OSHA wants to know about your competencies
[This is the second part of a two-part series on compliance with the Occupational Safety and Health Administration (OSHA). Last month, we focused on education and training. This month, we’ll discuss sharps safety, personal protective equipment (PPE), hazardous materials, plus more.]
To comply with requirements from the Occupational Safety and Health Administration (OSHA), perform annual competencies on sharps safety, personal protective equipment (PPE), hazardous equipment, employee safety (lifting), chemicals, and hazardous materials, said Beverly Kirchner, BSN, RN, CNOR, CASC, president of Genesee Associates, a Dallas-based national ambulatory surgery center development, consulting, and management company. Kirchner spoke at the recent annual meeting of the Ambulatory Surgery Center Association (ASCA).
OSHA compliance is a hot topic. A fine of $68,000 was proposed for a New Jersey surgery center for 10 “serious” violations related to failure to protect workers exposed to bloodborne pathogen hazards. (See “$68,000 proposed OSHA fine for ASC raises concerns: Is the field complying?” Same-Day Surgery, May 2013, p. 49.)
Sharps injuries have not decreased, despite the fact that they have been regulated for more than 10 years, Kirchner said. The OR is the number one place for sharps injuries, she said.
Based on the Standard Industrial Classification Code for Ambulatory Surgery Centers (8011), ASCs are exempt from keeping the OSHA 300 log. OSHA calls it “partially exempted” because ASCs don’t have to keep the log unless requested by OSHA. You do have to keep an injury list that includes sharps, Kirchner said. “Show the exchange of information and the understanding,” she said.
Keep detailed minutes of meetings regarding needlesticks, Kirchner said. AORN has a sharps safety toolkit. “You can print off the toolkit, and it’s your whole program right there – boom,” Kirchner said. (Editor’s note: A sharp’s safety checklist is available at http://bit.ly/17Xi4yI.) Consider putting your sharps boxes on the side of the computer carts. “Nurses love them, and they don’t have to take a step to do their job,” Kirchner said.
Include bloodborne pathogens training in a staff person’s initial assignment/orientation, within 90 days of any changes to the regulation, and annually, Kirchner said. “If a person changes job and it takes them to a different area or hazard, you have to retrain them at that point and time,” she said. The regulatory text should be available for all staff, Kirchner said.
When you have an incident, do not give the manufacturer any piece of equipment involved in the incident, Kirchner emphasized. “You have to justify to the OSHA surveyor why you did what you did,” she said.
What are you required to have for PPE?
In terms of personal protective equipment (PPE), you can have three to five different types of masks. “It’s employee and doctor preference,” Kirchner said.
Ensure that PPE is comfortable, so it’s not burdensome for your staff, but also meets the rules, she said. For example, use a face shield that touches the chest so no spray can reach under it, she advised. This should be used in the decontamination room or any time liquids are being poured that could be hazardous.
Use heavy gloves in your decontamination room, even if staff complain that they can’t feel with them, Kirchner said. “Thin gloves don’t work,” she said.
There is a “huge debate” over whether circulators should wear eye protection, she said. While it is not required, Kirchner does recommend using it. She recalled an incident in which the nurse was called to the table because the suction was blocked, she said. There was an “explosion” of liquid over her entire face that dripped on her, Kirchner said. “She wore eye protection after that,” she added.
Look at your workers compensation insurance to examine what it says regarding clothing and shoes, such as clogs without backs, Kirchner said.
You should be doing these drills
Complete safety drills for fires, malignant hyperthermia (MH), cardiac arrest, respiratory arrest, hazardous materials, and disasters, Kirchner said.
Bariatric procedures raise new MH concerns, she points out. “Do you have enough dantrolene for bariatric patients?” she asked. “Thirty-six vials are not enough for some patients.”
In terms of fire safety, fire extinguishers are not required in the OR, but where is the no. 1 place surgery providers have a fire? In the OR, Kirchner said.
Extinguishers will not harm the patient, says Kirchner, quoting OSHA and the Association of perioperative Registered Nurses (AORN).
The number one thing to do to avoid OSHA noncompliance is to communicate, Kirchner said. “You cannot communicate enough about hazards and potential hazards in our facilities,” she said.
Tips for OSHA Compliance
• Make sure you have proper spill kits for hazardous materials in your facility. Train employees about how to handle spills of formaldehyde, because that spill is considered an emergency exposure.
• Ensure you have a blood spill kit, and make sure your staff members have been educated on it.
• Look at your facility to determine where there are dangers of falling, such as in the OR. Most ORs have smooth vinyl floors, but textured floors can be twice as expensive. The advantage is that nurses can run on it and not fall.
• If your center uses stepladders to reach items that are stored high, make sure the ladders have the proper feet so they don’t slide.
• Determine whether you have made hand hygiene easy for your employees. For example, can employees easily reach items they need?
• In terms of infection control, conduct surveillance by looking and watching. Hand hygiene programs aren’t enough.
Source: Beverly Kirchner, BSN, RN, CNOR, CASC, president, Genesee Associates, Dallas.
This is the second part of a two-part series on compliance with the Occupational Safety and Health Administration (OSHA). Last month, we focused on education and training. This month, we’ll discuss sharps safety, personal protective equipment (PPE), hazardous materials, plus more.Subscribe Now for Access
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