OSHA HealthcareRelated Regulations
A practical and
understandable guide to the
OSHA standards that will
make your facility a safe
place to work.
OSHA’s Hospital eTool
The OSH Act of 1970 strives to “assure
safe and healthful working conditions”
for today’s workers, and mandates that
employers provide a safe work
environment for employees. Hospitals
and personal care facilities employ
approximately 1.6 million workers at
21,000 work sites. There are many
occupational health and safety hazards
throughout the hospital. This eTool
focuses on some of the hazards and
controls found in the hospital setting,
and describes standard requirements as
well as recommended safe work
practices for employee safety and
health.
OSHA’s Hospital
eTool
The OSHA Hospital e-Tool is a stand
alone, interactive, Web-based
training tool on occupational
safety and health topics. They
are highly illustrated and utilize
graphical menus as well as
expert system modules. These
modules enable the user to
answer questions and receive
reliable advice on how OSHA
regulations apply to their work
site. These e-Tools do not create
new OSHA requirements.
OSHA’s Hospital eTool
This eTool addresses the
following areas:
• Administration
• ICU
• Central Supply
• Laboratories
• Clinical Areas
• Dietary
• Emergency
• Engineering
• Heliport
• Housekeeping
• Laundry
• Laboratories
 Laundry
• Surgical Suite
 Healthcare
Wide Hazards
 Other
Healthcare
Wide
OSHA’s Hospital
eTool
Healthcare Wide Hazards
•
Bloodborne Pathogens
1. Exposure Control Plan
2. HIV, HBV, HCV
•
Electrical
•
Ergonomics
•
Fire Hazards
•
Hazardous Chemicals
•
Infection-MRSA, VRE, SARS, etc.
OSHA’s Hospital
eTool
Healthcare Wide Hazards (continued)
•Needlesticks
•Mercury Spills
•Slips/Trips/Falls
•Contaminated Work Environments
OSHA’s Hospital
eTool
Housekeeping/Utility Module
•Appropriate Disinfectants
•Contaminated Equipment
•Sharps and Containers
•Hazardous Chemicals
•Latex Allergy
•Slips/Trips/Falls
•Asbestos in Flooring
OSHA’s Hospital
eTool
Housekeeping and Asbestos:
All surfaces must be maintained as free as
possible of accumulations of waste containing
asbestos and/or asbestos dust. The preferred
methods of cleanup are wet cleaning and/or
vacuuming with HEPA filtered vacuuming
equipment.
Sanding of asbestos containing floors (Floor tiles
installed before 1980 most likely contain
asbestos) is prohibited. Low abrasion pads at
speeds lower than 300 rpm and wet methods
must be used. If floor has sufficient finish,
brushing or dry buffing is permissible. If workers
are required to buff or wax asbestos containing
resilient floors, building and facility owners must
identify the installed material and inform
employees and employers of outside contractors
doing such work.
OSHA’s Hospital
eTool
Floors-To Disinfect or Not to Disinfect…CDC says,
“Extraordinary cleaning and decontamination of floors
in healthcare settings is unwarranted. Studies have
demonstrated that disinfection of floors offers no
advantage over regular detergent/water cleaning and
has minimal or no impact on the occurrence of
healthcare-associated infections.
Additionally, newly cleaned floors become rapidly
recontaminated from airborne microorganisms and
those transferred from shoes, equipment wheels and
body substances. Nevertheless, healthcare
institutions may choose an EPA-registered
detergent/disinfectant for cleaning low-touch surfaces
(e.g., floors) in patient care areas because of the
difficulty that personnel may have in determining if a
spill contains blood or body fluids (requiring a
disinfection for cleanup) or when a multi-drug
resistant organism is likely to be in the environment.”
OSHA’s Hospital
eTool
OSHA's National Office sent a memorandum to
its field offices on November 1, 1996
regarding inquiries from companies who
manufactured and/or supplied product(s)
approved by the EPA as effective against
HBV and HIV. They inquired if the new EPA
registered products with the new EPA label
would be an "appropriate disinfectant"
under OSHA's Bloodborne Pathogen
Standard, 29 CFR 1910.1030. This memo
stated the products could be used under
limited conditions, specifically where HIV
and HBV were the only pathogens of
concern (for example, in a research setting).
Mr. Bach referred to this memorandum in
his article, "Disinfection Efficacy Against
Micobacterium tuberculosis and the OSHA
Bloodborne Pathogens Standard", in the
April 1999 issue of your Infection Control
Today magazine. Unfortunately, this
memorandum was superseded in 1997 and
no longer reflects OSHA's current policy on
the use of disinfectants with an EPAapproval against HBV/HIV.
OSHA’s Hospital
eTool
OSHA MEMORANDUM-CONTINUED
OSHA reconsidered the limitations in the
memorandum of November 1, 1996 and issued
a revision on February 28, 1997. We decided
that the policy requiring the use of EPAregistered tuberculocidal disinfectants and\or a
diluted bleach solution to decontaminate
contaminated work surfaces should be
expanded to include EPA-registered
disinfectants that are effective against both HIV
and HBV. OSHA's current policy is that EPAregistered disinfectants for HIV and HBV meet
the requirement in the bloodborne pathogen
standard and are "appropriate" disinfectants to
clean contaminated surfaces, provided such
surfaces have not become contaminated
with agent(s), volumes, or concentrations
of agent(s) for which higher level
disinfection is recommended.
OSHA Regulations
General Duty Clause Section
5(a)(1) of the OSH Act
requires that “Each
employer shall furnish to
each of his employees
employment and a place of
employment which are free
from recognized hazards
that are causing or are
likely to cause death or
serious physical harm to his
employees.”
OSHA
Regulations
General Duty Clause (continued)
Four elements are required for issuing General
Duty Clause violations:
1. The employer failed to keep the workplace
free of a hazard to which employees of that
employer were exposed.
2. The hazard was recognized.
3. The hazard was causing or was likely to
cause death or serious physical harm.
4. There was a feasible and useful method to
correct the hazard.
OSHA
Regulations
General Duty Clause (continued)
The General Duty Clause is used only where
there is no OSHA standard that applies to the
particular hazard involved.
Examples of Housekeeping-related workplace
hazards to which the General Duty Clause may
apply include:
•Aerosolizing disinfectants, bleach, or other
products which may cause shortness of breath
(acute) or respiratory illness (chronic).
•Housekeepers who wear exam gloves to do
routine chemical disinfection or surface
cleaning.
OSHA Regulations
The Exposure Control Plan shall contain at
least the following elements:
The exposure determination required by
paragraph
Regulated Waste means liquid or semiliquid blood or other potentially infectious
materials; contaminated items that would
release blood or other potentially infectious
materials in a liquid or semi-liquid state if
compressed; items that are caked with
dried blood or other potentially infectious
materials and are capable of releasing these
materials during handling; contaminated
sharps; and pathological and
microbiological wastes containing blood or
other potentially infectious materials.
OSHA
Regulations
The Exposure Control Plan shall be reviewed
and updated at least annually and whenever
necessary to reflect new or modified tasks
and procedures which affect occupational
exposure and to reflect new or revised
employee positions with occupational
exposure. The review and update of such
plans shall also:
Reflect changes in technology that eliminate
or reduce exposure to bloodborne pathogens;
and
Document annually consideration and
implementation of appropriate commercially
available and effective safer medical devices
designed to eliminate or minimize
occupational exposure.
OSHA
Regulations
Other Potentially Infectious Materials means
(1) The following human body fluids: semen,
vaginal secretions, cerebrospinal fluid,
synovial fluid, pleural fluid, pericardial fluid,
peritoneal fluid, amniotic fluid, saliva in
dental procedures, any body fluid that is
visibly contaminated with blood, and all body
fluids in situations where it is difficult or
impossible to differentiate between body
fluids; (2) Any unfixed tissue or organ (other
than intact skin) from a human (living or
dead); and (3) HIV-containing cell or tissue
cultures, organ cultures, and HIV- or HBVcontaining culture medium or other solutions;
and blood, organs, or other tissues from
experimental animals infected with HIV or
HBV.
Recommendations Regarding
the Spraying of Chemicals
It is recommended that chemical agents or
germicidal detergents not be used in a mist or
spray operation. Any chemical agent,if inhaled
over a long period of time, has the potential of
being detrimental to some individuals.
In general, the desired results can be achieved
by applying a stream of liquid to a mirror,
over-bed table, drinking fountains or similar
surfaces; or it can be applied in a stream to a
cleaning cloth which is then used to clean
these surfaces.
Spraying chemicals in the air has the potential
for down-side risk not only to the user of the
product but to patients who might have
breathing difficulties or other problems.
These products should not be aerosolized in a
healthcare environment. Some chemical
labels indicate that the product should not be
sprayed in a mist. Read your labels.
Recommendations for Utility Gloves In
Place of Exam Gloves
It is recommended that the manufacturer of
the glove worn by Housekeepers using
chemicals (especially disinfectants) be asked
to provide a letter to place in your file. This
letter should state that the glove will protect
the Housekeeper’s hands from chemicals for
up to 6 hours per day. If the manufacturer
won’t provide a letter to protect you, your
hospital and your workers, you need to find
one who will.
Consider using a Nitrile Utility Glove. Most
manufacturers will certify, in writing – No
absorption, No strikethrough for 6-8 hours.
Sell your staff that these gloves will provide
chemical protection and that failure to wear
them could lead to disciplinary action up to
and including discharge.