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    o hat does OSHA mean !y the term 2regulated 'aste23

    Management of Sharps

    o Ho' should sharps containers !e handled3

    o here should sharps containers !e located3

    o hat type of container should !e purchased to dispose of sharps3

    Disposal of Regulated Waste

    o Ho' do I dispose of regulated 'aste3

    Communication of Hazard to mplo!ees

    o hen are la!els re*uired3

    o hat are the re*uired colors for the la!els3

    o an there !e su!stitutes for the la!els3

    o hat are the exceptions to the la!eling re*uirement3

    o 4oes OSHA accept 4epartment of $ransportation5s (4O$) la!els for 'aste and

    specimens 'hich 'ill !e shipped or transported3

    "raining

    http://www.envcap.org/rmw/osha-bps.cfm#sharpshttp://www.envcap.org/rmw/osha-bps.cfm#disphttp://www.envcap.org/rmw/osha-bps.cfm#commhttp://www.envcap.org/rmw/osha-bps.cfm#trainhttp://www.envcap.org/rmw/osha-bps.cfm#sharpshttp://www.envcap.org/rmw/osha-bps.cfm#disphttp://www.envcap.org/rmw/osha-bps.cfm#commhttp://www.envcap.org/rmw/osha-bps.cfm#train
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    o hich employees must !e trained3

    o Should part6time and temporary employees !e trained3

    o ho has the responsi!ility for training 'orers employed !y agencies 'hich

    pro+ide personnel (e#g#, nurses) to other employers3

    o hat are the *ualifications that a person must possess in order to conduct

    employee training regarding !lood!orne pathogens3

    o here could information !e o!tained for conducting training on the

    lood!orne "athogens Standard3

    o ho are some examples of persons 'ho could conduct training on the

    !lood!orne standard3

    OSHA State "ool

    Definitions

    What is an #posure Control Plan$

    $he exposure control plan is the employer5s 'ritten program that outlines the protecti+emeasures an employer 'ill tae to eliminate or minimi7e employee exposure to !lood andO"I0#

    $he exposure control plan must contain at a minimum8

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    an exposure determination 'hich identifies o! classifications and, in some cases,

    tass and procedures 'here there is occupational exposure to !lood and O"I0:

    procedures for e+aluating the circumstances surrounding an exposure incident: and

    a schedule of ho' and 'hen other pro+isions of the standard 'ill !e implemented,

    including methods of compliance, communication of ha7ards to employees, andrecordeeping#

    What does OSHA mean b! the term %regulated &aste%$$he lood!orne "athogens Standard uses the term, 2regulated 'aste,2 to refer to the

    follo'ing categories of 'aste8

    li*uid or semi6li*uid !lood or other potentially infectious materials (O"I0):

    items contaminated 'ith !lood or O"I0 and 'hich 'ould release these su!stances

    in a li*uid or semi6li*uid state if compressed:

    items that are caed 'ith dried !lood or O"I0 and are capa!le of releasing these

    materials during handling:

    contaminated sharps: and

    pathological and micro!iological 'astes containing !lood or O"I0#

    It is the employer5s responsi!ility to determine the existence of regulated 'aste# $hisdetermination should not !ased on actual +olume of !lood, !ut rather on the potential torelease !lood, (e#g#, 'hen compacted in the 'aste container)# If an OSHA inspector

    determines that sufficient e+idence of regulated 'aste exists, either through o!ser+ation,

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    (e#g#, a pool of li*uid in the !ottom of a container, dried !lood flaing off duringhandling), or !ased on employee inter+ie's, citations may !e issued#

    OSHA has pro+ided some additional guidance for the determination of regulated 'aste#OSHA stated that !andages 'hich are not saturated to the point of releasing !lood orO"I0 if compressed 'ould not !e considered as regulated 'aste# Similarly, discardedfeminine hygiene products do not normally meet the criteria for regulated 'aste asdefined !y the standard# eyond these guidelines, it is the employer5s responsi!ility todetermine the existence of regulated 'aste#

    A; $O $O"

    Management of Sharps

    Ho& should sharps containers be handled$Each sharps container must either !e la!eled 'ith the uni+ersal !ioha7ard sym!ol andthe 'ord 2!ioha7ard2 or !e color6coded red# Sharps containers must !e maintained

    upright throughout use, replaced routinely, and not !e allo'ed to o+erfill# Also, thecontainers must !e8

    losed immediately prior to remo+al or replacement to pre+ent spillage orprotrusion of contents during handling, storage, transport, or shipping:

    "laced in a secondary container if leaage is possi!le# $he second container must

    !e8

    o losa!le:

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    o onstructed to contain all contents and pre+ent leaage during handling,

    storage, transport, or shipping: and

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    In addition to state rules for disposing of regulated 'aste, there are !asic OSHAre*uirements that protect 'orers# $he OSHA rules state that regulated 'aste must !eplaced in containers 'hich are8

    losa!le:

    onstructed to contain all contents and pre+ent leaage of fluids during handling,

    storage, transport or shipping:

    containers of contaminated laundry, on refrigerators and free7ers that are used to

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    store !lood or O"I0, and on !ags>containers used to store, dispose of, transport, or ship!lood or O"I0 (e#g#, specimen containers)# In addition, contaminated e*uipment 'hichis to !e ser+iced or shipped must ha+e a readily o!ser+a!le la!el attached 'hich containsthe !ioha7ard sym!ol and the 'ord 2!ioha7ard2 along 'ith a statement relating 'hichportions of the e*uipment remain contaminated

    What are the re(uired colors for the labels$$he !acground must !e fluorescent orange or orange6red or predominantly so, 'ithsym!ols and lettering in a contrasting color# $he la!el must !e either an integral part ofthe container or affixed as close as feasi!le to the container !y a string, 'ire, adhesi+e,

    or other method to pre+ent its loss or unintentional remo+al#

    Can there be substitutes for the labels$@es# /ed !ags or red containers may !e su!stituted for the !ioha7ard la!els#

    What are the e#ceptions to the labeling re(uirement$

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    $he la!eling re*uirements do not preempt either the =#S# "ostal Ser+ice la!elingre*uirements (9 / "art III) or the 4epartment of $ransportation5s Ha7ardous0aterials /egulations (F9 / "arts 1G1611)#

    4O$ la!eling is re*uired on some transport containers (i#e#, those containing 2no'ninfectious su!stances2)# It is not re*uired on all containers for 'hich C9 / 191D#1DDre*uires the !ioha7ard la!el# here there is an o+erlap !et'een the OSHA6mandatedla!el and the 4O$6re*uired la!el, the 4O$ la!el 'ill !e considered accepta!le on theoutside of the transport container pro+ided the OSHA6mandated la!el appears on anyinternal containers 'hich may !e present# ontainers ser+ing as collection receptacles

    'ithin a facility must !ear the OSHA la!el since these are not co+ered !y the 4O$re*uirements#

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    "raining

    Which emplo!ees must be trained$All employees 'ith occupational exposure must recei+e initial and annual training#

    Should part.time and temporar! emplo!ees be trained$

    "art6time and temporary employees are co+ered and are also to !e trained on companytime#

    Who has the responsibilit! for training &or/ers emplo!ed b! agencies &hichpro0ide personnel ,e1g12 nurses- to other emplo!ers$

    OSHA considers personnel pro+iders, 'ho send their o'n employees to 'or at otherfacilities, to !e employers 'hose employees may !e exposed to ha7ards# Since personnelpro+iders maintain a continuing relationship 'ith their employees, !ut another employer

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    (your client) creates and controls the ha7ard, there is a shared responsi!ility for assuringthat your employees are protected from 'orplace ha7ards# $he client employer has theprimary responsi!ility for such protection, !ut the 2lessor employer2 lie'ise has a

    responsi!ility under the Occupational Safety and Health Act#

    In the context of OSHA5s standard on lood!orne "athogens, the personnel pro+ider'ould !e re*uired to pro+ide the general training outlined in the standard, the clientemployer 'ould !e responsi!le for pro+iding site6specific training#

    $he contract !et'een the personnel pro+ider and the client should clearly descri!e the

    training responsi!ilities of !oth parties in order to ensure that all training re*uirements ofthe standard are met#

    What are the (ualifications that a person must possess in order to conductemplo!ee training regarding bloodborne pathogens$$he person conducting the training is re*uired to !e no'ledgea!le in the su!ect matterco+ered !y the elements in the training program and !e familiar 'ith ho' the coursetopics apply to the 'orplace that the training 'ill address# $he trainer must demonstrateexpertise in the area of occupational ha7ards of !lood!orne pathogens#

    Where could information be obtained for conducting training on the BloodbornePathogens Standard$

    OSHA5s Office of Information and onsumer Affairs (OIA) has de+eloped !rochures,factsheets, and a +ideotape on the standard# Single copies of the !rochure and factsheetscan !e o!tained !y 'riting OSHA "u!lications, CDD onstitution A+enue, , /oom1D1, ashington, 4 CDC1D or !y calling (CDC) C1961F the +ideotape is a+aila!lethrough the ational Audio isual enter, and the num!er is (D1) G&619 Allinformation a+aila!le through OIA should !e used as a supplement to the employer5s

    training program# Other sources of information include local Area and /egional OSHAOffices# In addition, each /egional Office has a lood!orne "athogens oordinator 'ho

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    ans'ers compliance and related *uestions on the standard#

    Who are some e#amples of persons &ho could conduct training on the

    bloodborne standard$Examples of health care professionals include infection control practitioners, nursepractitioners, and registered nurses# on6health care professionals include industrialhygienists, epidemiologists or professional trainers, pro+ided that they can demonstratee+idence of speciali7ed training in the area of !lood!orne pathogens#

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    OSHA State "ool

    Occupational safety and health rules in the =#S# are mostly standardi7ed, !ecause8

    $he federal Occupational Health and Safety Administration (OSHA) operate the primaryo! safety and health program in t'enty6nine (C9) of the fifty states# $his includesconducting inspections and enforcing its standards#

    $'enty6one states (C1) operate their o'n o! safety and health programs (threeadditional states co+er only state and local go+ernment employees)# States 'ith

    appro+ed programs must set o! safety and health standards that are 2at least aseffecti+e as2 compara!le federal standards# In most cases, states adopt standardsidentical to federal ones#

    onsultation ser+ices are a+aila!le in e+ery state# In most cases, these are free and areconducted at your healthcare facility# $hese ser+ices help employers identify and correct'orplace ha7ards and can help you a+oid +iolations and penalties#

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    =se the OSHA State $oolfor more information on OSHA regulations and consultationprograms in your state#

    A; $O $O"

    http://www.hercenter.org/osha.htmlhttp://www.envcap.org/rmw/osha-bps.cfm#tophttp://www.hercenter.org/osha.htmlhttp://www.envcap.org/rmw/osha-bps.cfm#top