OSHA's top citation: No exposure control plan

Hospital must update plan annually

Failing to keep your exposure control plan up to date could lead to a citation from the U.S. Occupational Safety and Health Administration.

Last year, hospitals were most likely to be cited for not having a written exposure control plan or for failing to document consideration of new devices, according to OSHA data. The Bloodborne Pathogen Standard also was the most commonly cited standard in inspections of hospitals.

"Once you have a plan and you have devices, your job isn't complete. You have to be diligent in looking at newer devices each year to see whether you need any updates in your [exposure control] plan," says Dionne Williams, MPH, a senior industrial hygienist at OSHA. "Staying on top of the program is going to be the key to protecting workers," she says.

You can ask your supplier if there are any new devices with better safety features, Williams advises. The International Healthcare Worker Safety Center at the University of Virginia in Charlottesville maintains a list of safety devices at www.healthsystem.virginia.edu/pub/epinet/new/safetydevicenew.html. A list of devices is also available from Sustainable Hospitals at sustainablehospitals.org/cgi-bin/DB_Index.cgi

If employees fail to activate safety devices, the problem might lie with the device. Using a device that automatically engages the safety feature may address that issue, Williams says.

OSHA does not require employers to purchase more recent devices, only to evaluate them. But if an inspector observes inactivated devices in sharps containers, that might prompt a closer look at the exposure control plan, Williams says.

Sometimes, the problem lies with the training. The hospital is responsible for making sure agency nurses and other contract workers with potential exposure receive training, she says. Physicians also need to be included in annual training, she says.

"Even though they may have very in-depth knowledge about health care and diseases, they still need training on bloodborne pathogens. They still need to know what the facility's procedures are, and training on the devices," Williams says.

Training is required if the hospital adds new procedures that pose a bloodborne pathogen hazard or if new devices are introduced. But even when there are no changes, the training helps keep employees aware of the risks, she says. "Employees themselves can get into a routine, which is why we have the requirement to have annual training," she says.

A dubious Top 10

The most common sections of the Bloodborne Pathogen Standard cited by OSHA were:

1. 1030(c)(1)(i) Failure to have a written exposure control plan.

2. 1030(c)(1)(iv) Failure to update the exposure control plan annually, reflecting new tasks or procedures.

3. 1030(g)(2)(i) Failure to provide training to employees with occupational exposure.

4. 1030(d)(2)(i) Failure to use safety engineered devices or work practice controls to reduce risk

5. 1030(f)(2)(i) Failure to offer the hepatitis B vaccine to employees with potential exposure.

6. 1030(h)(5)(i) Failure to maintain a sharps injury log.

7. 1030(f)(2)(iv) Failure to obtain a signed declination for employees who decline hepatitis B vaccine.

8. 1030(c)(1)(v) Failure to solicit input of frontline health care workers in the selection of sharps devices.

9. 1030(c)(1)(iv)(B) Failure to annually consider new sharps safety devices.

10. 1030(f)(1)(i) Failure to provide post-exposure vaccination and follow-up for hepatitis B.