Top 10 list exposes facilities with no plans

OSHA citing for lack of planning, training

The failure to have an exposure control plan was a surprising No. 1 on a "top 10" list of violations of the Occupational Safety and Health Administration’s (OSHA) bloodborne pathogen standard, reports Katherine West, MSEd, CIC.

West, who deals frequently with OSHA compliance issues as a consultant with Infection Control/Emerging Concepts in Manassas, VA, gathered health care citation data from states with federal OSHA plans for the period from August 1998 through July 30, 2000.

The violations were for failure to comply with the OSHA bloodborne pathogens standard, which was issued in 1991 to protect health care workers from bloodborne infections. The total number of violations would be larger with inclusion of the 23 state-OSHA plans, which have to have standards at least as rigorous as federal OSHA. Citations for not having a written exposure control plan totaled 410 violations, including 267 that were considered serious and likely led to fines, West notes. (See list, p. 8.)

OSHA's Top 10 Citations
The following is a list of the Occupational Safety and Health Administration's (OSHA) citations to health care facilities in federal-OSHA states for failure to comply with the bloodborne pathogens standard. The citations were issued between August 1998 and July 30, 2000.
Issue	Total Number of Violations	Number of Serious Violations
No Written Exposure Control Plan	410	267
No Training Programs	273	211
No Hepatitis B Vaccine Program	271	220
Lack of Exposure Control Plan Review/Update	198	78
No Annual Training	111	53
No Hepatitis B Vaccine Declination Forms	109	36
No Implementation Guide in the Exposure Plan	102	49
No Sharps Containers	80	62
Lack of Engineering Controls	78	64
No Initial Training on Assignment	65	49

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"It is shocking that there are health care workplace settings that still do not have written exposure control plans," she says.

Moreover, those that do have plans are failing to review and update them, the list reveals. "If you add new positions in the workplace then you have to add [employees] as either at-risk or not-at-risk positions. If you change products or institute new procedures, you have to change your plan," West reminds. "I think what is happening is that people who do write a plan write a non-compliant plan, meaning they write a spit-back’ plan [saying] XYZ hospital will offer hepatitis B vaccine at no charge to all employees at a convenient time and place.’ That is not what OSHA wants. It wants all the specifics pertinent to that workplace. [The plan] is supposed to be more of a learning, reference tool for staff."

Another surprising finding is that 273 of the inspected facilities were cited for having no training programs. Three of the most frequent citations are related to training issues, West observes. There is a real need for infection control professionals to ensure training requirements are met.

"Many people are not meeting the requirements, as this shows, on doing the full-blown initial training that is required before staff are put in an at-risk position," West says. "The other thing is some have no training programs at all and no annual training. So there are three different things: no initial training on hire, no annual training, and then an all-encompassing one of no training of any kind in place, which is just really unbelievable. I also know that many places are doing their training solely by videotape or computer program, which is not acceptable to OSHA."

There were also 109 violations for failing to show implementation of the exposure control plan, which essentially means dating and recording when requirements and revisions were made. The lack of a hepatitis B virus vaccination program was third on the list, another surprising finding given that the success of such efforts in reducing HBV in workers has been lauded in recent years. In addition, some of those that have HBV programs are drawing OSHA citations for not compiling declination forms of workers who refuse the offer of free HBV vaccine. A red flag for OSHA inspectors also rises if the number of declination forms is inordinately high, suggesting workers have not been educated about the safety and efficacy of the vaccine, West says.

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