Bloodborne blues: Top 3 citations for doc offices

According to the national office of the Occupational Safety and Health Administration (OSHA), the three most frequently cited violations in physician offices in 2006 were key provisions of Standard 29 CFR 1910.1030 regulating occupational exposure to bloodborne pathogens. The top three citations for the bloodborne standard were for deficiencies in the office exposure control plan, employee training and use of engineering controls. To help physician practices meet these frequently cited standards, below are some key OSHA requirements in each area:

• Exposure control plan (ECP): The ECP is a key document to assist our firm in implementing and ensuring compliance with the standard, thereby protecting our employees. The ECP includes:

determination of employee exposure;

implementation of various methods of exposure control, including:

— universal precautions;

— engineering and work practice controls;

— personal protective equipment;

— housekeeping.

hepatitis B vaccination;

post-exposure evaluation and follow-up;

communication of hazards to employees and training;

record keeping;

procedures for evaluating circumstances surrounding an exposure incident.

• Training: Annual training for all employees shall be provided within one year of their previous training.

Employers shall provide additional training when changes such as modification of tasks or procedures or institution of new tasks or procedures affect the employee's occupational exposure. The additional training may be limited to addressing the new exposures created.

Material appropriate in content and vocabulary to educational level, literacy, and language of employees shall be used.

The training program shall contain, at a minimum, the following elements:

— an accessible copy of the regulatory text of this standard and an explanation of its contents;

— a general explanation of the epidemiology and symptoms of bloodborne diseases;

— an explanation of the modes of transmission of bloodborne pathogens;

— an explanation of the employer's exposure control plan and the means by which the employee can obtain a copy of the written plan;

— an explanation of the appropriate methods for recognizing tasks and other activities that may involve exposure to blood and other potentially infectious materials;

— an explanation of the use and limitations of methods that will prevent or reduce exposure, including appropriate engineering controls, work practices, and personal protective equipment;

— information on the types, proper use, location, removal, handling, decontamination, and disposal of personal protective equipment;

— an explanation of the basis for selection of personal protective equipment;

— information on the hepatitis B vaccine, including information on its efficacy, safety, method of administration, the benefits of being vaccinated, and that the vaccine and vaccination will be offered free of charge;

— information on the appropriate actions to take and persons to contact in an emergency involving blood or other potentially infectious materials;

— an explanation of the procedure to follow if an exposure incident occurs, including the method of reporting the incident and the medical follow-up that will be made available;

— information on the post-exposure evaluation and follow-up that the employer is required to provide for the employee following an exposure incident;

— an explanation of the signs and labels and/or color coding required (warning labels on containers of regulated waste, containers of blood, blood components or blood products or other potentially infectious materials, or contaminated equipment and for HIV and HBV research laboratories and production facilities);

— an opportunity for interactive questions and answers with the person conducting the training session.

The person conducting the training shall be knowledgeable in the subject matter covered by the elements contained in the training program as they relate to the workplace that the training will address.

• Engineering controls: Specific engineering controls and work practice controls used are listed in the ECP such as nonglass capillary tubes, and needleless systems.

Sharps disposal containers are inspected and maintained or replaced by an employee named in the ECP on a frequency listed in the ECP or whenever necessary to prevent overfilling.

The facility identifies the need for changes in engineering controls and work practices through review of OSHA records, employee interviews, committee activities, etc.

The facility evaluates new procedures and new products regularly by such processes as literature review and supplier information.

Both frontline workers and management officials are involved in this process in a manner documented in the ECP.