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OSHA INFORMATION

 
The number for TOSHA consultation:  1-800-325-9901
 
The five questions:
 
1.  What is universal precautions?
2.  What do you do when there is a blood spill?
     Personal protective equipment
     Cleanup and disposal procedures
     Disinfection (hazard communication applies)
3.  What do you do with contaminated sharps and laundry?
4.  Have you been offered the hepatitis B vaccination free of charge?
5.  Where is the Exposure Control Plan?
 
Link to article and exposure control plan for dentists on Tn Dental Assoc. website:
 
Link to OSHA/TOSHA requirements for dentists:
 
BELOW ARE:
      1. SHARPS INJURY TARGETING PROGRAM CHECKLIST
      2. SHARPS INJURY AND PREVENTION INFORMATION        



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SHARPS INJURY TARGETING PROGRAM CHECKLIST

 

PRE INSPECTION:

 

*  Review sharps  injury logs and note types of injuries and departments where injuries are occurring 

*  Review CPL-02-02-069.

 

 

OPENING CONFERENCE:

 

*  Ask for administrator-have administrator choose department heads to include

*  Cover opening conference guidelines

*  Give a copy of “Fact Sheet”

*  Obtain a copy of the Exposure Control Plan.  Make sure it has all the required sections:

*  Employee exposure determination

*  Annual reviews

*  Engineering controls and work practice controls in use and documentation for non-safer sharps

*  Safer medical devices evaluated and implemented…review list evaluated and in use…make sure it covers all devices

*  How front-line employees were solicited for evaluation of safer devices

*  Written cleaning schedule and method of decontamination

*  Procedures for making Hepatitis B vaccination available to employees

*  Follow-up Procedures to be followed if there is an exposure incident

*  Written opinions for each hepatitis vaccination and each exposure incident…review medical records

*  Procedure for evaluation of circumstances for each exposure incident and documentation of corrective action

*  Obtain a copy of the current sharps injury log...make sure format is correct

*  Ask where non-safer sharps are used

*  Get documentation for their use-make sure it covers all sharps used throughout the facility

*  Ask if any needle recapping, removing, etc. is done

*  Get description of technique used

*  Make sure device is furnished if needed

*  Make sure all recapping, removing, etc. is documented (why it’s justified) in Exposure Control Plan

*  Make sure employees are trained to use the devices properly…review training records

 

*  Verify that proper follow-up and testing was provided for all exposure incidents.  For each exposure incident:

*  How exposure occurred

*  Identity of source individual and their blood test results

*  Description of exposed employee’s duties relating to the incident

*  Route of exposure

*  How exposure occurred

*  Relevant medical records for employee including hepatitis B status

*  Evaluation of circumstances surrounding the incident and document corrective action taken

 

WALK AROUND:

 

*  Examine sharps in use in critical areas…look at sharps containers, decontamination procedures,  labeling

*  Examine sharps in storage in critical areas

*  Interview employees…ask 5 questions and determine if the employee is trained annually

 

CLOSING CONFERENCE:

 

*  Conduct closing conference

 

 

TYPES OF SHARPS AND ENGINEERING CONTROLS :                            See “Fact Sheet”

 

CITATION GUIDELINES:

 

(c)(1)(ii)(c)- Failure to include procedures for the evaluation of exposure incidents in the exposure control plan

 

(c)(1)(iv)- No review and update of the Exposure Control Plan, as necessary, to reflect changes in technology, such as the use of effective engineering controls, that can eliminate or  minimize exposures

 

(c)(1)(iv)(B) – Did not document annual consideration and implementation of safer medical devices

 

(c)(1)(v) – Exposure Control  Plan did not solicit and document front line employee input in the selection of sharps with engineered sharps injury protection.

 

(d)(2)(i) – Engineering and work practice controls were not used to eliminate or minimize employee exposure.

 

(d)(2)(ii) – The employer did not have a system for regular checking of the engineering controls to ensure that safer devices function effectively

 

(d)(2)(vii) – Removing, bending, shearing, or recapping needles

 

(d)(2)(vii)(A)-Bending, recapping or removal of contaminated sharp without demonstrating and documenting that no alternative is feasible or that it is required by a specific medical             procedure

(d)(2)(vii)(B)-Removing a needle or sharp (such as a scalpel blade) without using a one-handed technique

 

(d)(2)(viii)(A)-(D)-Inappropriate containers for contaminated reusable sharps

 

(d)(2)(x)-Food or drinks being kept in refrigerators, freezers, shelves, cabinets or on countertops or benchtops with blood or OPIM are present

 

(d)(4)(i)-Worksite not maintained in a clean and sanitary condition or did not determine and implement a written schedule for cleaning and disinfection

 

(d)(4)(ii)(E) –Reaching by hand into containers of contaminated reusable sharps

 

(d)(4)(iii)(A)(1)-Contaminated sharps not discarded immediately

 

(d)(4)(iii)(A)(2)(i)-Sharps containers not located as close as feasible to the immediate area where sharps are used

 

(d)(4)(iii)(A)(2)(ii)-Sharps containers not maintained upright  throughout use

 

(d)(4)(iii)(A)(2)(iii) – Sharps containers overfilled

 

(d)(4)(iii)(A)(3)(i)-Sharps containers not closed when moving

 

(d)(4)(iii)(A)(4)-Sharps containers opened or emptied

 

(f)(1)(i)-Hepatitis B vaccination not made available to employees with occupational exposure

 

(f)(2)(iv)-Employees who declined the Hepatitis vaccination did not sign a declination form

 

(f)(3)(v)-Post-exposure evaluation did not include counseling

 

(f)(3)(I)-Failure to conduct an evaluation of exposure incidents following procedures established in Exposure Control Plan

 

(f)(4)(ii)-Healthcare professional evaluating an employee after an exposure incident was not provided the required information

 

(f)(5)-Healthcare professional’s written opinion not obtained and provided to the employee within 15 days of post-exposure evaluation

 

(g)(2)(i)-Training for employees with occupational was not at no cost to the employee and/or during working hours

 

(g)(2)(ii)(A)-Initial training was not conducted at the time of assignment

 

(g)(2)(iv)-Annual training not provided within one year of the previous training

 

(g)(2)(vii)(F) –Training did not include the use and limitations of engineering controls. 

 

(1)(i) thru (iv) –Deficient medical records maintained

 

(2)(i)(A-D)-Training records did not include date conducted, qualifications of the trainer, summary of training session and name and job title of attendees

 

 (5) – Sharps log did not have all required information.  (all sharps injuries must be logged even for employees of other employers working on site)

 

0800-1-10-.04(1)-Type and brand of device in use not documented within 6 days for every exposure incident

 

0800-1-10-.04(2)-Sharps with engineered protection evaluated and in use not documented

 

0800-1-3-.27(b) –Failure to remove names from privacy cases on injury and illness logs

 

All violations of the Bloodborne Pathogens Standard will normally be classified as serious (except for recordkeeping violations).
 


2.
 
SHARPS INJURY PREVENTION

                                                      LIST and INFORMATION  (September 2010)

 

                               

In all workplaces where employees are exposed to contaminated needles or other contaminated sharps, the employer shall comply with 29CFR 1910.1030, Tennessee Code Annotated 50-3-203(e)(1)-(e)(4) and Tennessee Rule 0800-1-10 as follows:

           

v  Evaluate available engineered sharps injury prevention devices for all sharps 

 

v  Solicit input from employees directly involved in patient care in the evaluation and selection of devices and document this in the Exposure Control Plan

 

v  Select the devices most appropriate to your procedures

 

v  Train  employees to use the devices,

 

v  Require use of the safer devices and use of safer work practices when handling and passing contaminated sharps

 

v  Update the Exposure Control Plan at least annually or when needed to document the devices evaluated and those placed into use  

 

v  Justify the use of any sharps without sharps injury protection & document in the Exposure Control Plan

 

v  Maintain a Sharps Injury Log with:

v  Type and brand of device involved in the exposure incident

v  Department or work area of occurrence

v  Explanation of how it occurred

 

The list below is to assist employers in complying with changes in Tennessee Code Annotated Section 50-3-203  (Senate Bill 1023/House Bill 634).   Inclusion of types of devices does not represent or imply any evaluation, endorsement, or approval by The Tennessee Department of Labor and Workforce Development, the Tennessee Department of Health, or any other agency.  This list is not all inclusive.

                                               

Types of Devices and Engineering Controls

 

Injection Equipment

Hypodermic needles and syringes- sliding sheath/sleeve, needle guards

Needleless jet injection

Retractable needles

Medication Vial Adaptors   (used to access ports of medication vials)

IV Medication Delivery Systems

                Needle guards for pre-filled medication cartridges

Needleless IV access-blunted cannulas

Needleless valve/access ports and connectors

Prefilled medication cartridge with safety needles

Recessed/protected needle

Needle guards for pre-filled medication cartridges

IV Insertion Devices

Shielded or retracting peripheral IV catheters

Shielded midline IV catheters                                                                                        

IV Catheter Securement Devices

Epidural/Spinal Needles                                                                                  

Blood Collection Devices

                Arterial blood gas syringes

                Phlebotomy needles
                Safety-engineered blood collection needles
                Blood tube holders
                Closed venous sampling systems
                Plastic blood collection tubes        

Butterfly blood collection needles

Blood Donor Plebotomy Devices

Other Catheter Equipment

                Guidewire Introducers-for venous and arterial access

                Central Venous Catheters

                Peripheral Inserted Central Catheters

                Radial Artery Catheters

Umbilical cord sampling devices

Lancets

Laser lancet

Retracting Lancet

Strip Lancet                                                                                        

Laboratory Devices

Hemoglobin reader                                                                                   

Mylar-wrapped glass capillary tubes                                       

Plastic capillary tubes                                                                                                                                     

Protected needles for blood culture vial access

Vacuum tube stopper

Plastic fingerstick sampling blood collection tube

Slide preparation devices

Surgical Devices

Scalpels (disposable safety, retracting, shielded)

Ultrasonic scalpel

Blunted Suture Needles (for internal suturing- fascia/muscles)

Surgical Glues & Adhesives

Alternative Skin Closure Devices

Surgical Sharps Protection and Other Surgical Sharps Protection

Hands free transfer disposable magnetic drapes

Sharps counting and disposal system

Magnetic floor sweep

Scalpel blade removal system

Hemodialysis and Apheresis Devices

Fluid Sampling Devices

Sharps Disposal or Destruction Containers

Irrigation Splash Shield (Eliminates use of needles in debridement procedures)

Blood Bank Devices

                Segment sampling devices

Nuclear Medicine Devices

Cut or puncture-resistant barrier products (gloves, liners or pads)

Huber Needle and related devices

Smallpox Vaccination Needles

Vaginal Retractors

Surgical Prep Razors

Bone Marrow Collection Systems

Dental Safety Devices                                                       

 

 

To access fact sheet online:  www.state.tn.us/labor-wfd/sharpslist.pdf

 

 Page 2

 

 

 

The next list below contains web site resources that can be used for the purposes of information and research.  The examples of effective engineering controls in this list do not include all those on the market, but are simply representative of the devices available.    Neither the Tennessee Department of Labor and Workforce Development nor the Tennessee Department of Health approve, endorse, register or certify any medical devices.  Inclusion on this list does not indicate approval, endorsement, registration or certification. 

                                                                                                                                                               

 

International Health Care Worker Safety Center, University of Virginia:

Available:   Features a list of safety devices with manufacturers and specific product names:http://www.healthsystem.virginia.edu/internet/epinet/safetydevicenew.cfm  and Safety in Surgery : http://healthsystem.virginia.edu/internet/safetycenter/internetsafetycenterwebpages/SafetyinSurgery/SafetyinSurgery.cfm

 

International Sharps Injury Prevention Society:

Available:       http://www.isips.org/

ISIPS is an international group of medical device and pharmaceutical manufacturers, health organizations, healthcare professionals, medical waste disposal experts and others that are joining forces to provide education, information, and product knowledge that will help reduce the number of sharps injuries that occur each year.  This website features a list of safety product categories with a description of the category and a list of safety products that fit under that category : http://www.isips.org/safetyproductlist.php

 

 

Food and Drug Administration (FDA) Safety Alert: Needlestick and Other Risks from Hypodermic Needles on Secondary IV Administration Sets - Piggyback and Intermittent IV:
http://www.osha.gov/SLTC/bloodbornepathogens/fdaletter.html

Warns of the risk of needlestick injuries from the use of hypodermic needles as a connection between two pieces of intravenous (IV) equipment. Describes characteristics of devices which have the potential to decrease the risk.                                                                                                                                                                                                                         

Occupational Safety and Health Administration (OSHA) Glass Capillary Tubes: Joint Safety Advisory About Potential Risks :
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=22695

Describes safer alternatives to conventional glass capillary tubes.

 

Occupational Safety and Health Administration (OSHA) Needlestick Injuries
Available:               
http://www.osha.gov/SLTC/bloodbornepathogens/index.html

Features recent news, recognition, evaluation, controls, compliance, and links to information on effective engineering controls.

 

Selecting Evaluating and Using Sharps Disposal Containers: This document presents a comprehensive framework for selecting sharps disposal containers and evaluating their efficacy as part of an overall needlestick injury prevention plan:         http://www.cdc.gov/niosh/sharps1.html

 

Training for Development of Innovative Control Technologies (TDICT) Project
Available:           
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=2570

TDICT "Safety Feature Evaluation Forms" in Appendix B of this directive.


OSHA Instruction CPL 2-2.69Enforcement procedures for the Occupational Exposure to Bloodborne Pathogens

Available: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=2570

Instruction that establishes policies and provides clarification to ensure uniform inspection procedures are followed when conducting inspections to enforce the Occupational Exposure to Bloodborne Pathogens Standard (29 CFR 1910.1030).    


Service Employees International Union (SEIU) Guide List

Available:            http://www.seiu.org                                                                            Page 3