Ensuring Compliance

Navigating OSHA Standards, Preventing Incidents and Mitigating Risk Regulatory Requirements in Healthcare

• Sources and scopes of regulations • Background on OSHA standards • Regulatory areas in healthcare safety • Requirements of regulations • Components of individual regulations Sources and Scopes

• Occupational Safety and Health Administration (OSHA) regulations • 29 Code of Federal Regulations (CFR) 1910 • General Industry Standards • 29 Code of Federal Regulations (CFR) 1926 • Construction • Several national consensus standards are incorporated by reference • National Institute for Occupational Safety and Health (NIOSH) • American National Standards Institute (ANSI) Sources and Scopes (cont.)

• Horizontal Standards cover a program with a large scope that covers all in the organization • Example: Walking Surfaces • Vertical Standards cover a specific industry or workplace condition • Example: Respiratory Protection Sources and Scopes (cont.)

• Vertical Standards override Horizontal when they exist • Example: If the “horizontal” HR Dress Code says facial hair is acceptable but the “vertical” Respiratory Protection program requires employees to be clean-shaven in areas affecting the respirator, the “vertical” standard trumps the “horizontal” standard Background

• OSH Act – 1970 • OSHA formation – 1971 • General Duty Clause – even if no specific standard exists, a can be enforced if/when acknowledged by OSHA • Law = this is what to do • Standard = this is how to do it • “Shall” = no options in compliance • “Should” = seriously recommended • “May” = a good idea Background (cont.)

• Programs • An accumulation of elements in standards • Policies • Specific guidance • What’s going to be done • Why it’s being done • Who’s doing it • How it will be enforced • Procedures • Training documents • Work reference documents • Specific and detailed Background (cont.)

• The Three P’s are to be developed based on organizational: • • • • System Safety Processes • The Three P’s are the basis for complying with and exceeding minimal standards • Management and Workforce team cohesion is very necessary Regulatory Areas in Healthcare

• Bloodborne Pathogen Exposure Prevention • Hazard Communication / Hazardous Materials • Personal Protective Equipment (PPE) • Respiratory Protection • Eyewash Stations • Lock-Out/Tag-Out • Workplace Violence Prevention • Environmental Protection • *Not all inclusive Hierarchy of Controls

• While OSHA standards prescribe guidance for many workplace , there are several areas in which hazard control decisions are left to the employer • These decisions require guidance from the Hierarchy of Controls • • Hazard Substitution • • • PPE Blooodborne Pathogen Exposure Prevention

• Hazard analysis – who’s at risk? • BBP Exposure Prevention Plan • Hazard controls implemented (Hierarchy of Controls) • Housekeeping maintained to isolate and contain hazards • Vaccinations available to at-risk employees • Recordkeeping maintained as appropriate (including incident investigations (Sharps Log) Hazard Communication (HAZCOM) “Right to Know Act”

• Written Program • Chemical inventories for each department • Safety Data Sheets (SDS) for each chemical • Global Harmonization System (GHS) labels for each unlabeled container • Training for all affected/at-risk employees Personal Protective Equipment (PPE)

• Hazard analysis – who’s at risk and for what? • PPE needs and gap analyses for each hazard • All affected employees trained on hazardous tasks and PPE needs/use • PPE in place for accessibility, availability and convenience Respiratory Protection Program

• Designation of Respiratory Protection Administrator • Written Program • Hazard Assessment • Medical Questionnaires • Education/Training • Fit Testing • Respirator Inventory/Use Eyewash Stations

• Chemical inventories for each department • Identification of all corrosive materials (via Safety Data Sheets) • Eyewash station within 10 seconds or 55 feet of chemical use point • Eyewash stations must be unobstructed • Eyewash must run continuously for 15 minutes • Eyewash must run tepid water (>60,<100 degrees F) Lock-Out Tag-Out (LOTO)

• All energy sources identified (electrical, mechanical, pneumatic, gravitational, and more) • All affected/authorized employees identified (*affected employees work with the equipment while authorized employees are able to lock out energy sources) • Procedures developed for isolation and de-energizing of all energy sources • All employees trained as appropriate (affected/authorized) • Locks, tags and procedures available for use at all times Workplace Violence Prevention

• Management commitment and employee involvement in zero-tolerance policy- making process • Worksite analysis completed for workplace violence risk factors • Hazard controls and preventative measures developed and implemented (as per Hierarchy of Controls) • Employees trained as necessary • Recordkeeping and after-action reporting maintained as necessary for real-world events and exercises Environmental Protection

• In addition to OSHA, the Environmental Protection Agency (EPA), the Texas Commission on Environmental Quality (TCEQ) and others have standards and regulations applicable to healthcare such as the Emergency Planning and Community Right to Know Act (EPCRA) • RCRA • CERCLA • and more Environmental Protection (cont.)

• Chemical inventories for all departments • Safety Data Sheets available to all chemicals • Chemical quantities and locations known and documented • Extremely Hazardous Substance (EHS) statuses known • Chemicals over EPA-defined Threshold Reporting Quantities (TPQ) are reported and chemicals over Threshold Planning Quantities (TPQ) have applicable response plans • For those chemicals above TRQ, Tier II Reports are developed and reported annually • Open containers (such as 55 gallon drums have applicable spill containment allowing for 110% containment of chemical quantity • Spill kits available and accessible for applicable chemical quantity • Spill response capabilities determined and employees trained and equipped as appropriate Disclaimer

• This presentation is NOT all-inclusive • General Duty Clause • Healthcare focus from OSHA • Changes in regulations • Ambiguous enforcement (ergonomics, workplace violence, etc.) Questions or Concerns?

• Cory Worden, Ph.D. ABD, M.S., CSHM, CSP, CHSP, ARM, REM, CESCO • 832 677 9821 • [email protected]