ANOTHER OSHA VISIT

Since I shared my facility's experience with a visit from the Occupational Safety And Health Administration (OSHA) in two previous articles, a medical facility in the northeast has experienced a similar visit, with very similar results. Conversations with my perioperative colleagues lead me to believe that most facilities are NOT in compliance with the OSHA Bloodborne Pathogen Standard (29 CFR1910.1030). By sharing these experiences in different parts of the country I hope to increase my colleagues' awareness of OSHA's visit criteria (OSHA2098) and the criteria for employee protection under the Bloodborne Pathogen Standard.

According to the newspaper article I read, the northeast medical center was issued several citations and fines for violations of the bloodborne pathogen standard. These citations included:

1. Did not consistently use devices that had built in engineering safety protection for staff members.

  • Syringes
  • Blood collection tubes
  • Scalpels
  • Suture needles designed to reduce sharps injury (blunt point)

2. Did not ensure employees used appropriate PPE when possible exposure could occur.

  • Protection to minimize exposure to splashes (masks, eye protection)
  • employees not wearing their personal protective equipment as required
  • equipment not readily available for the employees’ use Ø Failed to maintain documentation in their exposure control plan
  • No record of annual review of devices that could reduce or eliminate sharps injury and splashes.
  • Exposure control plan failed to list engineering / work–place controls
  • Injury log failed to list device type, brand and description of accident

OSHA inspectors identified forty-six instances of unsafe practices and fined the hospital $9,000.00, a very reasonable fine considering the inspectors could have levied $7,000.00 per violation.

OSHA made the following recommendations:

1. When possible and clinically appropriate, implement commercially available protective devices.

  • Document the process used to choose the devices, including the personnel involved in the selection. The selection committee must include non-management personnel.
  • Document the rationale for NOT selecting devices. Cost is not an acceptable deterrent to purchasing safe devices. Neither is "we did not like it" an acceptable rationale for rejecting a safety device.

2. Review devices that can reduce exposure to splashes involving bloodborne products or other potentially infectious material.

  • Eye wear
  • Masks
  • Face shields
  • All other personal protective equipment

3. Establish a review process for the exposure control plan to make sure it reflects current practices, procedures, etc.

4. Ensure the exposure control plan contains a complete listing of engineering and workplace controls.

5. Ensure injury/incident log has appropriate entries in accordance with 29cfr-1910.1030. (Form and directions available at www.osha.gov.

6. Implement a review process for employee device complaints and/or suggestions. Ensure that all employees are aware of the process and document all follow-up on complaints and/or suggestions.

7. Implement a policy for the wearing of PPE and document the enforcement of this policy.

  • Having a policy is not sufficient; implementation of the policy is critical.
  • Wearing of PPE is not optional; employees MUST wear PPE in circumstances detailed in the policy.
  • Proper PPE must be readily available for the employee.

I encourage you to meet with the physicians and administration in your facility to assess compliance with OSHA's expectations. Then take whatever steps are necessary to assure compliance. Be prepared for an OSHA visit; OSHA can visit any facility spontaneously or in response to an anonymous complaint. The best position for any facility is to

BE PREPARED.