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Bloodborne Pathogens Compliance Amber Hogan Industrial Hygienist OHCA, OSHA National Office.

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Presentation on theme: "Bloodborne Pathogens Compliance Amber Hogan Industrial Hygienist OHCA, OSHA National Office."— Presentation transcript:

1 Bloodborne Pathogens Compliance Amber Hogan Industrial Hygienist OHCA, OSHA National Office

2 Items Most Frequently Causing Sharp- Object Injuries Lancet Syringe Other needle Suture needle IV catheter stylet Scalpel blade Butterfly needle Phlebotomy needle Prefilled syringe Needle on IV line Glass item Blood gas syringe % of cases EPINet, 84 health care facilities, 1993-2000, cases=23,692 blood-filled needles* non blood-filled needles or solid-core devices (*24% of injuries involved blood-filled needles) Additional categories: Fingernails/teeth (1.2%) Fingernails/teeth (1.2%) Scissors (0.9%) Scissors (0.9%) Razors (0.6%) Razors (0.6%) Retractors, skin/bone hooks (0.5%) Retractors, skin/bone hooks (0.5%) Drill bit (0.3%) Drill bit (0.3%) Wire (0.3%) Wire (0.3%) Pin (0.3%) Pin (0.3%) Bovie electrocautery (0.3%) Bovie electrocautery (0.3%) Microtome blade (0.3%) Microtome blade (0.3%) Trocar (0.3%) Trocar (0.3%) Pickup/forceps/hemostats (0.3%) Pickup/forceps/hemostats (0.3%) Other sharp item (5.7%) Other sharp item (5.7%) International Health Care Worker Safety Center, Univ. of Virginia

3 Non- Sharp Exposures MOST EXPOSURES ARE FROM NON-SHARPS (Splashes and Splatters)! Touch unprotected skin 86% Touch skin through gap between protective garments 6% Soak through protective garment 3% Soak through clothing 6% EPINet 1999

4 Exposures: Job Categories Nurses40% MDs~20% Otherphlebotomists, housekeepers, students, etc.

5 Bloodborne Pathogens Standard * Needlestick Safety and Prevention Act Major Provisions by Paragraph (b)*Definitions (c)*Exposure Control Plan (ECP) (d)Engineering and Work Practice Controls - Personal Protective Equipment (PPE) (e)HIV and HBV Research Labs (f)Vaccination, Post-Exposure Follow-up (g)Labeling and Training (h)*Recordkeeping

6 Revisions to Standard Additional definitions, paragraph (b) –Needleless Systems, SESIPs New requirements in the Exposure Control Plan, paragraph (c) –Solicitation of input from non-managerial employees, paragraph (c) –Annual review of devices Sharps injury log, paragraph (h)

7 Contracts, contracts, contracts Contractors and Multi-Employer Worksites –Phlebotomy, Laundry, Nursing Services, Physicians, Administrative Staff Contracts with Personnel Services –Site-specific training, post-exposure follow-up, etc. Contracts with Residents –Engineering Controls (e.g., insulin syringes)

8 Multi-Employer Worksites Personnel Services Home Health MDs w/ Privilege Indepnt Contracts ExampleRNs, LPNs, NAs Hlthcare in Homes Orthopod, Plstic Surg Housekpg, Rad, Lndy ECP  EC & PPE +  (ADA v. Martin)  and/or + HBV, Trng , General , Specific 

9 Engineering and Work Practice Controls

10 Remember… Engineering AND Work Practice Controls –Use Safer Devices –Immediate Disposal Engineering Controls for all exposures –Sharps- Splatters –Splashes- Pools and Puddles

11 Safer Device Examples

12 More Examples…

13 Common Compliance Issues in Nursing and Personal Care Facilities

14 Insulin and Other Inject-ables Issues: –Daily injection of insulin or other meds –Residents supply syringes –CMMS reimbursement Bottom line: –OSHA requires employers to provide engineering controls Solution? –Contract agreement between home and resident

15 Old Supplies of Straight Syringes Employer… “Can I use up my old supply of regular syringes?” “Its okay if we just keep safer devices on the shelf incase an OSHA inspector comes.” OSHA… SESIPs must be evaluated, selected, AND implemented May still be need for regular syringes

16 Geriatrics as a Specialty Employer… Elderly are no/low risk for BBPs ___________________ Device negatively affects medical procedure OSHA… Eng Controls must be used to eliminate exposure to blood and OPIM ____________________ Positive defense

17 Blood Tube Holders Employer… “Reuse of tube holders saves money” OSHA… Each blood tube holder with needle attached must be immediately discarded into a sharps box after activation of its safety feature

18 Needle Destruction Devices ER must evaluate SESIPs Pros: Protects Downstream Cons: MUST be used in exact accordance with manufacturers instructions Not engineering control for “point of use”

19 HBV Vaccination and Titer HBV vaccination prior to placement Antibody test required –CDC…“all healthcare personnel who have contact with patients or blood and are at ongoing risk for percutaneous injuries should be tested 1-2 months…”

20 Post-Exposure Follow-up “As soon as possible” Site-specific location Appropriate clinical evaluation –Contaminated needle? –Source known? –Rapid HIV for source within 48 hours –Prophylaxis

21 Recordkeeping Reporting Injuries –Actual and Near Misses –Sharps Injury Log Recording Injuries –Sharps Injury Log and OSHA 300/301, etc. Using data as device surveillance

22 Other BBP Compliance Issues… QUESTIONS?

23 Occupational Exposure to Tuberculosis (TB)

24 Enforcement Procedures and Scheduling for Occupational Exposure to Tuberculosis, OSHA Instruction CPL 2.106 Issued February 9, 1996 Provides uniform inspection procedures Guidance on 5(a)(1) and pertinent standards

25 CPL 2.106, Applicability Scope of workplaces –Health Care Facilities –Correctional Institutions –Long-term Care Facilities for Elderly –Homeless Shelters –Drug Treatment Centers OSHA

26 “Minimal” Program TB control plan with certain minimal elements: –Action Plan For resident (e.g., isolation, transport) For employee (e.g., respirator) –Baseline skin test and medical history –Medical management where necessary –Employee training –Record keeping –Coordination with Public Health Agency

27 Inspection Procedures Trigger for Coverage: –CSHO to establish if facility has suspect or confirmed TB case w/in previous 6 months If so, review employer’s TB plan with Infection Control Director Verify implementation of plan through employee interviews, direct observation

28 Citation Policy If TB exposure, then employers must comply with: –5 (a)(1) – General Duty Clause –1910.139 - Respiratory Protection –1910.145 - Accident Prevention Signs and Tags –1910.1020 - Access to Employee Exposure and Medical Records –1904 - Recording and Reporting Occupational Injuries and Illnesses

29 5(a)(1) Documentation Must have: –Confirmed or suspected case, 6 months –Recognition of hazard Established by CDC for high hazard industries –Citations issued to: Higher incidence than general public Not provided appropriate protection/feasible abatement, AND Employee had exposure to TB (exhaled air, droplets

30 Recordability High-Risk Facility Employee is negative one year, positive the next Can not positively show that exposure was somewhere else

31 CSHO Protection Use professional judgment, extreme caution –Do not enter isolation area On rare occasions, if necessary, wear appropriate PPE –Negative pressure, elastomeric, HEPA Offered TB skin test

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