Healthcare Infection Prevention-OSHA settles emergency gear cleaning question

Either clean it or red bag it

Hospitals — not paramedics —are responsible for the cleaning of emergency gear soiled in delivery of patients, the U.S. Occupational Safety and Health Administration has ruled in response to a letter by an infection control consultant.

"This is a question that has been going on for years, and finally I just decided to try and put an end to it by writing a formal letter and getting a formal response," says Katherine West, BSN, MSEd, CIC, infection control consultant with Infection Control/Emerging Concepts in Manas-sas, VA. "I think this is really important. It helps the hospitals so they that don't get cited, and it helps emergency medical services get clarification on who is responsible for what."

OSHA's ruling on the issue is summarized as follows from the written answer given to West:

"According to the scenario illustrated in your letter, a fire or rescue service [first responder] responds to emergency situations using their equipment to transport and treat patients while en route to a health care facility. The hospital or other health care facility then removes the patient from the used, contaminated equipment provided by the first responders and proceeds to use its own equipment and medical devices. The facility leaves the equipment used and contaminated for the first responders to pick up and clean. Your question is: 'Who is responsible for cleaning this equipment?'

"Simply, it is every employer's responsibility to ensure a safe and healthful workplace for its employees. More specifically, according to the Bloodborne Pathogens Standard, each employer with employees who may have an occupational exposure to blood or other potentially infectious materials (OPIM) is responsible for eliminating or reducing the potential hazard. In this case, where equipment is shared between first responders and emergency department or general hospital staff, each employer has responsibilities for protecting employees from exposure to blood or body fluids.

"The equipment to which you are referring belongs to the first responders or emergency medical service [EMS] personnel and is to be returned to them for reuse. If a hospital places such equipment, contaminated, in the hallways or in closets awaiting pickup, it is exposing its employees and anyone in the area to potential bloodborne pathogens. According to paragraph (d)(4)(i) of the standard, 'employers shall ensure that (the) worksite is maintained in a clean and sanitary condition.'

"Paragraph (d)(4)(ii) provides that 'all equipment and environmental and working surfaces shall be cleaned and decontaminated after contact with blood or other potentially infectious materials [emphasis added].' Additionally, 'contaminated work surfaces shall be decontaminated with an appropriate disinfectant after completion of procedures; immediately or as soon as feasible when surfaces are overtly contaminated or after any spill of blood or other potentially infectious materials; and at the end of the work shift if the surface may have become contaminated since the last cleaning.'

"OSHA would regard a hospital as having met its obligations with respect to its own employees either by cleaning and decontaminating the equipment in accordance with (d)(4)(i) of the standard, or, alternatively, by preventing employee contact with such equipment by placing it in durable, leakproof, and labeled or color-coded containers and handling it in a manner similar to that prescribed for contaminated laundry [paragraph (d)(4)(iv)] and contaminated laboratory equipment [paragraph (e)(2)(ii)(B)]. The first responders' employer must then ensure that its employees take proper precautions when retrieving and decontaminating the equipment. Communication between two parties with regard to handling and decontamination of supplies and materials is of the utmost importance."