# Presentation: 271249

## SPD Safety and Sharps

- Department of Veterans Affairs
- Office of Occupational Safety and Health (00S1)

**Mr. Frank Denny**
**Program Manager, Occupational Safety and Health**
**http://vaww1.va.gov/vasafety/**
**http://www1.va.gov/vasafety/**

## Office of Occupational Safety and Health (00S1)

**Staff**
**John Hancock  - Director**
**   ****(202 273-9742)         (john.hancock@va.gov)**
**Mr. Frank Denny – ****Program Manager, Occupational Safety and Health**** ****(202 273-9743)     (frank.denny@va.gov****)**
**Jim Scaringi – Special Programs (Stress and Aggression Project)**
**    ****(202 273-7381)       (jim.scaringi@va.gov)**
**Mr. David Hull - Federal Workers' Compensation Program Manager**
**    ****(304 429-6741 ex 2334)       (david.hull@med.va.gov)**
**Ms. Amy Delong – Program Assistant**
**    ****(202 273-9745)       (amy.delong@va.gov)**
**FAX Number - (202) 273-9777**
**Intranet:  http://vaww.va.gov/vasafety**
**Internet:  http://www.va.gov/vasafety**

## DASHO

- The Secretary of VA appoints the DASHO
- Designated Agency Safety and Health Official (DASHO) is the individual appointed responsible for the management of the OSH program (29 CFR 1960.2 f and 1960.8)
**The Honorable Michael W. Hager **– per  VA Directive 7700
- Office of OSH (00S1) is staff to the DASHO

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**Notes:**
What is the system supporting OSH
Who should you call and when

## Mandates

-  OSHA - Public Law 91-596, 84 STAT. 1590, 91st  Congress, S.2193 - December 29, 1970
- SEC. 19. Federal Agency Safety Programs and Responsibilities
-     Union Contracts
-     Executive Order 12196
-     VA Policies, e.g., 7176

**http://www.osha.gov/SLTC/etools/hospital/central/central.htm**

**http://vaww1.va.gov/vasafety/page.cfm?pg=4**

## Exposure to Ethylene Oxide Gas (EtO) 

- “Potential Hazard”

## EtO Definitions 1910.1047 (b) 

**"Employee exposure"** means exposure to airborne EtO which would occur if the employee were not using respiratory protective equipment.
**"Action level"** means a concentration of airborne EtO of 0.5 ppm calculated as an eight (8)-hour time-weighted average.
**"8-hour time-weighted average (TWA)."** The employer shall ensure that no employee is exposed to an airborne concentration of EtO in excess of one (1) part EtO per million parts of air (1 ppm) as an (8)-hour time-weighted average (8-hour TWA).
**"Excursion limit."** The employer shall ensure that no employee is exposed to an airborne concentration of EtO in excess of 5 parts of EtO per million parts of air (5 ppm) as averaged over a sampling period of fifteen (15) minutes.
**"Authorized person"** means any person specifically authorized by the employer whose duties require the person to enter a regulated area, or any person entering such an area as a designated representative of employees for the purpose of exercising the right to observe monitoring and measuring procedures under paragraph (l) of this section, or any other person authorized by the Act or regulations issued under the Act.
**"Emergency"** means any occurrence such as, but not limited to, equipment failure, rupture of containers, or failure of control equipment that is likely to or does result in an unexpected significant release of EtO.

**http://www.osha.gov/SLTC/ethyleneoxide/index.html**

## OSHA Fact Sheet

- http://www.osha.gov/OshDoc/data_General_Facts/ethylene-oxide-factsheet.pdf

- Page 1

-   What is EtO
-   It’s Hazard
-   What needs to be done if there is an overexposure
-   Respirators
-   Required Monitoring

## OSHA Fact Sheet

- Page 2

- http://www.osha.gov/OshDoc/data_General_Facts/ethylene-oxide-factsheet.pdf

-   Medical Surveillance
-   Hazard Communication
-   Recordkeeping
-   Protection
-   Additional Information

-   The policies and procedures should outline the training that all employees must receive (e.g., leaks and alarms).
-   The policies and procedures should also delineate appropriate personnel and methods for preparation, mixing, application, storage, removal, and disposal of any hazardous agents.
-   Emergency procedures should include provisions for fires, chemical or radioactive spills, extensive blood or body fluid spills, release of compressed, toxic, and corrosive gases, and power failure.

- OSHA Technical Manual

## Access to Safety Equipment and Condition

- OSHA Technical Manual

- OSHA Technical Manual

- OSHA Technical Manual

## Mercury Spills

## Glutaraldehyde

## Burns and Cuts

## Ergonomics

## Hazardous Chemical

- MSDS

## What is an MSDS?

## Set the Example

## Electrical Hazards

- Safety Glasses are being used...

## Slips/Trips/Falls

## Employees can be Ingenious 

## Working Together

## Latex Gloves

## What is PPE ?

- PPE includes gloves, gowns, laboratory coats, masks, face shields, eye protection, mouthpieces, resuscitation bags, pocket masks, or other ventilation devices.
- PPE is for the hazard potential

- http://www.osha.gov/SLTC/etools/hospital/hazards/ppe/ppe.html

## Workplace Hazard Assessment for Use of PPE

- Workplace Hazard Assessment for Use of PPE

## OSHA

- Number Exposed 3997

- Number Exposed 901

##  General Hand Protection

**29 CFR 1910.138 (a)**
- General requirements.  Employers shall select and require employees to use **appropriate hand protection** when employees' hands are exposed to hazards such as those from skin absorption of harmful substances; severe cuts or lacerations; severe abrasions; punctures; chemical burns; thermal burns; and harmful temperature extremes.

- http://www.osha.gov/SLTC/etools/hospital/hazards/ppe/ppe.html

## What is “Appropriate” PPE

- Performance Oriented
-    For example:  29 CFR 1910.1030(d)(3)(i) -  **PPE:** will be considered "appropriate" only if it does not permit blood or other potentially infectious materials to pass through to or reach the employee's work clothes, street clothes, undergarments, skin, eyes, mouth, or other mucous membranes under normal conditions of use and for the duration of time which the protective equipment will be used.

## Bloodborne Pathogens

## Use of PPE is Required under the  BBP Standard

**29 CFR 1910.1030**PPE is required by the Bloodborne Pathogens Standard if exposure to blood and other potentially infectious materials (OPIM) **is anticipated** and where occupational exposure remains, after institution of engineering and work practice controls (1910.1030(d)(2)(i)).**  **PPE can provide some protection from infectious materials as a barrier to protect skin and mucus membranes from contact with blood and other potentially infectious materials.

- http://www.osha.gov/SLTC/etools/hospital/hazards/ppe/ppe.html

## PPE will be Provided at No Cost

**29 CFR 1910.1030 (d) (3) (i)**
**“**When there is occupational exposure, the employer shall provide, at no cost to the employee, appropriate personal protective equipment such as, but not limited to, gloves, gowns, laboratory coats, face shields or masks and eye protection, and mouthpieces, resuscitation bags, pocket masks, or other ventilation devices.  Personal protective equipment will be considered "appropriate" only if it does not permit blood or other potentially infectious materials to pass through to or reach the employee's work clothes, street clothes, undergarments, skin, eyes, mouth, or other mucous membranes under normal conditions of use and for the duration of time which the protective equipment will be used.”

## Employer is Responsible for Use

**29 CFR 1910.1030 (d) (3) (ii)**
**“**The employer shall ensure that the employee uses appropriate personal protective equipment unless the employer shows that the employee temporarily and briefly declined to use personal protective equipment when, under rare and **extraordinary circumstances**, it was the employee's professional judgment that in the specific instance its use would have prevented the delivery of health care or public safety services or would have posed an increased hazard to the safety of the worker or co-worker.   When the employee makes this judgement, the circumstances shall be investigated and documented in order to determine whether changes can be instituted to prevent such occurrences in the future.”

## PPE Accessible and the Right Sizes

**29 CFR 1910.1030 (d) (3) (iii)**
**“****Accessibility**. The employer shall ensure that appropriate personal protective equipment in the appropriate sizes is readily accessible at the worksite or is issued to employees. Hypoallergenic gloves, glove liners, powderless gloves, or other similar alternatives shall be readily accessible to those employees who are **allergic to the gloves** normally provided.”

## Employer is Responsible for Cleaning

**29 CFR 1910.1030 (d) (3) (iv)**
**“****Cleaning, Laundering, and Disposal**. The employer shall clean, launder, and dispose of personal protective equipment required by paragraphs (d) and (e) of this standard, at no cost to the employee.”

## Employer is Responsible for Repair

**29 CFR 1910.1030 (d) (3) (v)**
**“****Repair and Replacement**. The employer shall repair or replace personal protective equipment as needed to maintain its effectiveness, at no cost to the employee.”

## Use Gloves

**29 CFR 1910.1030 (d) (3) (ix)**
**“**Gloves shall be worn when it can be reasonably anticipated that the employee may have hand contact with blood, other potentially infectious materials, mucous membranes, and non-intact skin; when performing vascular access procedures except as specified in paragraph (d)(3)(ix)(D); and when handling or touching contaminated items or surfaces.”

## Gloves must be in Good Repair

**29 CFR 1910.1030 (d) (3) (ix) (C)**
- “Utility gloves may be decontaminated for re-use if the integrity of the glove is not compromised.  However, they must be discarded if they are cracked, peeling, torn, punctured, or exhibit other signs of deterioration or when their ability to function as a barrier is compromised.”

## Wash Your Hands

- 1910.1030 (d) (2) (v)
- Employees must wash hands immediately or as soon as feasible after removing gloves or other PPE.

## Where is PPE Removed?

- 1910.1030 (d) (3) (vii)
- Employees must remove protective clothing before leaving the room.

## Disposed in What?

- 29 CFR 1910.1030 (d) (3) (viii)
- Dispose of PPE in an appropriately designated area or container for storage, washing, decontamination, or disposal.

## Cleaning Schedule

**29 CFR 1910.1030 (d) (4) (i)**
**“**Employers shall ensure that the worksite is maintained in a clean and sanitary condition. The employer shall determine and implement an appropriate written schedule for cleaning and method of decontamination based upon the location within the facility, type of surface to be cleaned, type of soil present, and tasks or procedures being performed in the area.”

## Reaching into Containers

**29 CFR 1910.1030 (d) (4) (ii) (E)**
- “Reusable sharps that are contaminated with blood or other potentially infectious materials shall not be stored or processed in a manner that requires employees to reach by hand into the containers where these sharps have been placed.”

## What does Regularly Scheduled Mean?

**29 CFR 1910.1030 (d) (4) (ii) (C)**
- “All bins, pails, cans, and similar receptacles intended for reuse which have a reasonable likelihood for becoming contaminated with blood or other potentially infectious materials shall be inspected and decontaminated on a regularly scheduled basis and cleaned and decontaminated immediately or as soon as feasible upon visible contamination.”

## Make Instructions Easy to Understand

## Disposal Containers

**29 CFR 1910.1030 (d) (4) (iii) (A) (4)**
- “Reusable containers shall not be opened, emptied, or cleaned manually or in any other manner which would expose employees to the risk of percutaneous injury.”

- Comment ?

## Disposal Containers Must be Used in a Manor for Which they Were Intended

## Hapatitis B Vaccination

**29 CFR 1910.1030 (f) (2) (i)**
- “Hepatitis B vaccination shall be made available after the employee has received the training required in paragraph (g)(2)(vii)(I) and within 10 working days of initial assignment to all employees who have occupational exposure unless the employee has previously received the complete hepatitis B vaccination series, antibody testing has revealed that the employee is immune, or the vaccine is contraindicated for medical reasons.”

## Training and Education

## Training/Education

**29 CFR 1910.1030 (h)(2)(i)**** - **Training records shall include the following information:
**1910.1030 (h)(2)(i)(A)**** - **The **dates** of the training sessions;
**1910.1030 (h)(2)(i)(B)**** - **The **contents** or a summary of the training sessions;
**1910.1030 (h)(2)(i)(C)**** - **The **names and qualifications** of persons conducting the training;
**1910.1030 (h)(2)(i)(D)**** - **The **names and job titles** of all persons attending the training sessions.
**1910.1030 (h)(2)(ii)**** - **Training **records shall be maintained for 3 years** from the date on which the training occurred.

## Training Elements

**1910.1030 (g)(2)(vii)(A)**** **An **accessible copy**** ****of the regulatory text** of this standard and an explanation of its contents;
**1910.1030 (g)(2)(vii)(B)**** **A **general explanation** of the epidemiology and symptoms of bloodborne diseases;
**1910.1030 (g)(2)(vii)(C)**** **An explanation of the **modes of transmission** of bloodborne pathogens;
**1910.1030 (g)(2)(vii)(D)**** **An explanation of the **employer's exposure control plan** and the means by which the employee can obtain a copy of the written plan;
**1910.1030 (g)(2)(vii)(E)**** **An explanation of the appropriate methods for recognizing **tasks and other activities that may involve exposure** to blood and other potentially infectious materials.

## Education

**1910.1030 (g)(2)(vii)(F)** An explanation of the **use and limitations** of methods that will prevent or reduce exposure including appropriate engineering controls, work practices, and personal protective equipment;
**1910.1030 (g)(2)(vii)(G)** Information on the types, proper use, location, removal, handling, decontamination and disposal of **personal protective equipment**;
**1910.1030 (g)(2)(vii)(H)** An explanation of the **basis for** **selection** of personal protective equipment;
**1910.1030 (g)(2)(vii)(I)** **Information on the hepatitis B vaccine**, including information on its efficacy, safety, method of administration, the benefits of being vaccinated, and that the vaccine and vaccination will be offered free of charge;
**1910.1030 (g)(2)(vii)(J)**** **Information on the **appropriate actions** to take and persons to contact in an **emergency** involving blood or other potentially infectious materials;
**1910.1030 (g)(2)(vii)(K)** An explanation of the **procedure to follow if an exposure incident occurs**, including the method of reporting the incident and the medical follow-up that will be made available;
**1910.1030 (g)(2)(vii)(L)**** **Information on the **post-exposure evaluation** and follow-up that the employer is required to provide for the employee following an exposure incident.

## Education

**1910.1030 (g)(2)(vii)(N)**** **An **opportunity for interactive questions and answers** with the person conducting the training session.
**1910.1030 (g)(2)(viii)**** **The **person conducting the training shall be knowledgeable** in the subject matter covered by the elements contained in the training program as it relates to the workplace that the training will address.

## Education Must be Conducted and Refreshed

## Sharps Injuries Log

**29 CFR 1910.1030 (h)(5)(i)**** – “**The employer shall establish and maintain a sharps injury log for the recording of percutaneous injuries from contaminated sharps.  The information in the sharps injury log shall be recorded and maintained in such manner as to protect the confidentiality of the injured employee.  The sharps injury log shall contain, at a minimum:
**1910.1030 (h)(5)(i)(A)**** - **The type and brand of device involved in the incident,
**1910.1030 (h)(5)(i)(B)**** - **The department or work area where the exposure incident occurred,
**1910.1030 (h)(5)(i)(C)**** - **An explanation of how the incident occurred.
**1910.1030 (h)(5)(ii)**** - **The requirement to establish and maintain a sharps injury log shall apply to any employer who is required to maintain a log of occupational injuries and illnesses under 29 CFR 1904.
**1910.1030 (h)(5)(iii)**** - **The sharps injury log shall be maintained for the period required by 29 CFR 1904.6.”

## Managing Sharps

- What sharps are appropriate for SPD to decontaminate and stored for reuse?
- What sharps are for disposal?
- How is this implemented outside SPD?
- Do facility organization list the sharps they use?

## Question

**29 CFR 1910.1030 (d)(2)(vii)(A)** - OSHA does not allow sharps to be bent, recapped or removed unless the employer can demonstrate that no alternative is feasible or that such action is required by a specific medical or dental procedure.
- Does this mean - Removing and disposal of a scalpel blade at the point of use, while the handle is sent to SPD for sterilization is an OSHA violation?
**29 CFR 1910.1030 (d)(4)(iii)(A)(1)(i)** - Contaminated sharps shall be discarded immediately or as soon as feasible in containers that are:  Closable.
- Does this mean that not removing the disposable contaminated blade at the point of use is an OSHA violation?

## OSHA Evaluates

**   ****Is Management Indifferent to Risk:  **Does “Management” take administrative controls as their responsibility.  Does management staff have the attitude of “O’Well” this happens.  For example:
- Pharmacy prescriptions errors/mistakes occur just as inappropriate sharps being sent to SPD.
- Go a head and write us up, you can not fine the facility.

## Solution

- Compete elimination of all inappropriate sharps arriving in SPD is not needed to comply with OSHA;
- Administrative controls or strong Standard Operating Procedures (SOP) are an acceptable solution; and
- OSHA is looking to the VAMC for a solution, VA has the experts.
- OSHA wishes to see agreement at the facility to the solution.

## OSHA View

- OSHA states that the lack of formal accident reports does not establish a good program, i.e., the injury potential must be considered.
- Exposure Control plan
- Training – who attended

## Violation Topic

**Inadequate Equipment to Screen for Inappropriate Sharps, **i.e., Cut-resistant gloves or push-pull stick
**Program Weaknesses:**
**Administrative controls or strong Standard Operating Procedures (SOP)** were not observed, e.g., administrative commitment to proper sharp management.
**Training **- When OSHA spoke with some employees, e.g., nurses reported that they had not been trained and/or management did not take the issue serious.

## OSHA View

- In OSHA’s Hazard Communication Standard (Preamble)
-    “The effectiveness of a hazard communication program is directly related to the attitude and ability of the person presenting the information to the workers (see Ex. 4-75).  If the trainer conveys the impression that the information is trivial, or the message is unnecessary, then the program will not be effective.”

## Technical Issues

- What is the process of sharp management, i.e. Standard Operating Procedures (SOPs)
- The SOP (Sponge, Instrument and Sharp Counts Policy) is not accepted as a solution by SPD management or the union.  WHY?
- What type of sharps can be sent to SPD?
- What safety procedures can be used?
- What safety equipment is accepted?

## SOPs Need Acceptance

## Management

- Players
-   SPD
-   Clinical organizations that use sharps
-   Safety
-   Administration
-   Unions
-   Committees (Community standards Committee)
-   Other facilities – OSHA will export solutions

## Team Work

## Team Work

## Relationship to Bloodborne Pathogen Standard

- Employers _**may elect**_ to use the OSHA 300 and 301 forms to meet the sharps injury log requirements, _**provided two conditions are met**_:
- The **employer must enter the**** ****type and brand of the device**** ****on either the 300 or 301 form**.
- The **employer must maintain the records in a way that**** ****segregates sharps**** ****injuries from other types of work-related injuries and illnesses, or**** ****allows sharps injuries to be easily separated**.

- Needlesticks and Sharps Injuries – ALL needlesticks and sharps injuries that are contaminated with another persons blood or other potentially infectious material are recordable. Record splashes or other exposures to blood or other potentially infectious material if it results in diagnosis of a bloodborne disease or meets the general recording criteria.

## Recordkeeping

- OSHA 301 or 2162

## Slide 72

## If there was an injury/illness Incident

- What would you do?
- What if there is an incident, e.g., improper disposal, but no injury?

## Questions

## August 24, 2005