a surprise visit from osha. - absorbent pads for spills
Surprise Tour from OSHA is right here!
"There are no two words that can do more harm to the lab manager.
When I heard them in October, of course I thought so. 25, 1988.
A few months ago, a technical expert filed a complaint with the Occupational Safety and Health Authority.
Now, this division of the United StatesS.
The Department of Labor investigated what Laboratories call safety and health hazards at our doorstep.
The Atlantic Medical Center is two. campus, 300-
Located on the north bank of Boston, the tertiary trauma center.
Just three months ago, I just signed up as labmanager and am still preparing for myself.
That unusually hot summer overwhelmed the hospital's refrigeration system.
On one occasion, when the temperature in an isolated corner of the laboratory reached 90 degrees Fahrenheit, the analyzer refused to operate.
The extremely high ambient temperature causes the instrument to fail.
Conditions of work continued to deteriorate.
When the internal temperature rises, the blood reservoir alarm starts to sound intermittently.
The technicians were not happy either.
One day they went to the company to protest in shorts.
To make the workplace more acceptable, we bring fans from several regions.
This is a big mistake.
The hot summer is still hot; tempers flared;
A frustrated technical expert
As a spokesman
Made a notorious phone call. (
The staff later admitted that it was not a personal matter, but a desperate attempt to ease unbearable conditions. )
That's why I have a notice in my hand that violates some of the rules, such as using a zone fan, which "blows blood and blood products" to the lab staff ".
Other allegations include our failure to specify a "clean area" by labeling the keyboard and phone as "contaminated" and "non-contaminated"
The use of pollution ", the implementation of hand washing rules, the provision of adequate eye protection, and the full documentation of the hospital's formal training program in general preventive measures and hazard communication.
If this is not bad enough, two investigators at OSHA told us that they have the right to review the safety of the hospital as a whole --
And fully intend to do so.
Atlanta was awarded a dubious honor to become the first hospital in the Massachusetts area to undergo such a thorough examination.
The whole process will take five months to complete.
Two of our inspectors will see it all the time.
The OSHA team started the employee interview immediately.
Investigators intend to ask supervisors and technicians at different times and locations.
I was asked to deliver six.
"I quickly reviewed the day's work tasks and transferred two technicians, two technicians and two blood-drawing doctors from the workstation, resulting in the absence, which will cause the laboratory
Participants were told they had the right to refuse to answer any questions.
It was suggested that the Union Labor had a union representative at hand at the time of inquiry.
In conducting interviews with supervisors, managers and administrators are allowed to participate as a whole.
I am sitting with the director of laboratory pathologists and the director of Human Resources, who is also the official escort of OSHA.
The technicians are questioned (en masse)
After closing the door
The initial focus of the competent meeting was on their ability to properly train staff.
All were asked in detail about their familiarity with the material safety data sheet (MSDS)
Hazard Communication and infection control policies.
They were also asked about their professional training and any continuing education they received that made them eligible to train others.
The inspector tested our supervisor's knowledge of the hazard communication standards and the employee's right to know.
The investigation then turned to infection control.
When the hospital's universal preventive measures policy worked, supervisors were asked how the information was passed on to staff.
Investigators asked to review the documents that had actually been properly trained.
Next, the supervisor was asked about the waste disposal issue.
The OSHA team wants to evaluate the consistency of the supervisor's understanding of our agency's infection control policy.
For example, does the supervisor have a clear idea of which items are "in red bags "(
As infectious waste)
With "brown bags "(as non-Pollution waste)?
Finally, there is the problem of full ventilation.
Ironically, as early as August, we installed a new air-conditioning system, and the initial problem was solved.
I spent a lot of "quality time" with members of the OSHA team ".
They raised endless questions about our policies, read our safety manual carefully, asked us how we could share important lab information with our staff, and asked for a large number of documents.
Part of the OSHA strategy is to look at our rankingand-
People at Filelaboratori actually know what management claims to tell them.
Sometimes our ideas change;
They often do not.
For example, I know that the lab encourages staff to get hepatitis B vaccinations.
But they told OSHA we never discussed it.
I think these members have forgotten.
Unfortunately, we lack proper documentation and are therefore stopped for not doing what we actually do.
The rest of the day's OSHA survey involved blood-borne diseases.
Since OSHA has not yet developed its own regulations, inspectors rely on the CDC's guidelines for universal preventive measures. (
In August 1988, OSHA released a teaching guide on exposure to hepatitis B virus and HIV ,(1)
Regulations were put forward in May 1989. (2)
The final regulations have not yet been introduced. )
In line with the CDC guidelines, the OSHA inspector made suggestions.
First of all, we must designate the phone, keyboard, desk and door handle as non-
Contaminated areas and banned gloves and specimens in these areas.
Our goal is obviously to eliminate
Pollution in the workplace.
The supervisor's interview ended with a series of related questions: Are gloves available at any time?
Is their quality acceptable?
Does the lab have a written policy detailing when a doctor must wear gloves?
Is any microbiology examination required?
Should blood bankers wear eye protection devices when cutting market segments?
These questions seem to show that there is a lack of knowledge about the laboratory.
Later, when I learned that the inspectors only visited another laboratory and that we represented their first mission within the hospital, my suspicions were confirmed.
Verify our supervisor's comments on infection control and tracking
Subsequently, the inspection team interviewed a doctor who had reported an accidental needle.
OSHA asked how things happened and after that he was instructed what to do immediately and how the hospital followed up.
The team wants to determine whether our staff health department is trying to determine the source of the patient and obtain his or her consent for hepatitis B virus and HIV testing.
Finally, oshainspector asked if the blood draw doctor was told about the hepatitis vaccine and encouraged him to receive it.
The key to all of these issues is to see if appropriate infection control training has been conducted.
If a blood draw doctor knows nothing about the vaccine, the inspector will assume that he has not been trained at all.
He said no;
We know there is, but there is no documentation to prove it.
Needless to say, in this case, careful record keeping is essential to protect the employer.
Unfortunately, many people have even forgotten the existence of training programs shortly after attending training.
The researchers continued to carry out histological studies, in which formaldehyde was injected when the surgical pathway specimens were sliced.
OSHA wants to know how much formaldehyde is used, where it is used, and how big the container is.
They asked one of our two organization technical experts if she knew the symptoms of acute and chronic exposure and how she would clean up the accidental leak.
The team reviewed our documentation on pouring staff training and tested our ability to produce formaldehyde MSDS on demand.
The campus inspection lasted nearly six months.
Inspectors regularly return to the hospital to evaluate other departments and stay in the laboratory once or twice.
At the summary meeting on last March, the inspectors finally shared their findings, including possible citations.
There are a few surprises.
For example, we understand that the centrifuge is considered a reusable device, so we have to have the scheduled cleaning and sterilization documents on hand.
This revelation sparked an alengthy debate about the classification of reusable devices.
OSHA won the debate.
For the treatment of blood and other body fluids, gloves are considered mandatory, but not mandatory for routine venous incision.
We were told that the blood draw doctor should have a list of the few cases where the gloves were considered mandatory in the specimen purchase.
These exceptions usually include wounds, scratches, or other breakage on the skin of the intravenous doctor;
Taking advantage of uncooperative patients;
Babies and children need to stick with their fingers or heels; and on-the-
Training in venous incision(
By the way, with respect to venous puncture, they can only be cited if the employer does not provide gloves or does not encourage the use of gloves in such "special" circumstances. )
I find the reasons behind this task very strange.
Basically, OSHA says gloves are unnecessary when getting samples, but gloves must be worn when dealing with blood and other body fluids.
Once the blood of the asa patient is removed from the evacuation tube, it will gradually become a specimen state --
The person holding it must wear gloves.
This suspicious distinction must be resolved.
The inspector reiterated the need to eliminate the possibility of laboratory personnel transferring pollution using telephones and computer terminals while wearing dirty gloves.
OSHA recommends that we clearly identify the equipment as "clean" or "contaminated" and strictly enforce the cross-bancontamination. (
Everything in our lab.
Including the door of my office.
A formal label has now been put on. )
The histological Department received two citations.
The first statement is that we have to develop an emergency procedure to clean up the accidental formaldehyde leak, including a cut-off volume limit, and we will notify the Fire Department.
We are also cited for the lack of documentation for training laboratory personnel in the proper handling of formaldehyde.
We were informed that the Code of Federal Regulations No. 29 gave a detailed description of what must be included in the formal training process.
The code requires that all records relating to the training of personnel and the monitoring of formaldehyde content be kept for 30 years after the termination of the service by the employee.
After hard study, I strongly recommend consulting a copy of this section before implementing any training or emergency leak plan.
Nearly six months after the initial investigation, OSHA was quoted.
The document sets out the standards or regulations for the violation and indicates the location of the violation.
It also sets out the dates and fines for failing to comply.
The employer has the right to object to any emission reduction date deemed unreasonable.
This does not apply in our case, as we have corrected almost all the defects.
Copies of all citations are required by law to be posted immediately and prominently-
At or near the offending location.
Before the violation is corrected, or within at least three working days, the city must remain posted.
Based on the information provided at the information meeting, we began to make an immediate correction and when the official reference arrived, we were in poor condition.
In some cases compliance is only a matter of ordering a box of goggles or absorbing pads for cleaning up spills.
Six of us.
A month after I met, I had several opportunities to discuss the goals and ideas of OSHA with investigators.
Although these people are not experts in the way the laboratory operates, they have a good understanding and a considerable understanding of the function of the laboratory.
In retrospect, I think investigation is often an experience of learning from each other.
I do have an issue with the investigators deliberately separating management from staff.
This makes us feel that only the rights of technical and support personnel belong to OSHA.
Inspectors appear to be indifferent to the safety and general rights of management.
OSHA should address the situation or attitude that led us to this perception.
While OSHA's intentions are good, its bureaucratic approach can be frustrating.
For example, inspectors constantly complain to us about the "poor" quality of our gloves ".
The problem is: The gloves are stuck with tape and will inevitably be torn.
We tried one glove brand after another, but it didn't work, but it couldn't convince OSHA that they couldn't all be defective.
We ended up solving the problem by changing labels for different brands.
After surviving the OSHA inspection, my institution painfully gained the wisdom that documents are everything.
All efforts related to equipment maintenance, staff training, Hazard Communication and infection control education must be carefully planned, written, implemented and documented.
Records of training at each stage must be submitted and updated annually.
Employees must sign and date all records.
The extra work and expenses are considerable but necessary.
Today, our lab provides a safer working environment for all employees than before.
Our duty and goal is to try to keep this up. woncondition. (1. )
Law enforcement procedures for occupational exposure to hepatitis B virus (HBV)
And human immune deficiency virus (HIV). Washington, D. C.
, OSHA guidance month CPL-2. 44A, Aug. 15, 1988. (2. )
Occupational exposure of blood-borne pathogens (
Regulations proposed by OSHA). Washington, D. C.
Federal Register, Volume 154, No.
Page 102, May 30, 1989. 23041-23139.
General references: Part 1900 Code of Federal Regulations No 29-1910. Washington,D. C. , U. S.
Office of Government print, 1988.
Rules and regulations.
Hepatitis B virus and human immune deficiency virus (HIV or AIDS);
Occupational exposure. Washington, D. C.
, Federal Register, Volume 1. 52, No. 233, Dec. 4, 1987, p. 45438 ff.