Monday, June 30, 2014

Methods of Control

Work Practices  

Q22. Can employees of an ambulance medical rescue service eat or drink inside the cab of the unit?

A22. Employees are allowed to eat and drink in an ambulance cab only if the employer has implemented procedures to permit employees to wash up and change contaminated clothing before entering the ambulance cab, has prohibited the consumption, handling, storage, and transport of food and drink in the rear of the vehicle, and has procedures to ensure that patients and contaminated materials remain behind the separating partition.

Q23. What alternatives are acceptable if soap and running water are not available for handwashing?

A23. Antiseptic hand cleansers in conjunction with clean cloth/paper towels or antiseptic towelettes are examples of acceptable alternatives to running water. However, when these types of alternatives are used, employees must wash their hands with soap and running water as soon as feasible. These alternatives are only acceptable at worksites where it is  infeasible to provide soap and running water.

Q24. What are the labeling exemptions for specimens?

A24. The labeling exemption in section (d)(2)(xiii)(A) of the standard applies to facilities that handle all specimens with Universal Precautions provided the containers are recognizable as containing specimens. This exemption applies only while these specimens remain within the facility. Also, all employees who will have contact with the specimens must be trained to handle all specimens with Universal Precautions. If the specimens leave the facility (e.g., during transport, shipment, or disposal), a label or red color-coding is required.

Q25. Do specimens have to be double-bagged?

A25. Secondary containers or bags are only required if the primary container is contaminated on the outside. Also, if the specimen could puncture the primary container, a secondary puncture-resistant container is required. All specimen containers, primary and secondary, must be closed, properly labeled or color-coded (except as described above) and must prevent leakage.

Q26. Are employers required to decontaminate equipment before servicing or shipping?

A26. The standard requires that all equipment that may be contaminated must be examined and decontaminated as necessary before servicing or shipping. If complete decontamination is not feasible, the equipment must be labeled with the required biohazard label which also specifically identifies which portions of the equipment remain contaminated. In addition, the employer must ensure that this information is conveyed to the affected employees, the servicing representative, and/or the manufacturer, as appropriate, before handling, servicing, or shipping.

Wednesday, June 25, 2014

Methods of Control Continued

Engineering Controls 

Q17. What are engineering controls?

A17. The term, "engineering controls," refers to controls (e.g., sharps disposal containers, self-sheathing needles, safer medical devices, such as sharps with engineered sharps injury protections and needleless systems) that isolate or remove the bloodborne pathogens hazard from the workplace.

Q18. What are some examples of safer devices or alternatives that could be used in lieu of exposed needles?

A18. Some examples of such devices or alternatives include needleless systems, needle-protected systems, and "self-sheathing" needles.

Q19. Are employers required to provide these safer devices?

A19. The standard requires that engineering and work practice controls be used to eliminate or minimize employee exposure. The Exposure Control Plan must document annual consideration and implementation of appropriate, commercially-available and effective engineering controls designed to eliminate or minimize exposure. The employer must solicit and document for this process input from non-managerial employees responsible for direct patient care who are potentially exposed to injuries from contaminated sharps.

Q20. Is recapping of needles allowed?

A20. Bending, recapping, or removing contaminated needles is prohibited, except under certain circumstances. When the employer can demonstrate that bending, removal or recapping is required by a specific medical or dental procedure or that no alternative is feasible, such actions are permitted. However, such actions must be accomplished by some method other than the traditional two-handed procedure (e.g., a mechanical device or a one hand scoop method). For example, these actions may be necessary when performing blood gas analyses; when inoculating a blood culture bottle; or when administering incremental doses of a medication to the same patient. Where no alternative to bending, recapping, or removing contaminated needles is feasible or such action is required by a specific medical or dental procedure there must be a written justification to that effect included as part of the exposure control plan. On the basis of reliable evidence, this justification must state the reason for the employer's determination that no alternative is feasible or must specify that a particular medical or dental procedure requires, for example, the bending of the needle and the use of forceps to accomplish this task. Shearing or breaking contaminated needles is completely prohibited by the standard.

Q21. How should reusable sharps (e.g., large bore needles, scalpels, saws, etc.) be handled?

A21. Reusable sharps must be placed in containers which are puncture-resistant, leakproof on the sides and bottom, and properly labeled or color-coded until they are reprocessed. Contaminated reusable sharps must not be stored or reprocessed in a manner that would require the employee to reach by hand into containers.

Monday, June 16, 2014

Methods of Control

Universal Precautions 

Q15. What is meant by the term Universal Precautions? 

A15. Universal Precautions is OSHA's required method of control to protect employees from exposure to all human blood and OPIM. The term, "Universal Precautions," refers to a concept of bloodborne disease control which requires that all human blood and certain human body fluids be treated as if known to be infectious for HIV, HBV or other bloodborne pathogens. 

Q16. Can Body Substance Isolation (BSI) be adopted in place of Universal Precautions? 

A16. Yes. Body Substance Isolation is a control method that defines all body fluids and substances as infectious. BSI incorporates not only the fluids and materials covered by the standard but expands coverage to include all body substances. BSI is an acceptable alternative to Universal Precautions, provided facilities utilizing BSI adhere to all other provisions of the standard.

Wednesday, June 11, 2014

Exposure Control FAQs continued

Q11. Does the exposure control plan need to be a separate document?

A11. No. The exposure control plan may be part of another document, such as the facility's health and safety manual, as long as all components are included. However, in order for the plan to be accessible to employees, it must be a cohesive entity by itself or there must be a guiding document which states the overall policy and goals and references the elements of existing separate policies that comprise the plan. For small facilities, the plan's schedule and method of implementation of the standard may be an annotated copy of the final standard that states on the document how the provisions of the standard are implemented. Larger facilities could develop a broad facility program, incorporating provisions from the standard that apply to their establishments.

Q12. How often must the exposure control plan be reviewed?

A12. The standard requires an annual review of the exposure control plan. In addition, whenever changes in tasks, procedures, or employee positions affect, or create new occupational exposure, the existing plan must be reviewed and updated accordingly.

Q13. Must the exposure control plan be accessible to employees?

A13. Yes, the exposure control plan must be accessible to employees, as well as to OSHA and NIOSH representatives. The location of the plan may be adapted to the circumstances of a particular workplace, provided that employees can access a copy at the workplace during the workshift. If the plan is maintained solely on computer, employees must be trained to operate the computer.
A hard copy of the exposure control plan must be provided within 15 working days of the employee's request in accord with 29 CFR 1910.1020.

Q14. What should be included in the evaluation of an exposure incident?

A14. Following an exposure incident, employers are required to document, at a minimum, the route(s) of exposure, and the circumstances under which the exposure incident occurred. To be useful, the documentation must contain sufficient detail about the incident. There should be information about the following:
  • The engineering controls in use at the time and work practices followed;
  • Description of the device in use;  
  • The protective equipment or clothing used at the time of the exposure incident;
  • Location of the incident and procedures being performed when the incident occurred; and
  • Employee’s training.
  • The source individual, unless the employer can establish that identification is infeasible or prohibited by state or local law.
The employer should then evaluate the policies and "failures of controls" at the time of the exposure incident to determine actions that could prevent future incidents.

Wednesday, June 4, 2014

Exposure Control FAQs

Q8. What is an exposure control plan?

A8. The exposure control plan is the employer's written program that outlines the protective measures an employer will take to eliminate or minimize employee exposure to blood and OPIM.
The exposure control plan must contain, at a minimum:
  • The exposure determination which identifies job classifications with occupational exposure and tasks and procedures where there is occupational exposure and that are performed by employees in job classifications in which some employees have occupational exposure.
  • The procedures for evaluating the circumstances surrounding exposure incidents;
  • A schedule of how other provisions of the standard are implemented, including methods of compliance, HIV and HBV research laboratories and production facilities requirements, hepatitis B vaccination and post-exposure evaluation and follow-up, communication of hazards to employees, and recordkeeping; Methods of compliance include:
    • Universal Precautions;
    • Engineering and work practice controls, e.g., safer medical devices, sharps disposal containers, hand hygiene;
    • Personal protective equipment;
    • Housekeeping, including decontamination procedures and removal of regulated waste.
  • Documentation of:
    • the annual consideration and implementation of appropriate commercially available and effective safer medical devices designed to eliminate or minimize occupational exposure, and
    • the solicitation of non-managerial healthcare workers (who are responsible for direct patient care and are potentially exposed to injuries from contaminated sharps) in the identification, evaluation, and selection of effective engineering and work practice controls.

Q9. In the exposure control plan, are employers required to list specific tasks that place the employee at risk for all job classifications?

A9. No. If all the employees within a specific job classification perform duties where occupational exposure occurs, then a list of specific tasks and procedures is not required for that job classification. However, the job classification (e.g., "nurse") must be listed in the plan's exposure determination, and all employees within the job classification must be included under the requirements of the standard.

Q10. Can tasks and procedures be grouped for certain job classifications?

A10. Yes. Tasks and procedures that are closely related may be grouped. In other words, they must share a common activity, such as "vascular access procedure" or "handling of contaminated sharps."