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This article is being written as a follow-up to my previous article in e-chatter entitled “OSHA: A Personal Experience”. Several years ago I had the pleasure to attend a lecture on OSHA Bloodborne Pathogen Standard requirements. This was a very informative lecture given by the OSHA Assistant Area Director. I was fortunate enough to spend several minutes after her presentation at which time she shared several important things with me.
OSHA wants to see documentation on what you are doing. They do not care what you say, but what you can show.
- Policy and procedure identifying patient care areas.
- No staff food or drink allowed in this area. Food and drink cannot be kept in refrigerators, freezers, shelves, cabinets or on countertops where OPIM (Other Potentially Infectious Material) are present. This includes coffee of physicians and anesthesia. They will look in the trash.
- No application of lip balm, lipstick, or other cosmetics nor handling of contact lenses in areas of potential exposure. Use of hand lotions is acceptable.
- Document wearing of PPE’s (Personal Protective Equipment) and keep recordings for future possible inspections.
- Policy and procedure to identify non-patient care areas.
- Food and drink is allowed in this designated area. (Break room, desk area, etc.)
- Policy and procedure on sharps containers. (How often they are checked and when they are changed.) Make sure that they are not overfilled.
- Policy and procedure on needle recapping if allowed. Must be mechanical or one-handed technique. (They have been known to look inside of sharps boxes for recapped needles/syringes). Contaminated needles and other sharps shall not be bent, sheared, or broken.
- Re-usable PPE’s must be kept in good repair. (Heavy duty work rubber gloves in decontamination area, aprons, etc.)
- Biohazard trash containers must have a lid on it.
- Use Red bags or affix biohazard labels to containers that store, transport, or ship blood, OPIM (Other Potentially Infectious Material) such as lab specimens.
- Never pick up broken glass with hands (even if gloved). Use dust pan with broom or tongs.
- PPE’s must be supplied and or cleaned by the employer.
- Repair and/or replacement of non-disposable PPE’s must be provided by the employer.
There are many other requirements in the standard (29 CFR 1910.1030) that you should be familiar with, but these are a few that may help you in case of a walk-in inspection by OSHA. This document is available at www.osha.gov.
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Lowell Price, Lowell Price has scrubbed, circulated, supervised, or directed in the perioperative setting for the past 24 years. He is a CNOR, active in AORN and involved in promoting perioperative nursing and new surgical procedures in his community. 100% of his nursing staff are members of AORN. Lowell is a patient safety advocate and is proactive in addressing patient/nurse safety issues in his facility |
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