Responding to a reader's comment about eyewash station citations
I read a comment posted by one of you to a blog entry of mine a while back dealing with OSHA requirements for eyewash stations. The poster asked whether anyone else had ever been cited by The Joint Commission for not having eyewash units installed in locations where staff members could be exposed to bodily fluids.
This person’s organization received a supplemental recommendation several years ago for not providing eyewash units in all patient care areas. The given reference was OSHA’s bloodborne pathogens standard, which was an erroneous reference, the commenter said.
That's an interesting situation, to which my general response (or perhaps it’s really a specific response) is that I haven't run into anyone who's been cited for not having eyewash stations where there are blood and body fluid exposure risks.
However, I have seen folks getting cited for not inspecting eyewash stations according to their policy and for not having them in areas where there is a demonstrable risk of chemical exposures.
At any rate, if anyone out there does get cited for not having emergency eyewash stations in the event of blood and body fluid exposures, it would certainly be an opportunity to try out the post-survey clarification process.
The surveyors are not presumed to be infallible, nor should they be (they're only human). If there's a lack of understanding, either as a global concept or merely a function of how one operationalizes the results of risk assessments (did you really think that I would go on for this long without invoking the mighty risk assessment?), then it becomes our professional responsibility to point out that understanding gap to surveyors and Joint Commission powers that be.
By the way, thanks to the reader for posting his comment. Keep ‘em coming, this blog is for everyone.
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