Transcript OSHA Compliance Instruction CPL 2-2.44D

Bloodborne Pathogens
Compliance
Amber Hogan
Industrial Hygienist
OHCA, OSHA National Office
Items Most Frequently Causing SharpObject Injuries
EPINet, 84 health care facilities, 1993-2000, cases=23,692
35
30
% of cases
25
20
blood-filled needles*
non blood-filled needles or
solid-core devices
(*24% of injuries involved
blood-filled needles)
Additional categories:
Fingernails/teeth (1.2%)
Scissors (0.9%)
Razors (0.6%)
Retractors, skin/bone hooks (0.5%)
Drill bit (0.3%)
Wire (0.3%)
Pin (0.3%)
Bovie electrocautery (0.3%)
Microtome blade (0.3%)
Trocar (0.3%)
Pickup/forceps/hemostats (0.3%)
Other sharp item (5.7%)
15
10
5
0
International Health Care Worker Safety Center, Univ. of Virginia
Non- Sharp Exposures
MOST EXPOSURES ARE FROM NON-SHARPS
(Splashes and Splatters)!
Touch unprotected skin
86%
Touch skin through gap between protective garments
6%
Soak through protective garment
3%
Soak through clothing
6%
EPINet 1999
Exposures: Job Categories
• Nurses
• MDs
• Other
40%
~20%
phlebotomists, housekeepers,
students, etc.
Bloodborne Pathogens Standard
*Needlestick Safety and Prevention Act
Major Provisions by Paragraph
(b) *Definitions
(c) *Exposure Control Plan (ECP)
(d) Engineering and Work Practice Controls
- Personal Protective Equipment (PPE)
(e) HIV and HBV Research Labs
(f) Vaccination, Post-Exposure Follow-up
(g) Labeling and Training
(h) *Recordkeeping
Revisions to Standard
• Additional definitions, paragraph (b)
– Needleless Systems, SESIPs
• New requirements in the Exposure Control
Plan, paragraph (c)
– Solicitation of input from non-managerial
employees, paragraph (c)
– Annual review of devices
• Sharps injury log, paragraph (h)
Contracts, contracts, contracts
• Contractors and Multi-Employer Worksites
– Phlebotomy, Laundry, Nursing Services, Physicians,
Administrative Staff
• Contracts with Personnel Services
– Site-specific training, post-exposure
follow-up, etc.
• Contracts with Residents
– Engineering Controls (e.g., insulin syringes)
Multi-Employer Worksites
Personnel
Services
Home
Health
EC &
PPE
+

(ADA v.
Martin)
HBV,
Trng
, General
, Specific

MDs w/
Privilege
Indepnt
Contracts
Example RNs, LPNs, Hlthcare Orthopod, Housekpg,
NAs
in Homes Plstic Surg Rad, Lndy
ECP




 and/or +  and/or +


Engineering and
Work Practice
Controls
Remember…
• Engineering AND Work Practice Controls
– Use Safer Devices
– Immediate Disposal
• Engineering Controls for all exposures
– Sharps
– Splashes
- Splatters
- Pools and Puddles
Safer Device Examples
More Examples…
Common Compliance Issues in
Nursing and Personal Care
Facilities
Insulin and Other Inject-ables
• Issues:
– Daily injection of
insulin or other meds
– Residents supply
syringes
– CMMS reimbursement
• Bottom line:
– OSHA requires
employers to provide
engineering controls
• Solution?
– Contract agreement
between home and
resident
Old Supplies of Straight Syringes
Employer…
• “Can I use up my old
supply of regular
syringes?”
• “Its okay if we just
keep safer devices on
the shelf incase an
OSHA inspector
comes.”
OSHA…
• SESIPs must be
evaluated, selected,
AND implemented
• May still be need for
regular syringes
Geriatrics as a Specialty
Employer…
• Elderly are no/low risk for
BBPs
___________________
• Device negatively affects
medical procedure
OSHA…
• Eng Controls must be
used to eliminate
exposure to blood and
OPIM
____________________
• Positive defense
Blood Tube Holders
Employer…
• “Reuse of tube holders
saves money”
OSHA…
• Each blood tube
holder with needle
attached must be
immediately discarded
into a sharps box after
activation of its safety
feature
Needle Destruction Devices
• ER must evaluate SESIPs
Pros:
• Protects Downstream
Cons:
• MUST be used in exact
accordance with
manufacturers instructions
• Not engineering control
for “point of use”
HBV Vaccination and Titer
• HBV vaccination prior to placement
• Antibody test required
– CDC…“all healthcare personnel who have
contact with patients or blood and are at
ongoing risk for percutaneous injuries should
be tested 1-2 months…”
Post-Exposure Follow-up
• “As soon as possible”
• Site-specific location
• Appropriate clinical evaluation
–
–
–
–
Contaminated needle?
Source known?
Rapid HIV for source within 48 hours
Prophylaxis
Recordkeeping
• Reporting Injuries
– Actual and Near Misses
– Sharps Injury Log
• Recording Injuries
– Sharps Injury Log and OSHA 300/301, etc.
• Using data as device surveillance
Other BBP Compliance Issues…
QUESTIONS?
Occupational Exposure to
Tuberculosis (TB)
Enforcement Procedures and
Scheduling for Occupational
Exposure to Tuberculosis,
OSHA Instruction CPL 2.106
• Issued February 9, 1996
• Provides uniform inspection procedures
• Guidance on 5(a)(1) and pertinent standards
CPL 2.106, Applicability
OSHA
• Scope of workplaces
– Health Care Facilities
– Correctional Institutions
– Long-term Care Facilities
for Elderly
– Homeless Shelters
– Drug Treatment Centers
“Minimal” Program
• TB control plan with certain minimal elements:
– Action Plan
• For resident (e.g., isolation, transport)
• For employee (e.g., respirator)
–
–
–
–
–
Baseline skin test and medical history
Medical management where necessary
Employee training
Record keeping
Coordination with Public Health Agency
Inspection Procedures
• Trigger for Coverage:
– CSHO to establish if facility has suspect or
confirmed TB case w/in previous 6 months
• If so, review employer’s TB plan with
Infection Control Director
• Verify implementation of plan through
employee interviews, direct observation
Citation Policy
• If TB exposure, then employers must comply
with:
–
–
–
–
5 (a)(1) – General Duty Clause
1910.139 - Respiratory Protection
1910.145 - Accident Prevention Signs and Tags
1910.1020 - Access to Employee Exposure and Medical
Records
– 1904 - Recording and Reporting Occupational Injuries
and Illnesses
5(a)(1) Documentation
• Must have:
– Confirmed or suspected case, 6 months
– Recognition of hazard
• Established by CDC for high hazard industries
– Citations issued to:
• Higher incidence than general public
• Not provided appropriate protection/feasible
abatement, AND
• Employee had exposure to TB (exhaled air, droplets
Recordability
• High-Risk Facility
• Employee is negative one year, positive the
next
• Can not positively show that exposure was
somewhere else
CSHO Protection
• Use professional judgment, extreme caution
– Do not enter isolation area
• On rare occasions, if necessary, wear
appropriate PPE
– Negative pressure, elastomeric, HEPA
• Offered TB skin test