OSHA inspectors to check sharps, work practices
January 1, 2000 3 minutes read
OSHA inspectors to check sharps, work practices
Exposure control plan must be updated annually
The Occupational Safety and Health Admini stration recently revised its compliance guidance to inspectors enforcing the bloodborne pathogens standard, emphasizing that hospitals can be cited and fined unless needle safety devices are being regularly evaluated.1 The Nov. 5, 1999, directive states that employers must review and update the exposure control plan at least annually to reflect changes in technology, such as the use of effective engineering controls that can eliminate or minimize exposures.
"There is now a large body of research and data available to OSHA and the public concerning the effectiveness of these engineering controls," the directive states. ". . . The employer must review and update the [exposure control] plan as necessary to reflect changes in the technology, such as the use of effective engineering controls that eliminate or minimize exposures."
Highlights of the requirements are summarized from the compliance directive as follows:
Engineering controls and work practices [paragraph (d)(2)(i)]: This paragraph requires the employer to institute engineering and work practice controls as the primary means of eliminating or minimizing employee exposure. It conforms to OSHA’s traditional adherence to a hierarchy of controls. OSHA has always required employers to use engineering and work practice controls. Thus the employer must use engineering and work practice controls that eliminate occupational exposure or reduce it to the lowest feasible extent. It is OSHA’s view that preventing exposures requires a comprehensive program, including engineering controls (e.g., needleless devices, shielded needle devices, and plastic capillary tubes) and proper work practices (e.g., no-hands procedures in handling contaminated sharps, eliminating hand-to-hand instrument passing in the operating room). Where engineering controls will reduce employee exposure either by removing, eliminating or isolating the hazard, they must be used. Significant improvements in technology are most evident in the growing market of safer medical devices that minimize, control or prevent exposure incidents. OSHA does not advocate the use of one particular device over another.
Inspection guidelines. The compliance officer should determine by interviews or observation whether sufficient engineering controls and work practices are used. While it is generally accepted that an exposure incident can occur at any time or place, a review of the facility records can better direct the officer to areas that are more likely to be sites of exposure incidents. The officer should determine if there were occasions where injuries were incurred during the same procedure, using the same equipment, in the same location or among similar employees (e.g., housekeepers) and determine whether engineering or work practices have been implemented to prevent or minimize future injuries. The compliance officer should investigate whether the employer has instituted alternative engineering controls and work practices to eliminate or minimize employee exposure in areas where exposure incidents have been documented.
Citation guidelines. Paragraph (d)(2)(i) should be cited for failure to use engineering/work practice controls as discussed above. The compliance officer should carefully evaluate the exposure control measures, such as effective engineering controls, that are in use at the facility. Part of the evaluation should include whether other devices that are commercially available were reviewed or considered by the employer and whether there is evidence that other engineering controls would reduce exposures. That would include studies of efficacy, pilot tests by the employer, or data available in published studies. Inspectors should take into consideration that the availability or use of an engineering control is not enough to guarantee that an employee cannot be injured. Employee acceptance and employee training are required for the engineering control to be effective. When the compliance officer finds that an employer is using an engineering control, but believes another device would clearly be more effective than the one in use, the compliance officer should document how the device was being used and how it was selected by the employer and/or employee. The compliance officer should consult with the OSHA regional bloodborne pathogens coordinator to determine if a violation exists.
Reference
1. Occupational Safety and Health Administration. 29 CFR 1910.1030. Occupational Exposure to Bloodborne Pathogens. OSHA instruction CPL 2.103. Field inspection reference manual. Washington, DC: Nov. 5, 1999.
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