The topic of eyewash stations comes up a lot.

In general, OSHA requires eyewash stations in locations in which there is a risk of accidental exposure to corrosive or caustic materials.

There are definitely specific environments—including the food services, boiler rooms, high-level disinfection—where I would be looking for eyewash stations, but only after looking at the chemicals involved.

The need to have an eyewash station in close proximity can be ascertained by looking at the chemical's first aid instructions, either on the container or on the MSDS. If the first aid information indicates that an exposure to the eyes requires flushing for 15 or more minutes, then you need to have an eyewash station.

If the first aid instructions do not indicate a 15-minute or longer flush after exposure, then you do not "need" to have an eyewash station--though nothing’s stopping you from installing one.

By the way, those lovely little wall-mounted plastic bottles do not meet the standard for emergency eyewash as would be required for conditions noted above.

I've been working on my slide presentations for the Second Annual Hospital Safety Symposium, so our upcoming show has been on my mind.

I hope to see many of you at the symposium, which will return to Las Vegas on May 8-9. During my sessions, I'll be discussing risk assessments, clarifying EC survey citations, and what's on the horizon for the EC standards in 2009.

You can click this link for our full agenda and registration info.

Now that OSHA can enforce annual fit-testing provisions for TB respirators, there’s been a lot of talk about increased use of PAPRs, which don’t require fit-testing because of their design. 

But here’s one disadvantage of PAPRs: From a sensitivity to patients standpoint, I think in an emergency, "hooding up" to deal with patients might fly for a bit, but I think ultimately the "comfort level" for patients in isolation will be strained if there's too much care in the hood.

Imagine if you’re a patient and every time the nurses come in, they have full hoods on—it’s not a cozy image.

Have you considered a more pervasive use of PAPRs to ensure appropriate levels of protection?

Hi everyone, it's Scott Wallask at HCPro checking in.

I've got a quick question: We got a comment posted to Steve Mac's item about TB fit-testing last week, and the comment from our end appears to be plagued by a software bug. We can't tell who it was who posted the comment.

If you posted to the blog about the TB fit-testing requirement, could you email me privately?

It's a problem more on our end, we're not trying to bust anyone's chops.

Thanks,

Scott W.

swallask@hcpro.com

So I see that OSHA--thanks to President Bush signing off on the federal budget--now has the ability to enforce its annual fit-testing requirements for tuberculosis (TB).

This one is going to have some hidden costs. The fact of the matter is, compliance even with initial fit-testing is certainly (based on my observations) inconsistent at best, so some folks are going to have to come at annual fit-testing basically from ground zero.

At any rate, it seems to me that somewhere in the regulatory language (maybe in the post-TB standard stuff) there was some sort of cost estimate that was fairly minimal. And, as I think about it, this isn't even getting into the issue of fit-testing staff members who are going to be using PAPRs in the event of a decon event.

It'll be interesting to see if OSHA actually goes after this with any gusto--could get ugly.

What do you think? Is this a big deal? You can click on the comment links below to post your thoughts.

Hi everyone, it's Scott Wallask checking in from HCPro.

It appears the dissolution of the annual tuberculosis fit-testing prohibition is now official, as President Bush signed the fiscal year 2008 budget for labor and health and human services in late December. A record of the bill--numbered H.R. 2764--indicates it is now public law.

OSHA's budget falls under this bill. In prior years, it was within this area of the budget that you'd find the prohibition of OSHA enforcing annual TB fit-testing. But that prohibition isn't in the current budget's wording, which brings to an end a several-year ban on such fit-tests.

Let us know what you think by clicking the comments link below.

Thanks,

Scott Wallask

swallask@hcpro.com

Hi everyone –

It's Scott Wallask checking in. I saw a posting on the listserv run by the Association for Professionals in Infection Control and Epidemiology, in which someone was kind enough to post a link to OSHA's 2006 informal opinion about Crocs in healthcare settings.

As many of you know, few fashion concerns bring up a good ol' fashioned debate as well as Crocs do. I actually saw a Crocs store in downtown Boston a few weekends ago.

Anyway, the OSHA posting isn't official, nor is it a letter of interpretation, so take it for what it's worth.

Happy holidays,

Scott W.

swallask@hcpro.com

Our colleague David LaHoda was good enough to point out on Tuesday afternoon an AHA News Now report that indicated President Bush had vetoed a fiscal year 2008 budget for labor and health and human services.

It's within this proposed budget that the OSHA annual fit-testing provision for tuberculosis exposure resides. As it stands now, the proposal would allow OSHA to enforce annual respirator fit-testing for TB, which Congress has disallowed for several years.

The veto probably just delays the inevitable when it comes to fit-testing, but for now, OSHA still can’t enforce annual fit-tests for TB respirators.

Thanks,

Scott Wallask

swallask@hcpro.com

I’m sure many of you are watching, with various degrees of trepidation, the pending federal budget that, among other things, will once again let loose the hounds of the Occupational Safety and Health Administration in pursuit of fresh fines. I’m talking about Congress letting OSHA enforce annual tuberculosis fit-testing for respirators.

We could probably spend a good long time (and mayhap one day we will) discussing the efficacy of the practical application of the respiratory protection standard (CFR 1910.134) as a function of managing occupational exposures to TB, or indeed whether there was a significant shortcoming in the nondevelopment of a TB standard for healthcare workers. That said, it appears that enforcement of annual TB fit-testing is going to become a way of life for hospitals.

Hopefully—and you definitely want to do a little assessment here to make sure—you have your new hire process under control from a fit-testing perspective (though I do know of more than a few organizations that are a little soft in this area). Clearly starting at the front end of the process is the way to establish a solid foundation for your program.

Ideally, you will be able use the practical experience from the new hire process to identify an appropriate level of resources for expanding the respiratory protection program to include annual TB fit-testing and all its component pieces (medical evaluations, pulmonary function tests, and the like).

I’m guessing that there aren’t many of you out there with sufficient existing resources to carry this off (if you do—good for you!). It is more than likely that in the near future, you will have to submit some sort of business plan to your organization’s leaders in order to obtain those additional resources, including a fairly well-detailed accounting of the process (this is likely going to be a shared responsibility within the organization, but, make no mistake, this is the organization’s responsibility).

My best advice would be to get a group together, flowchart the process, determine a per-unit expense, and get that request to your organization’s leaders before the compliance canines beset your house.

Hi everyone --

It's Scott Wallask up at HCPro. Just an FYI, an OSHA spokesperson confirmed for me today that the agency has not started inspecting for annual fit-testing for tuberculosis (TB), despite what you might have read elsewhere.

OSHA, like all of us, is awaiting final approval of the funding budget for fiscal year 2008. When that happens, it is almost certain that the annual TB fit-testing enforcement will be in effect.

Since 2004, Congress has prohibited OSHA from using budget funds to enforce annual fit-testing provisions for TB, which falls under the respiratory protection standard. But politics and that fellow who snuck back into the country with TB in May shifted the landscape.

Scott W.

swallask@hcpro.com

Hi everyone –

It’s Scott Wallask over here at the Hospital Safety Center with a quick note.

There’s been a lot of reports swirling around about annual fit-testing requirements for tuberculosis (TB) in hospitals.

In 2004 as part of OSHA’s budget approval, Congress prohibited the agency from using those funds to enforce fit-testing provisions for TB, which falls under the respiratory protection standard. That prohibition has continued for the past several years.

While it seems likely that the fit-testing ban for TB will end with the fiscal year 2008 budget, it is not official quite yet.

FY 08 technically started today, but at this point, the full Congress has not passed various appropriations bills to send the funding along, Dan Glucksman, a spokesperson for the International Safety Equipment Association in Arlington, VA, told to me this afternoon. The American Hospital Association reported about this aspect as well last week.

So, reports that mandatory annual fit-testing for TB begins today may be a bit premature.

I’m waiting to hear back from OSHA about this whole issue. When I do, I’ll let you know.

Thanks,

Scott W.

swallask@hcpro.com

In past discussions relative to risk assessments, I feel like I've given short shrift to an important part of the process: closing the loop and making sure it stays closed.

In many cases, it's not merely enough to have conducted a risk assessment (EC.1.10, EP #4); there is also an expectation that the interventions you identify to manage the risks "...achieve the lowest potential adverse impact on the safety and health..." (EC.1.10, EP #5).

And, at least as far as the scientific method is concerned, the only way you can be sure that you've achieved that goal is to collect and analyze performance data relative to the intervention.

For instance, there are a number of ways that you can provide your staff members with access to material safety data sheets. Sometimes it seems like new technologies emerge every day in this realm. Be that as it may, OSHA's hazard communication standard, like many of the risk management concerns you're likely to face, is primarily a performance-based undertaking. OSHA doesn't necessarily tell you how to do it, beyond the goal of ensuring access (see these interpretations of the hazcom standard, 1910.1200).

So long as you can demonstrably meet the requirement of ensuring access, from a compliance standpoint you should be in good shape. That said, I'm sure you have processes in place that can also help you comply with the hazcom standard, such as:

• Hazard surveillance rounds
• Spot-checking during fire drills
• Annual evaluations of the hazardous materials and waste management program

Thus, these activities become the source of data in support of, or in opposition to, your organization's compliance.

But wait-we're not done spinning this one . . .

There’s been a fair amount of media coverage relative to workplace violence in general and healthcare in particular. As safety professionals, we clearly have an obligation to enact whatever prudent measures are necessary to appropriately manage the risks associated with potential for violence in our workplaces.

Since we’ve already talked a bit about risk assessments in general (and by the way, there’s a pretty good assessment form regarding violence and aggression available here), I want to talk a little bit about one of the interventions that seems to be gaining a bit of popularity—the use of armed security officers.

Somehow in the midst of all my work-related activities, I managed to miss the event in Houston in April in which a father was Tasered by a hospital security officer while holding a newborn (use this link to check out the latest on the story, including video footage of the discharge of the Taser).

Even before I saw the footage, I have to admit that I was rather horrified at the description of the event. From a risk management and general liability standpoint, I’m just not keen on aggressively pursuing someone holding an infant (though it appears there was some indication that the father in this case was attempting to leave with the infant in some sort of custody dispute).

I’m seeing the use of armed security officers in hospitals much more frequently, and I am always curious about how well-defined the rules of engagement might be, whether they include the use of lethal force, what education has been provided, how are competencies assessed, etc.

Now you might want to call me a yellow-bellied, Massachusetts liberal type, but I’m really curious about how folks feel about this particular event. Clearly, there are opinions to be had by a great many people, some of whom will probably be involved in the pending lawsuit, but purely as a function of process, what’s up here?

If you were to use this case as a training example, how would you characterize this officer’s actions as a learning experience? Are their improvement opportunities to be had and, if so, what are they? I can’t help but think that The Joint Commission might have similar questions to ask the folks at the Houston hospital in question. If you were in a surveyor’s shoes, what would you say?