OSHA Seeking Comments for Possible Infectious Agents Standard

OSHA is requesting information and comment on occupational exposure to infectious agents in settings where healthcare is provided, (e.g., hospitals, outpatient clinics, etc.), and healthcare-related settings (e.g., laboratories that handle potentially infectious biological materials). OSHA is interested in strategies that are being used in such healthcare and other healthcare-related work settings to mitigate the risk of occupationally-acquired infectious diseases.

David Michaels, OSHA’s new director stated in May that OSHA has inadequate standards for workers exposed to infectious materials. “The OSHA laboratory standard deals with chemicals,” Mr. Michaels said. “It doesn’t deal with infectious agents.” Rather than trying to establish new rules for each infectious agent or for any specific hazards, Mr. Michaels expects OSHA to eventually require employers, in consultation with their employees, to identify all potential hazards in their workplaces and to take steps to reduce them. OSHA would then have the power to cite employers for failure to adequately implement this process.

As a first step toward possible new regulations, the agency issued a sweeping request for information on occupational risks from infectious agents, and for suggestions on how best to reduce them. The focus is mainly on hospital and other health care workers, but any rules are expected to also cover industry laboratory workers. The deadline for comments is August 4, 2010. For more information go to: http://tinyurl.com/2984wbm.

How to Don and Doff a Lab Coat

OSHA requires that all lab employees be able to demonstrate how to don and doff a lab coat. For written instructions go to the CDC link at: http://www.cdc.gov/ncidod/dhqp/pdf/ppe/ppeposter148.pdf

Cleaning Blood Spills From Carpets

In a letter of interpretation on June 10, 1994, OSHA stated "that carpeted surfaces cannot be routinely decontaminated," but it makes no specific recommendations for decontamination. The letter explains that even though in most cases there is minimal dermal exposure to carpeting, employers must make a reasonable effort to clean and sanitize carpeting with carpet detergent/cleaner products. Carpet should not be used in areas where the chance of blood and body fluid spills can occur.

Pediatric Source Blood Draws

Labs in a pediatric faciity need to draw source-patient blood after a needlestick exposure just as in an adult facility. You cannot claim to observe universal precautions, which OSHA requires, when you assume that blood or body fluids from a pediatric patient pose no risk in an occupational exposure. If you don't obtain a blood sample, even from a pediatric patient, you are not in compliance with the OSHA bloodborne pathogen standard.

Workplace Safety

On this Labor Day, OSHA reminds everyone to make workplace safety and health a top priority. Through its balanced approach, OSHA helps to assure employee safety and health by setting and enforcing standards; providing training, outreach and education; establishing partnerships; and encouraging continual process improvement in workplace safety and health. There are a number of OSHA resources available to assist employers and employees in identifying workplace hazards and possible solutions to those hazards.

OSHA Fines

Ever wonder what OSHA really fines facilities for violations? Most places keep that under their hat unless there is a death that occurs and the incident makes the papers. However, a recent edition of Medical Environment Weekly, published by HCPro stated that OSHA fines for a first time violation of the safety needle requirement was $394.

NIOSH Fact Sheet

NIOSH has just published a new fact sheet that indicates bloodborne pathogen exposure control plans must be specirfic to your facility, updated yearly and accessible to all employees. Recently OSHA fined a physician office $2,000 for not making the exposure control plan available to all its employees.

Stockpiling Respirators and Facemasks for Pandemic Flu

Is your facility concerned about a possible pandemic flu? Are you stockpiling respirators and facemasks in anticipation? OSHA has a proposed guideline on just this issue and you have until July 8, 2008 to coment. Check out the May 9th Federal Register for details on how to submit coments.

Chemical Hygiene

Under the OSHA Chemical Hygiene Standard of 1990, chemicals that are in kits or contain less than 1% of a hazardous chemical do not have to be listed or treated differently. Many of the stains and reagents come in kits and rarely contain any chemical that is more that 1%. One colleague asked specifically about the Hematek packs. Under OSHA's definition they are considered a kit. They can remain on the shelf until they are opened and put on the machine where they remain until the pack is empty.

May is Healthy Vision Month

Healthy Vision Month is an annual observance coordinated by the National Eye Institute of the National Institutes of Health (NIH) each May. It encorages workers to make vision a health priority in the workplace. OSHA is reminding everyone about the importance of eye protection on the job. Here is what you can do to protect your eyes:

• Choose effective protective eyewear deisgned for your specific lab task
• Make sure the eyewear is properly fitted
• Know where the protective eyewear is located and how it should be used

For more informatio on prevening workplace injuries visit OSHA's Web site.

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.

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.