A common theme in the call to protect healthcare workers from surgical smoke is the lack of enforcement by OSHA. Given this apparently widespread perception, Hospital Employee Health submitted the following questions to OSHA and received these responses from the agency via email.
HEH: What are OSHA’s regulations on worker exposure to surgical smoke, which NIOSH says can cause “both acute and chronic health effects ranging from eye, nose, and throat irritation to emphysema, asthma or chronic bronchitis?”
OSHA: OSHA does not have a specific standard that addresses hazards related to smoke from surgical procedures. However, there are other OSHA standards related to these hazards, including:
- General Duty Clause. (http://1.usa.gov/1EHfbpD) Employers can be cited for violation of the General Duty Clause if a recognized serious hazard exists in their workplace and the employer does not take reasonable steps to prevent or abate the hazard. The General Duty Clause is used only where there is no standard that applies to the particular hazard.
- Personal Protective Equipment (http://1.usa.gov/1Y0Wynf) worn to minimize exposure to chemical, radiological, and physical hazards during surgery.
- Respiratory Protection (http://1.usa.gov/1QodsXg) to control occupational diseases caused by inhaling air contaminated with harmful substances.
- Air Contaminants (http://1.usa.gov/1fO5bIb), which contains permissible exposure limits for chemicals typically found in surgical smoke.
OSHA’s Laser/Electrosurgery Plume webpage (http://1.usa.gov/20Rqa5J) also provides a letter of interpretation on hazards of smoke generated from surgical procedures and national consensus standards related to laser hazards and non-beam hazards.
HEH: Just to clarify, does OSHA regard surgical smoke as a hazard and would the agency respond to a complaint by a healthcare worker on this?
OSHA: Yes, the agency does consider smoke from surgical procedures hazardous and would investigate if a worker filed a complaint.
HEH: Do you have any data on how often OSHA has inspected/cited healthcare employers on surgical smoke issues?
OSHA: We have not found any such inspections or citations.
No Sense of Urgency
While this may be due in part to the challenge of retrieving records from the bureaucratic entanglement of a federal agency, it inspires little confidence in OSHA’s commitment to protect workers from surgical smoke. Though OSHA confirmed it considers surgical smoke hazardous, its e-tool website is also surprisingly equivocating on the issue (http://1.usa.gov/1TKtL6y ). Words like “may,” “potential,” and “possible” suggest why hospitals may not see surgical smoke evacuation as a compliance priority:
- Laser or electrosurgical units may be required during surgical procedures. Smoke byproduct or “plume” is created when tissue is thermally destroyed. Smoke plume may contain toxic gases and vapors such as benzene, hydrogen cyanide, and formaldehyde, bioaerosols, dead and live cellular material (including blood fragments), and viruses.
- The research is limited on transmission of disease through surgical smoke, but the potential for generating infectious viral fragments, particularly during treatment of venereal warts, may exist. Researchers have suggested that the smoke may act as a vector for cancerous cells which may be inhaled by the surgical team and other exposed individuals.
Potential Hazards: Exposure to high concentrations of smoke may cause ocular and upper respiratory tract irritation and create visual problems for the perioperative team. Smoke may contain toxic gases that could have the potential for adverse health impacts, such as mutagenic and carcinogenic impacts.
Possible Solutions:
- Use portable smoke evacuators and room suction systems with inline filters.
- Keep the smoke evacuator or room suction hose nozzle inlet within 2 inches of the surgical site to effectively capture airborne contaminants.
- Have a smoke evacuator available for every operating room where plume is generated.
- Evacuate all smoke, no matter how much is generated.
- Keep smoke evacuator “ON” (activated) at all times when airborne particles are produced during all surgical or other procedures.
- Consider all tubing, filters, and absorbers as infectious waste and dispose of them appropriately. Use universal precautions as required by the OSHA Bloodborne Pathogens Standard when contaminated with blood or other potentially infectious materials.
- Use new tubing before each procedure and replace the smoke evacuator filter as recommended by the manufacturer.
- Inspect smoke evacuator systems regularly to ensure proper functioning.
A common theme in the call to protect healthcare workers from surgical smoke is the lack of enforcement by OSHA.
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