Workplace Safety Programs Pay Off

OSHA is teaming up with other organizations promoting safety to get the word out that "Safety Is Good Business," which is also the theme of North American Occupational Safety and Health Week (NAOSH), May 4–10, 2008.

Investing in health and safety programs is a sound strategy for business of all sizes and types, according to the American Society of Safety Engineers (ASSE), which sponsors the NAOSH Week activities. For every $1 invested in safety programs, $4-$6 are saved in decreased injuries, illnesses, medical costs, and workers' compensation costs while worker productivity increases, according to a NAOSH Week fact sheet.

Zip Bags for Transporting Specimens

If you use zip bags without the biohazard symbol you can reuse them (a hassle) or throw them out with the regular trash unless they are visibly contaminated with blood or body fluids. If you use zip bags with the biohazard symbol they must go in red bag waste or your waste hauler won't take them.

As long as you are transporting specimens in a clear bag so that anyone can see blood or body fluids in them, you can use bags without the biohazard symbol but only within your facility. Any specimen that is sent across a public street or highway must have the symbol on the bag. This is part of the DOT regs.

What is Considered a Sharp?

I have received several queries about plastic pipette tips and whether they must be considered a sharp when they are disposed of and, as a result, placed in a sharps container. There has been discussion as to whether this is an OSHA or DOT regulation. When OSHA was contacted through the Denver office, it indicated that there was no OSHA regulation regarding plastic pipette tips being declared a sharp and having to be placed in a sharps container.

However, in the CFR 173.134 reads, in part, “Sharps means any object contaminated with a pathogen or that may become contaminated with a pathogen through handling or during transportation and also capable of cutting or penetrating skin or packaging material. Sharps include needles, syringes, scalpels, broken glass, culture slides (glass), culture dishes (glass), broken capillary tubes, broken rigid plastic, and exposed ends of dental wires.” According to the definition, only broken glass or plastic is considered a sharp. The potential to break is not specifically addressed.

The issue then becomes, will the plastic tips puncture the red bag and cause the healthcare worker potential exposure? Each facility should address this issue in its safety committee and come up with a policy and procedure for dealing with this type of waste.

OSHA Posts TB Enforcement Letter

OSHA finally got around to posting a notice on its Web site, www.osha.gov, that it will start enforcing annual fit-testing in healthcare facilities for respirators used to protect from tuberculosis (TB) exposure. OSHA received Congressional approval to reactivate this provision of the Respiratory Protection Standard, 1910.134, December 26, 2007, but the notice appeared last week, even though it is dated March 24. OSHA will now cite employers for failure to conduct annual fit testing for employees required to wear respirators as protection from TB.

Computer Vision Syndrome (CVS)

CVS is an ergonomic illness associated with individuals who use a computer on a regular basis. The aging workforce is susceptible to a variety of workplace safety risks. According to the American Optometric Association, computer vision syndrome leaves older employees vulnerable to problems like dry eye, eyestrain and fatigue. Here is what employers can do to prevent this problem:

Encourage older employees to have a comprehensive eye exam at least once a year especially if they are experiencing symptoms of CVS such as eye redness, frequent rubbing of the eyes, blurriness or eye fatigue or limited attention to visual tasks.


Remind employees to use the 20-20-20 rule. Every 20 minutes look 20 feet away from the computer and blink 20 times to minimize the development of eye focusing problems and eye irritation caused by improper blinking.


Make sure the computer monitor is adjusted to the individual user’s height. The top of the monitor should be at eye level.

MSDS for Infectious Substances

The Health Canada website at http://www.phac-aspc.gc.ca/msds-ftss/index.html#menu?
now has material safety data sheets for infectious substances. These MSDS are produced for personnel working in the life sciences as quick safety reference material relating to infectious micro-organisms.


The MSDS are organized to contain health hazard information such as infectious dose, viability (including decontamination), medical information, laboratory hazard, recommended precautions, handling information and spill procedures. The intent of these documents is to provide a safety resource for laboratory personnel working with these infectious substances. Because these workers are usually working in a scientific setting and are potentially exposed to much higher concentrations of these human pathogens than the general public, the terminology in these MSDS is technical and detailed, containing information that is relevant specifically to the laboratory setting. It is hoped along with good laboratory practices, these MSDS will help provide a safer, healthier environment for everyone working with infectious substances.

Training for Couriers

It is the responsibility of the employer of the couriers to training the couriers. If it is an outside firm, you must state in the contract that the employer is required to provide bloodborne pathogen as well as shipping training to each courier that picks up from your site.

If your couriers are in house, you are responsible for their training. They are to be trained on bloodborne pathogens and shipping as well. They are to understand that they are responsible for the package when it is in their possession. They have the right to refuse to take a package that is not appropriately packed and labeled therefore they need to know what is required for proper packaging so they can tell at a glance whether to accept the package or not. They are not responsible for packaging the shipment. That has do be done by whomever is shipping the package. Anytime blood or body fluids go across a public street or highway they must be packaged according to DOT. If it is a doctor’s office that is shipping to you, then they need to have shipping training also.

Information from OSHA about Physician Offices

Physicians and other medical professionals are dedicated to helping patients mend their injuries and cure their illnesses. Employers whose workplaces are in medical facilities must be aware of the importance of protecting their staff from hazards as well. Doctors, nurses and other staff face potential dangers from needlesticks, exposure to infectious diseases, contamination and dangerous chemicals. OSHA recognizes the significance of medical employees having a work environment reasonably free of occupational hazards. OSHA's Medical and Dental Offices: A Guide to Compliance with OSHA Standards (OSHA 3187), provides a brief overview of the hazards most frequently found in medical and dental offices. It also highlights the OSHA-approved standards and guidelines employers must follow to promote employee safety and health. The brochure summarizes standards on :
Bloodborne Pathogens
Hazard Communication
Ionizing Radiation
Exit Routes
Electrical

Visit OSHA's Web site for more informational materials focusing on safety and health dangers. Look for "Quick Tips" on a new occupational safety and health topic in your next issue of QuickTakes.

Rapid HIV Testing Following a Needlestick

The following question was submitted to OSHA:

Is it a violation of 29 CFR 1910.1030 for a medical facility subject to OSHA authority not to perform "rapid HIV antibody testing" on a source individual after an exposure incident?

Here is the reply from OSHA's Richard Fairfax at the Office of Health Enforcement:

Reply: As you may know, the bloodborne pathogens standard provides that "the source individual's blood shall be tested as soon as feasible" after an exposure incident and after consent is obtained [29 CFR 1910.1030(f)(3)(ii)(A)]. At the current time there are at least four FDA-approved tests available for "rapid HIV antibody testing," which usually can confirm negative HIV status in less than an hour after blood is drawn from a source individual. They are widely available, easy to use, and inexpensive. Standard enzyme immunoassay (EIA) testing can take a much longer time, especially if facilities to perform the tests are not available locally. Therefore, an employer's failure to use rapid HIV antibody testing when testing as required by paragraph 1910.1030(f)(3)(ii)(A) would usually be considered a violation of that provision. The use of rapid HIV antibody testing is supported by the current CDC recommendations for HIV post-exposure prophylaxis (PEP) in the Updated U.S. Public Health Service Guidelines for the Management of Occupational Exposures to HIV and Recommendations for Postexposure Prophylaxis, published on September 30, 2005. The CDC states on page 7 that having a "rapid HIV test could result in decreased use of PEP and spare personnel both undue anxiety and adverse effects of antiretroviral PEP." The document goes on to note on page 8 that "rapid HIV testing of source patients can facilitate making timely decisions regarding use of HIV PEP after occupational exposures to sources of unknown HIV status." Current guidance on the management of HBV and HCV exposure and PEP, as well as guidance for evaluation of the exposure source, is also contained in the Updated U.S. Public Health Service Guidelines for the Management of Occupational Exposures to HBV, HCV and HIV and Recommendations for Postexposure Prophylaxis (June 29, 2001), Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statute, standards, and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov. If you have any further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190.

Teaching Tools

Need some tools for teaching safety. The CDC has a set of cards covering infectious diseases that are free. Go to www.cdc.gov/ncidod for more information. Also check out some of the great animated bugs at http://www.nanobugs.com/. These are great teaching tools for all ages.

Planning for an OSHA Inspection

Concerned about what happens during an OSHA inspection? Like to know how to plan for such an event. Get a copy of our white paper, "Planning for an OSHA Inspection" by sending an email to info@safetylady.com and requesting it.

Shoes for the Clinical Laboratory

In 1980, CAP generated a document that said laboratory employee shoes must adequately cover the foot – not be made of canvas or be sandals or sneakers or open toed.

CLSI document GP17-A2 states:

“Shoes should be comfortable, rubber-soled, and cover the entire foot. Disposable, fluid-resistant shoe covers can be worn for jobs where splashing is expected. Because canvas shoes will absorb chemicals or infectious fluids, they are not recommended (if worn, they should be covered with disposable, fluid-resistant shoe covers). Leather or a synthetic, fluid-impermeable material is suggested.”

The committee that worked on GP17-A2 was made up of physicians and representatives of both CAP and CLSI. The document was also crafted to meet ISO 15190 requirements for medical laboratories.

I can’t speak for the whole facility, but these are the requirements for lab employees. Crocs do not cover the entire foot therefore they are not allowed in the lab.

Proper Laboratory Temperature

The temperature in the lab should be maintained at 65-70 degrees Fahrenheit with a humidity between 35 and 55%. The American Society of Heating, Refrigeration and Air Conditioning Engineers (ASHRAE) have guidelines covering these ranges. As laboratories add more automated equipment, the room temperature goes up due to the amount of heat generated. Old labs are often a composite of several small rooms that lack the proper circulation and ventilation. If it is too hot, the equipment doesn’t work properly and the lab results are erroneous. ASHRAE also states that air exchange is important. Twelve exchanges per hour removes 99% of airborne particulates in 23 minutes. Armed with this information, laboratory management should work with the facility’s engineering department to assure employee comfort.