OSHA Healthcare-Related Regulations

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OSHA Healthcare-Related Regulations

• A practical and understandable guide to the OSHA
  standards that will make your facility a safe
  place to work.

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OSHAs Hospital eTool
The OSH Act of 1970 strives to assure safe and
healthful working conditions for todays
workers, and mandates that employers provide a
safe work environment for employees. Hospitals
and personal care facilities employ approximately
1.6 million workers at 21,000 work sites. There
are many occupational health and safety hazards
throughout the hospital. This eTool focuses on
some of the hazards and controls found in the
hospital setting, and describes standard
requirements as well as recommended safe work
practices for employee safety and health.
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OSHAs Hospital eTool
The OSHA Hospital e-Tool is a stand alone,
interactive, Web-based training tool on
occupational safety and health topics. They are
highly illustrated and utilize graphical menus as
well as expert system modules. These modules
enable the user to answer questions and receive
reliable advice on how OSHA regulations apply to
their work site. These e-Tools do not create new
OSHA requirements.
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OSHAs Hospital eTool

• ICU
• Laboratories
• Laundry
• Laboratories
• Laundry
• Surgical Suite
• Healthcare Wide Hazards
• Other Healthcare Wide

• This eTool addresses the following areas
• Administration
• Central Supply
• Clinical Areas
• Dietary
• Emergency
• Engineering
• Heliport
• Housekeeping

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OSHAs Hospital eTool

• Healthcare Wide Hazards
• Bloodborne Pathogens
• Exposure Control Plan
• HIV, HBV, HCV
• Electrical
• Ergonomics
• Fire Hazards
• Hazardous Chemicals
• Infection-MRSA, VRE, SARS, etc.

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OSHAs Hospital eTool

• Healthcare Wide Hazards (continued)
• Needlesticks
• Mercury Spills
• Slips/Trips/Falls
• Contaminated Work Environments

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OSHAs Hospital eTool

• Housekeeping/Utility Module
• Appropriate Disinfectants
• Contaminated Equipment
• Sharps and Containers
• Hazardous Chemicals
• Latex Allergy
• Slips/Trips/Falls
• Asbestos in Flooring

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OSHAs Hospital eTool
Housekeeping and Asbestos All surfaces must be
maintained as free as possible of accumulations
of waste containing asbestos and/or asbestos
dust. The preferred methods of cleanup are wet
cleaning and/or vacuuming with HEPA filtered
vacuuming equipment. Sanding of asbestos
containing floors (Floor tiles installed before
1980 most likely contain asbestos) is prohibited.
Low abrasion pads at speeds lower than 300 rpm
and wet methods must be used. If floor has
sufficient finish, brushing or dry buffing is
permissible. If workers are required to buff or
wax asbestos containing resilient floors,
building and facility owners must identify the
installed material and inform employees and
employers of outside contractors doing such work.
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OSHAs Hospital eTool
Floors-To Disinfect or Not to DisinfectCDC says,
Extraordinary cleaning and decontamination of
floors in healthcare settings is unwarranted.
Studies have demonstrated that disinfection of
floors offers no advantage over regular
detergent/water cleaning and has minimal or no
impact on the occurrence of healthcare-associated
infections. Additionally, newly cleaned floors
become rapidly recontaminated from airborne
microorganisms and those transferred from shoes,
equipment wheels and body substances.
Nevertheless, healthcare institutions may choose
an EPA-registered detergent/disinfectant for
cleaning low-touch surfaces (e.g., floors) in
patient care areas because of the difficulty that
personnel may have in determining if a spill
contains blood or body fluids (requiring a
disinfection for cleanup) or when a multi-drug
resistant organism is likely to be in the
environment.
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OSHAs Hospital eTool
OSHA's National Office sent a memorandum to its
field offices on November 1, 1996 regarding
inquiries from companies who manufactured and/or
supplied product(s) approved by the EPA as
effective against HBV and HIV. They inquired if
the new EPA registered products with the new EPA
label would be an "appropriate disinfectant"
under OSHA's Bloodborne Pathogen Standard, 29 CFR
1910.1030. This memo stated the products could be
used under limited conditions, specifically where
HIV and HBV were the only pathogens of concern
(for example, in a research setting). Mr. Bach
referred to this memorandum in his article,
"Disinfection Efficacy Against Micobacterium
tuberculosis and the OSHA Bloodborne Pathogens
Standard", in the April 1999 issue of your
Infection Control Today magazine. Unfortunately,
this memorandum was superseded in 1997 and no
longer reflects OSHA's current policy on the use
of disinfectants with an EPA-approval against
HBV/HIV.
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OSHAs Hospital eTool
OSHA MEMORANDUM-CONTINUED OSHA reconsidered the
limitations in the memorandum of November 1, 1996
and issued a revision on February 28, 1997. We
decided that the policy requiring the use of
EPA-registered tuberculocidal disinfectants
and\or a diluted bleach solution to decontaminate
contaminated work surfaces should be expanded to
include EPA-registered disinfectants that are
effective against both HIV and HBV. OSHA's
current policy is that EPA-registered
disinfectants for HIV and HBV meet the
requirement in the bloodborne pathogen standard
and are "appropriate" disinfectants to clean
contaminated surfaces, provided such surfaces
have not become contaminated with agent(s),
volumes, or concentrations of agent(s) for which
higher level disinfection is recommended.
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OSHA Regulations
General Duty Clause Section 5(a)(1) of the OSH
Act requires that Each employer shall furnish to
each of his employees employment and a place of
employment which are free from recognized hazards
that are causing or are likely to cause death or
serious physical harm to his employees.
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OSHA Regulations

• General Duty Clause (continued)
• Four elements are required for issuing General
  Duty Clause violations
• The employer failed to keep the workplace free of
  a hazard to which employees of that employer were
  exposed.
• The hazard was recognized.
• The hazard was causing or was likely to cause
  death or serious physical harm.
• There was a feasible and useful method to correct
  the hazard.

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OSHA Regulations

• General Duty Clause (continued)
• The General Duty Clause is used only where there
  is no OSHA standard that applies to the
  particular hazard involved.
• Examples of Housekeeping-related workplace
  hazards to which the General Duty Clause may
  apply include
• Aerosolizing disinfectants, bleach, or other
  products which may cause shortness of breath
  (acute) or respiratory illness (chronic).
• Housekeepers who wear exam gloves to do routine
  chemical disinfection or surface cleaning.

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OSHA Regulations
The Exposure Control Plan shall contain at least
the following elements The exposure
determination required by paragraph Regulated
Waste means liquid or semi-liquid blood or other
potentially infectious materials contaminated
items that would release blood or other
potentially infectious materials in a liquid or
semi-liquid state if compressed items that are
caked with dried blood or other potentially
infectious materials and are capable of releasing
these materials during handling contaminated
sharps and pathological and microbiological
wastes containing blood or other potentially
infectious materials.
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OSHA Regulations
The Exposure Control Plan shall be reviewed and
updated at least annually and whenever necessary
to reflect new or modified tasks and procedures
which affect occupational exposure and to reflect
new or revised employee positions with
occupational exposure. The review and update of
such plans shall also Reflect changes in
technology that eliminate or reduce exposure to
bloodborne pathogens and Document annually
consideration and implementation of appropriate
commercially available and effective safer
medical devices designed to eliminate or minimize
occupational exposure.
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OSHA Regulations
Other Potentially Infectious Materials means (1)
The following human body fluids semen, vaginal
secretions, cerebrospinal fluid, synovial fluid,
pleural fluid, pericardial fluid, peritoneal
fluid, amniotic fluid, saliva in dental
procedures, any body fluid that is visibly
contaminated with blood, and all body fluids in
situations where it is difficult or impossible to
differentiate between body fluids (2) Any
unfixed tissue or organ (other than intact skin)
from a human (living or dead) and (3)
HIV-containing cell or tissue cultures, organ
cultures, and HIV- or HBV-containing culture
medium or other solutions and blood, organs, or
other tissues from experimental animals infected
with HIV or HBV.
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Recommendations Regarding the Spraying of
Chemicals
It is recommended that chemical agents or
germicidal detergents not be used in a mist or
spray operation. Any chemical agent,if inhaled
over a long period of time, has the potential of
being detrimental to some individuals. In
general, the desired results can be achieved by
applying a stream of liquid to a mirror, over-bed
table, drinking fountains or similar surfaces or
it can be applied in a stream to a cleaning cloth
which is then used to clean these
surfaces. Spraying chemicals in the air has the
potential for down-side risk not only to the user
of the product but to patients who might have
breathing difficulties or other problems. These
products should not be aerosolized in a
healthcare environment. Some chemical labels
indicate that the product should not be sprayed
in a mist. Read your labels.
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Recommendations for Utility Gloves In Place of
Exam Gloves
It is recommended that the manufacturer of the
glove worn by Housekeepers using chemicals
(especially disinfectants) be asked to provide a
letter to place in your file. This letter should
state that the glove will protect the
Housekeepers hands from chemicals for up to 6
hours per day. If the manufacturer wont provide
a letter to protect you, your hospital and your
workers, you need to find one who will. Consider
using a Nitrile Utility Glove. Most
manufacturers will certify, in writing No
absorption, No strikethrough for 6-8 hours. Sell
your staff that these gloves will provide
chemical protection and that failure to wear them
could lead to disciplinary action up to and
including discharge.
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