Buyer beware! ,,,,
,
,,
Eddie Hedrick, BS, MT(ASCP), ClC Columbia, Missouri
The new Occupational Safety and Health Administration (OSHA) blood-borne pathogens standard ~provides a perfect opportunity for the heakh care industry to witness the best and the worst of the free-enterprise system. The need for newer and safer types of personal protective equipment and engineering controls to protect those at risk for occupational exposure to blood and other potentially infectious materials has stimulated industry to develop these items. This response assists in providing increased safety for health care workers and patients. This represents the ideal situation, in which industry and the health care community work together to reach a common goal. In contrast, these new regulations also provide the occasion for "opportunists" to play on the fear of something new, fines; the federal government, bad publicity, and possible litigation, to sell misinformation, gadgets, and gimmicks. Since the release of the blood-borne pathogen standard, those responsible for implementing the standard have been inundated with brochures in the mail and sales representatives with videos, booklets, training materials, and personal protective equipment, all of which are declared to assist in complying with the OSHA regulation. M a n y w a r n that if you do not use a specific type of product, such as the one they are selling, you may be subjected to OSHA fines and other undesirable consequences. Internal company memos directing the sales force to "seize the moment" to sell the latest anti-AIDS gimmick have become all too common. Many of these companies are only interested in selling merchandise, not in providing the appropriate level of protection to those at risk. Others are sincere in their efforts, but are not totally familiar with the details of the final regulation. All too often they overemphasize or misrepresent the value or need for a specific product. Many continue to quote information from the May 30, 1989, proposed standard 2 which has been completely replaced with the final regulation. Mr. Hedrick is Advertising Editor for the JOURNALand manager, Infection Control/Staff Health Services, University Hospitals and Clinics, Columbia, Missouri.
17/45/38968
170
Additionally, during the past few months OSHA "experts" have appeared out of nowhere. Unfortunately, many of these experts are not well enough informed about the specifics of the regulation and so they too may promote misinformation. Because of all this misinformation and the confusion it creates, it is important for those responsible for implementing these regulations to take a step back and evaluate the situation in a commonsense manner. Obviously, many companies have or are in the process of developing a full range of legitimate products that will help employers to increase protection for workers at risk of occupational exposure. Many excellent programs and educational materials have also been developed by various organizations, such as the Association for Practitioners in Infection Control, the American Hospital Association, the American Medical Association, state hospital associations, and others. How can you tell which are good and which are not? The following suggestions may be helpful in selecting products, programs, and educational items to assist in your efforts to increase protection for health care workers at risk. SUGGESTIONS 1. OSHA approves of nothing!! Any product or program that claims to be "OSHA approved" should be approached with caution. OSHA disapproves of many things, but it does not endorse products, programs, or materials. When companies claim that their product will allow you to comply with the standard, you must evaluate it carefully to make sure all of the provisions are present and applicable to your environment. Do not take anyone else's word, it is your responsibility. 2. Beware of those who claim to be "experts" regarding the blood-borne pathogen standard. At this point in time there is no such thing; ask four OSHA inspectors how to interpret specific portions of the standard and you will get four different answers. Until the inspectors are properly trained to interpret the standard in a consistent and appropriate manner, interpretations will vary and confusion will result.
Volume 20 Number 4
Although frustrating, this problem should last only until.OSHA provides training to the inspectors. If you have specific questions regarding the standard, you can get the best answers by contacting the Regional Bloodborne Pathogen Director at your regional OSHA office or by contacting someone at the American Hospital Association. Obviously, others in your local area have become familiar with the document; you may wish to consult with them. The most important thing to remember is that because you are responsible for implementing the standard, you must become as familiar with the regulation as possible. This means that you should take the time to read the preamble, the regulation, a n d t h e compliance document! 3. Watch out for vendors selling these documents for $75 to $100. You can obtain the standard and the compliance document from the federal government for less than $5 by writing to your regional OSHA office or to the national office: The Occupational Safety and Health Administration OSHA Publications Room N-3101 Frances Perkins Bldg. 200 Constitution Ave. N.W. Washington, DC 20210 Telephone (202)523-9667 4. The final standard does n o t require personal protective equipment to be "fluid proof, . . . . fluid resistant," or "impervious." The employer has flexibility in choosing the type of personal protective clothing a n d its specific characteristic or protective capabilities. This decision should be based on the task being performed
Buyer beware/
17t
and the degree of exposure that is reasonably anticipated. A cotton lab coat is thus perfectly acceptable when the amount of blood exposure anticipated is small, but if the degree of exposure would allow the blood to soak through to the employee's clothing or skin, a more efficient barrier must be provided. Protective clothing can be reusable or disposable and can be made from a broad range of materials, with varying degrees of resistance to liquid penetration. The key to this part of the standard is that whatever material is selected must not allow blood or other potentially infectious materials to penetrate through to the clothing or skin under normal use conditions and for the expected duration of exposure. Overall, the OSHA blood-borne pathogen standard provides an opportunity for industry and the health care community to work together to decrease the risk of exposure to infectious diseases for employees and patients. However, those directly responsible for complying with the regulations must use common sense and watch out for vendors concerned only with making a "fast buck." Knowledge of the contents of the preamble, standard, and compliance document is your best defense. Buyer beware! References
1. Department of Labor, Occupational Safety and Health Administration. Occupational exposure to bloodborne pathogens;finalrule.FederalRegister1991;56(235):64004182. 2. Department of Labor, Occupational-Safetyand Health Administration. Occupational exposure to bloodborne pathogens; proposed rule and notice of hearings. Federal Register 1989;54(102):23042-139.
,
,,
Eddie Hedrick, BS, MT(ASCP), ClC Columbia, Missouri
The new Occupational Safety and Health Administration (OSHA) blood-borne pathogens standard ~provides a perfect opportunity for the heakh care industry to witness the best and the worst of the free-enterprise system. The need for newer and safer types of personal protective equipment and engineering controls to protect those at risk for occupational exposure to blood and other potentially infectious materials has stimulated industry to develop these items. This response assists in providing increased safety for health care workers and patients. This represents the ideal situation, in which industry and the health care community work together to reach a common goal. In contrast, these new regulations also provide the occasion for "opportunists" to play on the fear of something new, fines; the federal government, bad publicity, and possible litigation, to sell misinformation, gadgets, and gimmicks. Since the release of the blood-borne pathogen standard, those responsible for implementing the standard have been inundated with brochures in the mail and sales representatives with videos, booklets, training materials, and personal protective equipment, all of which are declared to assist in complying with the OSHA regulation. M a n y w a r n that if you do not use a specific type of product, such as the one they are selling, you may be subjected to OSHA fines and other undesirable consequences. Internal company memos directing the sales force to "seize the moment" to sell the latest anti-AIDS gimmick have become all too common. Many of these companies are only interested in selling merchandise, not in providing the appropriate level of protection to those at risk. Others are sincere in their efforts, but are not totally familiar with the details of the final regulation. All too often they overemphasize or misrepresent the value or need for a specific product. Many continue to quote information from the May 30, 1989, proposed standard 2 which has been completely replaced with the final regulation. Mr. Hedrick is Advertising Editor for the JOURNALand manager, Infection Control/Staff Health Services, University Hospitals and Clinics, Columbia, Missouri.
17/45/38968
170
Additionally, during the past few months OSHA "experts" have appeared out of nowhere. Unfortunately, many of these experts are not well enough informed about the specifics of the regulation and so they too may promote misinformation. Because of all this misinformation and the confusion it creates, it is important for those responsible for implementing these regulations to take a step back and evaluate the situation in a commonsense manner. Obviously, many companies have or are in the process of developing a full range of legitimate products that will help employers to increase protection for workers at risk of occupational exposure. Many excellent programs and educational materials have also been developed by various organizations, such as the Association for Practitioners in Infection Control, the American Hospital Association, the American Medical Association, state hospital associations, and others. How can you tell which are good and which are not? The following suggestions may be helpful in selecting products, programs, and educational items to assist in your efforts to increase protection for health care workers at risk. SUGGESTIONS 1. OSHA approves of nothing!! Any product or program that claims to be "OSHA approved" should be approached with caution. OSHA disapproves of many things, but it does not endorse products, programs, or materials. When companies claim that their product will allow you to comply with the standard, you must evaluate it carefully to make sure all of the provisions are present and applicable to your environment. Do not take anyone else's word, it is your responsibility. 2. Beware of those who claim to be "experts" regarding the blood-borne pathogen standard. At this point in time there is no such thing; ask four OSHA inspectors how to interpret specific portions of the standard and you will get four different answers. Until the inspectors are properly trained to interpret the standard in a consistent and appropriate manner, interpretations will vary and confusion will result.
Volume 20 Number 4
Although frustrating, this problem should last only until.OSHA provides training to the inspectors. If you have specific questions regarding the standard, you can get the best answers by contacting the Regional Bloodborne Pathogen Director at your regional OSHA office or by contacting someone at the American Hospital Association. Obviously, others in your local area have become familiar with the document; you may wish to consult with them. The most important thing to remember is that because you are responsible for implementing the standard, you must become as familiar with the regulation as possible. This means that you should take the time to read the preamble, the regulation, a n d t h e compliance document! 3. Watch out for vendors selling these documents for $75 to $100. You can obtain the standard and the compliance document from the federal government for less than $5 by writing to your regional OSHA office or to the national office: The Occupational Safety and Health Administration OSHA Publications Room N-3101 Frances Perkins Bldg. 200 Constitution Ave. N.W. Washington, DC 20210 Telephone (202)523-9667 4. The final standard does n o t require personal protective equipment to be "fluid proof, . . . . fluid resistant," or "impervious." The employer has flexibility in choosing the type of personal protective clothing a n d its specific characteristic or protective capabilities. This decision should be based on the task being performed
Buyer beware/
17t
and the degree of exposure that is reasonably anticipated. A cotton lab coat is thus perfectly acceptable when the amount of blood exposure anticipated is small, but if the degree of exposure would allow the blood to soak through to the employee's clothing or skin, a more efficient barrier must be provided. Protective clothing can be reusable or disposable and can be made from a broad range of materials, with varying degrees of resistance to liquid penetration. The key to this part of the standard is that whatever material is selected must not allow blood or other potentially infectious materials to penetrate through to the clothing or skin under normal use conditions and for the expected duration of exposure. Overall, the OSHA blood-borne pathogen standard provides an opportunity for industry and the health care community to work together to decrease the risk of exposure to infectious diseases for employees and patients. However, those directly responsible for complying with the regulations must use common sense and watch out for vendors concerned only with making a "fast buck." Knowledge of the contents of the preamble, standard, and compliance document is your best defense. Buyer beware! References
1. Department of Labor, Occupational Safety and Health Administration. Occupational exposure to bloodborne pathogens;finalrule.FederalRegister1991;56(235):64004182. 2. Department of Labor, Occupational-Safetyand Health Administration. Occupational exposure to bloodborne pathogens; proposed rule and notice of hearings. Federal Register 1989;54(102):23042-139.
