H1N1


OSHA recently solidified leadership for the agency and has provided a clearer picture of the regulatory horizon.

First of all, David Michaels, PhD, MPH, assumed his position as head of OSHA when the Senate confirmed his nomination as assistant secretary of Labor for occupational safety and health. Nominated by President Barack Obama on June 28, the Senate acted on the nomination December 3.

Michaels, an epidemiologist, has been a professor at the George Washington University School of Public Health and Health Services in Washington, DC, and is also the author of Doubt is Their Product: How Industry’s Assault on Science Threatens Your Health.

Agency watchers assumed that any work on new, and perhaps controversial, standards, would await the establishment of a permanent director.

While Michaels as settling in, Secretary of Labor Hilda L. Solis held an online Q&A session Dec. 7 to discuss regulations at the Department of Labor.

Solis announced that OSHA is considering airborne infectious disease protection for healthcare workers and will publish a request for information in the Federal Register in March.

A standard would require healthcare employers to protect workers from tuberculosis, severe acute respiratory syndrome (SARS), and influenza, such as H1N1, on which OSHA recently issued an enforcement directive.

When asked if an airborne infectious disease standard would be modeled after the California version, which took years to achieve consensus among employers, labor and other stakeholders, Solis said the California standard “would certainly be one important piece of information that OSHA will consider in deciding whether to propose or issue a standard.” She would not predict how long it would take to issue a final standard.

Also, Solis confirmed that although OSHA has conducted several inspections, it has not yet issued any citations based on the H1N1 enforcement directive.

In an OSHA-specific session later that day, HealthLeaders Media asked OSHA interim director Jordan Barab, if the absence of airborne infectious disease standard has hampered the agency with regard to its H1N1 educational preparedness and enforcement activities?

“No, it has not hampered us,” said Barab. “While a standard on airborne transmissible diseases would have been preferable, we believe that we are responding to the issues effectively using existing standards and the General Duty Clause.”

On the matter of issuing an industry-wide ergonomics standard, both Solis and Barab reiterated—word-for-word in fact—”At this time, OSHA has no plans for regulatory activity.” Both said that a proposal to reinstate the work-related musculoskeletal disorders column on the OSHA 300 Injury Log was not a prelude to issuing such a standard.

Concerning an industry-specific ergonomic standard, such as one for safe patient handling standard, Barab said,” There are many options that OSHA might consider if the agency decides to pursue rulemaking in this area. Industry specific standards is one option that would be considered.”


David LaHoda, the managing editor of Medical Environment Update and OSHA Watch, has produced healthcare training videos and consulted for medical practices and ambulatory healthcare facilities.

First aid in the era of biohazards

by Lisa J. Burns, Q.S.S.P.

10 best practices to keep responders safe

Everyone sees the need for trained responders, first-aid kits and automated external defibrillators at the workplace. But what about the simple cut that bleeds enough to require a gauze bandage? Does the responder — or just a nearby helpful employee — see the need to wear disposable gloves? Bloodborne pathogens and other biohazards command little attention from most people, yet can cause critical illnesses and sometimes eventual death.

Defining the danger
Bloodborne pathogens are microorganisms (bacteria or viruses) carried in the blood that can be transmitted and cause disease in other people. Hepatitis B Virus (HBV) and Human Immunodeficiency Virus (HIV) are two examples that are addressed by the OSHA Bloodborne Pathogen standard 29 CFR 1910.1030. Malaria and syphilis also are caused by bloodborne pathogens. Other body fluids also may transmit these and other diseases.

Infectious disease such as the H1N1 flu virus is a workplace concern that employers must address.

Transmission
Unbroken skin generally acts as a barrier to bloodborne pathogens. However, microorganisms can enter through any damaged or broken skin such as acne, sunburn, blisters, open sores, cuts or abrasions. They also may be transmitted through mucous membranes, including those of the eyes, nose or mouth.

Infectious diseases such as the H1N1 flu virus are primarily transmitted through airborne body fluids emitted with coughs and sneezes, and breathed in by others in the immediate vicinity. They also are transmitted when a hand used to cover the mouth then touches faucets, doorknobs and other surfaces from which it is later picked up by others.

OSHA first-aid regulations
Emergency medical services and first aid that general industry employers must provide are described in OSHA standard 29 CFR 1910.151. The standard recommends kits and supplies that are compliant with the minimum guidelines established by the American National Standards Institute (ANSI) in Z308.1-2009. It also incorporates other standards and measures by reference, such as 29 CFR 1910.1030, which deals with bloodborne pathogens.

OSHA’s 29 CFR 1910.1030 standard requires limiting employee exposure to blood and other potentially infectious materials. It specifies that training and personal protective equipment must be provided for employees who can be “reasonably anticipated” to face possible contact with blood or other potentially infectious materials on the job.

The standard, issued in 1991, was updated in 2001 in response to the Needlestick Safety and Prevention Act, and can be found at http://www.osha.gov, along with FAQs and various letters of interpretation issued over the years since then.

Best practices
Following the best PPE practices recommended below will help keep first responders safe from bloodborne pathogens and other infectious material.

1. “Universal precautions.” Treat every situation as potentially dangerous. OSHA’s universal precautions require that all human blood or other potentially infectious materials be considered hazardous.

2. Hand protection. Before donning gloves, cover any cuts or sores on your own hands with a bandage. Inspect the gloves and if the material is thin, doubleglove to provide another layer of protection. Do not use torn or punctured gloves, no matter how miniscule the damage might be. When removing used gloves, pull them off from the cuff, turning them inside out so the outside of the gloves do not touch your bare skin. Dispose of them in a designated biohazard bag. Immediately scrub your hands thoroughly, including under nails — and any other potentially contaminated skin — with nonabrasive soap and running water at hand-washing facilities that employers must provide in readily accessible areas.

3. Eye and face protection. While providing first aid or other medical assistance as well as working in labs or while cleaning up a spill, there may be a risk of splashing or vaporization of contaminated fluids. Use goggles to protect against transmission of pathogens through your eye membranes. Use a face shield in addition to goggles to protect against splashes to your nose and mouth.

4. Body protection. In some cases, you may need to wear aprons or body shields to protect your clothing and keep blood or other contaminated fluids from soaking through to your skin. Wear shoe covers to avoid contamination of your footwear.

5. Clean up. For clean-up of blood or other body fluids from sick or injured employees, use gloves and, depending on the situation, some or all of the above-mentioned PPE. In addition, you should have available a small shovel and scraper, appropriate absorbent materials, biohazard bags, ties, germicidal towelettes — and for large areas, a mop or sponge and bucket with a solution of 1/4 cup bleach to 1 gallon of water. Some manufacturers supply complete biohazard clean-up kits that contain all the necessary supplies, including special absorbent materials that deodorize as well as bind the hazardous body substances together.

6. Deposit waste. Once clean-up is complete, deposit the waste material first in a labeled, red biohazard bag and tie it tightly. Use germicidal towelettes or bleach solution to clean the contaminated area. Then put the first bag into a second biohazard bag, and add the used towelettes or sponges, your shoe covers, gown, face mask with eye shield and, lastly gloves in the same bag, and seal it with a tie. Discard the red bag in an appropriate container for infected solid waste as required by local regulations.

7. Sharps. For any broken glass or other sharp material, use a broom with shovel or dustpan, and deposit them in appropriate boxes. Never touch them with your gloved or ungloved hands and do not put them in a biohazard bag.

8. Decontamination. Finally, wipe your hands with antiseptic hand wipes that provide rapid bactericidal action and allow them to air dry. Next, go to the nearest handwashing area and wash your hands and all potentially exposed skin thoroughly with non-abrasive soap and running water.

9. Equipment decontamination. A person trained in the appropriate procedures must decontaminate and sterilize all non-disposable equipment and tools used, such as mops, buckets and re-usable gloves, as soon as possible.

No complacency
Factory or construction site, chemical, plastics or food and beverage processing plant — no matter what the workplace — there should be no toleration of complacency when there is potential for exposure to bloodborne pathogens and other infectious disease. The effects of exposure may not be immediate, but there is a definite potential for serious illness and eventual death.

Lisa J. Burns, Q.S.S.P. Lisa is associate product manager-personal protection- Americas at North by Honeywell. She is a member of the International Safety Equipment Association and a Qualified Safety Sales Professional. Lisa can be reached at (401) 275-2608 or by e-mail at Lisa.J.Burns@Honeywell.com.

The risk of influenza to healthcare workers is not a new concern, but the ongoing experience with novel influenza A (nH1N1) makes this issue even more urgent. Among the many considerations for the health and well-being of healthcare workers is the question about what types of personal protective equipment (PPE) (respiratory protection, gloves, gowns, eye protection, and other equipment) are needed to protect these frontline workers. PPE needs to be regarded one part of a set of infection control strategies to reduce the potential for infection in healthcare workers. At the request of the Centers for Disease Control and Prevention (CDC) and the Occupational Safety and Health Administration (OSHA) the Institute of Medicine convened the Committee on Respiratory Protection for Healthcare Workers in the Workplace Against Novel H1N1 Influenza A to provide recommendations regarding the necessary respiratory protection for healthcare workers in their workplace against novel H1N1 influenza A.

RESPIRATORY PROTECTION

The committee focused solely on the scientific and empirical evidence regarding the efficacy of various types of personal respiratory protective equipment (e.g., medical masks and respirators). Studies on influenza transmission show that airborne (inhalation) transmission is one of the potential routes of transmission. N95 respirators are documented to filter out 95 to 99 percent of relevant particles and have maximum effectiveness when properly fitted to the face of users. Research results on the filtration and fit of medical masks show wide variation in penetration of aerosol particles and inadequate fit suggesting that the use of medical masks is unlikely to be effective against airborne transmission.

Recommendationation 1: Use Fit -Teste d N95 Respirators espirators

Healthcare workers (including those in non-hospital settings) who are in close contact with individuals with nH1N1 influenza or influenza-like illnesses should use fit-tested N95 respirators or respirators that are demonstrably more effective as one measure in the continuum of safety and infection control efforts to reduce the risk of infection.

• The committee endorses the current CDC guidelines and recommends that these guidelines should be continued until or unless further evidence can be provided to the effect that other forms of protection or other guidelines are equally or more effective.

• Employers should ensure that the use and fit testing of N95 respirators be conducted in accordance with OSHA regulations, and healthcare workers should use the equipment as required by regulations and employer policies.

It is important to note that controversy exists regarding clinical guideline decision making as many factors besides efficacy may affect policy decisions for PPE guidance including economics, equipment supplies, vaccine availability, immunization status, extent of worker compliance, and logistical considerations in the implementation of such guidance. The committee was not charged to address these other issues.