways, but I sincerely hope that this “real life” experience with one OSHA inspector will help my colleagues prepare for an unannounced OSHA visit. Editor’s note: Watch for articles on “Bloodborne Pathogens” and “Acute Care Facilities” in future issues of eChatter |