
OSHA
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
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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
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