Friday, May 30, 2014

Housekeepers, maintenance workers and janitors

Q6. We have employees who are designated to render first aid. Are they covered by the standard?

A6. Yes. If employees are trained and designated as responsible for rendering first aid  as part of their job duties, they are covered by the protections of the standard. However, OSHA will consider it a de minimis violation - a technical violation carrying no penalties - if employees, who administer first aid as a collateral duty to their routine work assignments, are not offered the pre-exposure hepatitis B vaccination, provided that a number of conditions are met. In these circumstances, no citations will be issued.
The de minimis classification for failure to offer hepatitis B vaccination in advance of exposure does not apply to personnel who provide first aid at a first-aid station, clinic, or dispensary, or to the healthcare, emergency response or public safety personnel expected to render first aid in the course of their work. The de minimis classification is limited to persons who render first aid only as a collateral duty, responding solely to injuries resulting from workplace incidents, generally at the location where the incident occurred. To merit the de minimis classification, the following conditions also must be met:
  • Reporting procedures must be in place under the exposure control plan to ensure that all first-aid incidents involving the presence of blood or OPIM are reported to the employer before the end of the work shift during which the incident occurs.
  • Reports of first-aid incidents must include the names of all first-aid providers who rendered assistance and a description of the circumstances of the accident, including date and time, as well as a determination of whether an exposure incident, as defined in the standard, has occurred.
  • A report that lists all such first-aid incidents must be readily available to all employees and provided to OSHA upon request.
  • First-aid providers must receive training under the Bloodborne Pathogens standard that covers the specifics of the reporting procedures.
  • All first-aid providers who render assistance in any situation involving the presence of blood or other potentially infectious materials, regardless of whether or not a specific exposure occurs, must have the vaccine made available to them as soon as possible but in no event later than 24 hours after the exposure incident. If an exposure incident as defined in the standard has taken place, other post-exposure follow-up procedures must be initiated immediately, as per the requirements of the standard.

Q7. Are employees such as housekeepers, maintenance workers and janitors covered by the standard?

A7. Housekeeping workers in healthcare facilities may have occupational exposure, as defined by the standard. Individuals who perform housekeeping duties, particularly in patient care and laboratory areas, may perform tasks, such as cleaning blood spills and handling regulated wastes, which cause occupational exposure.
While OSHA does not generally consider all maintenance personnel and janitorial staff employed in non-healthcare facilities to have occupational exposure, it is the employer's responsibility to determine which job classifications or specific tasks and procedures involve occupational exposure. For example, OSHA expects products such as discarded sanitary napkins to be discarded into waste containers which are lined in such a way as to prevent contact with the contents. At the same time, the employer must determine if employees can come into contact with blood during the normal handling of such products from initial pick-up through disposal in the outgoing trash. If OSHA determines, on a case-by-case basis, that sufficient evidence of reasonably anticipated exposure exists, the employer will be held responsible for providing the protections of 29 CFR 1910.1030 to the employees with occupational exposure.

Friday, May 23, 2014

Bloodborne Pathgoens FAQs: Part 2

Q1. Who is covered by the standard?

A1. The standard applies to all employees who have occupational exposure to blood or other potentially infectious materials (OPIM).
  • Occupational exposure is defined as reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee's duties.
  • Blood is defined as human blood, human blood components, and products made from human blood.
  • Other potentially infectious materials is defined as the following: saliva in dental procedures; semen; vaginal secretions; cerebrospinal, synovial, pleural, pericardial, peritoneal, and amniotic fluids; body fluids visibly contaminated with blood; along with all body fluids in situations where it is difficult or impossible to differentiate between body fluids; unfixed human tissues or organs (other than intact skin); HIV-containing cell or tissue cultures, organ cultures, and HIV- or HBV-containing culture media or other solutions; and blood, organs, or other tissues from experimental animals infected with HIV or HBV.

Q2. Does the Bloodborne Pathogens standard apply to employees in the agriculture, maritime and construction industries?

A2. The standard does not apply to agriculture or construction. The standard applies to ship repairing, shipbuilding and shipbreaking and on commercial fishing vessels and other vessels where OSHA has jurisdiction, but not in longshoring and marine terminals. However, the General Duty Clause (Section 5(a)(1) of the OSH Act) will be used, where appropriate, to protect employees from bloodborne hazards in construction, longshoring, marine terminals and agriculture.

Q3. Are volunteers and students covered by the standard?

A3. Volunteers are not covered by the standard. Students are covered if they are compensated.

Q4. Are physicians who are not employees of the hospital in which they work covered by the standard?

A4. Physicians employed by professional corporations are considered employees of that corporation. The corporation which employs these physicians may be cited by OSHA for violations affecting those physicians. The hospital where the physician practices may also be held responsible as the employer who created or controlled the hazard. Physicians who are sole practitioners or partners are not considered employees under the OSH Act; therefore, they are not covered by the protections of the standard. However, if a physician not employed by a hospital were to create a hazard to which hospital employees were exposed, it would be consistent with current OSHA policy to cite the hospital, the employer of the exposed employees, for failure to provide the protections of the Bloodborne Pathogens standard.

Q5. My company supplies contract employees to healthcare facilities. What are my responsibilities under the Bloodborne Pathogens standard?

A5. OSHA considers personnel providers, who send their own employees to work at other facilities, to be employers whose employees may be exposed to hazards. Because your company maintains a continuing relationship with its employees, but another employer (your client) creates and controls the hazard, there is a shared responsibility for assuring that your employees are protected from workplace hazards. The client employer has the primary responsibility for such protection, but the "lessor employer" likewise has a responsibility under the Occupational Safety and Health Act. In the context of OSHA's standard on Bloodborne Pathogens, 29 CFR 1910.1030, your company would be required, for example, to provide the general training outlined in the standard; ensure that employees are provided with the required vaccinations; and provide proper follow-up evaluations following an exposure incident. Your clients would be responsible, for example, for providing site-specific training and personal protective equipment, and would have the primary responsibility regarding the control of potential exposure conditions. The client, of course, may specify what qualifications are required for supplied personnel, including vaccination status. It is certainly in the interest of the lessor employer to ensure that all steps required under the standard have been taken by the client employer to ensure a safe and healthful workplace for the leased employees. Toward that end, your contracts with your clients should clearly describe the responsibilities of both parties in order to ensure that all requirements of the standard are met.

Tuesday, May 20, 2014

Bloodborne Pathogens FAQs

What are bloodborne pathogens?

Bloodborne pathogens are infectious microorganisms in human blood that can cause disease in humans. These pathogens include, but are not limited to, hepatitis B (HBV), hepatitis C (HCV) and human immunodeficiency virus (HIV). Needlesticks and other sharps-related injuries may expose workers to bloodborne pathogens. Workers in many occupations, including first aid team members, housekeeping personnel in some industries, nurses and other healthcare personnel may be at risk of exposure to bloodborne pathogens.

What can be done to control exposure to bloodborne pathogens?

In order to reduce or eliminate the hazards of occupational exposure to bloodborne pathogens, an employer must implement an exposure control plan for the worksite with details on employee protection measures. The plan must also describe how an employer will use a combination of engineering and work practice controls, ensure the use of personal protective clothing and equipment, provide training , medical surveillance, hepatitis B vaccinations, and signs and labels, among other provisions. Engineering controls are the primary means of eliminating or minimizing employee exposure and include the use of safer medical devices, such as needleless devices, shielded needle devices, and plastic capillary tubes.

How do I find out about employer responsibilities and worker rights?

Workers have a right to a safe workplace. The law requires employers to provide their employees with working conditions that are free of known dangers. The OSHA law also prohibits employers from retaliating against employees for exercising their rights under the law (including the right to raise a health and safety concern or report an injury). For more information see or worker rights.
OSHA has a great deal of information to assist employers in complying with their responsibilities under the OSHA law.

OSHA can help answer questions or concerns from employers and workers. To reach your regional or area OSHA office, go to OSHA's Regional & Area Offices webpage or call 1-800-321-OSHA (6742).
Small Business employers may contact OSHA's free and confidential on-site consultation service to help determine whether there are hazards at their worksites and work with OSHA on correcting any identified hazards. On-site consultation services are separate from enforcement activities and do not result in penalties or citations. To contact OSHA's free consultation service, go to OSHA's On-site Consultation webpage or call 1-800-321-OSHA (6742) and press number 4.

Workers may file a complaint to have OSHA inspect their workplace if they believe that their employer is not following OSHA standards or that there are serious hazards. Employees can file a complaint with OSHA by calling 1-800-321-OSHA (6742) or by printing the complaint form and mailing or faxing it to your local OSHA area office. Complaints that are signed by an employee are more likely to result in an inspection.
If you think your job is unsafe or you have questions, contact OSHA at 1-800-321-OSHA (6742). It's confidential. We can help. For other valuable worker protection information, such as Workers' Rights, Employer Responsibilities, and other services OSHA offers, visit OSHA's Workers' page.

Monday, May 12, 2014

Program Evaluation

By establishing evaluation procedures and a process for enhancing your safe patient handling program, you can periodically assess the effectiveness of your hospital's efforts and ensure continuous safe patient handling improvement and long-term success. A few evaluation steps to consider:
  • Set goals that include worker safety. Most hospitals already have safety goals, but the safe patient handling leaders include worker safety in their goals and measure whether they are meeting them.
  • Track the success of your program. Examine the number and type of patient handling injuries, the root causes that led to these injuries, the number of lost work or modified duty days, and more types of program measures. You can also assess the efficacy of your safe patient handling policies. These data can also help you identify opportunities for improvement. 
  • Share results with your employees. Sharing safety trend data creates motivation and instills pride (and competition) among units to achieve success.
  • Gather feedback from staff who handle patients. Realize that every program will need adjustments after being put into practice. Even small changes can improve the use of equipment and worker engagement tremendously.
Looking to build on your program's success? Learn from some hospitals that have implemented safe patient handling practices* with positive results.

The following resources will help you evaluate your hospital's safe patient handling program: