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 Hazardous Waste Operations and Emergency Response Standard (HAZWOPER) applies to five distinct groups of employers and their employees. These include any employees who are exposed or potentially exposed to hazardous substances — including hazardous waste — and who are engaged in one of the following operations:

clean-up operations — required by a governmental body, whether federal, state, local, or other involving hazardous substances — that are conducted at uncontrolled hazardous waste sites;

corrective actions involving clean-up operations at sites covered by the Resource Conservation and Recovery Act of 1976 (RCRA) as amended (42 U.S.C. 6901 et seq.);

voluntary clean-up operations at sites recognized by federal, state, local, or other governmental body as uncontrolled hazardous waste sites;

operations involving hazardous wastes that are conducted at treatment, storage, and disposal facilities regulated by Title 40 Code of Federal Regulations Parts 264 and 265 pursuant to RCRA, or by agencies under agreement with U.S. Environmental Protection Agency to implement RCRA regulations; and

emergency response operations for releases of, or substantial threats of releases of, hazardous substances regardless of the location of the hazard.

(More information can be found in osha documents as specified by 1910.120 and 1926.65)

OSHA has authorized several specific HAZMAT training courses know has the hazwoper training courses.These courses are comprised of the 40 hour hazwoper, 24 hour hazwoper and the 8 hour hazwoper refresher course.

Many OSHA authorized sites like OSHAu.co offer hazwoper training courses online.These courses can be administered in self-paced, downloadable modules which allow the student to complete the required training at their leisure.Online training also provides employers with the benefit of allowing their employees to take the required training from any internet-based computer eliminating travel costs and while maintaining productivity. The benefits of online training are realized through increased safety and health of employees and an increased protection of our environment and it’s resources.

EPA Announces Next Steps on Two Hazardous Waste Rules

EPA is announcing next steps on two hazardous waste rules to respond to concerns raised by stakeholders: the Definition of Solid Waste rule and the Emission Comparable Fuels rule. 

EPA is planning to hold a public meeting to discuss possible revisions to the Definition of Solid Waste (DSW) rule in response to an administrative petition asking the agency to reconsider and repeal the rule. The rule became effective on December 29, 2008. The meeting is planned for the end of June, and a Federal Register notice with the details of the meeting will be published in May. 

The DSW rule modified the regulations for recycling hazardous secondary materials to encourage the recycling of certain materials to help conserve resources. The rule includes conditions designed to ensure that the recycling of the materials is protective of human health and the environment. The rule also takes into account a series of opinions in the U.S. Court of Appeals for the D.C. Circuit on the meaning of the term “discard,” which forms the basis of the definition of solid waste.

Since publication of the DSW rule, the Sierra Club has raised concerns about the effectiveness and protectiveness of the rule and has requested EPA stay the rule in an administrative petition. In addition, the Sierra Club and the American Petroleum Institute have filed judicial petitions for review in the U.S. Court of Appeals for the D.C. Circuit. Various industry groups have also filed letters opposing the Sierra Club’s administrative petition. 

EPA expects that stakeholders’ input at the public meeting will assist the agency in deciding whether to make revisions to the rule and how such revisions would further ensure that the rule appropriately and safely encourages resource conservation for those hazardous secondary materials that are conditionally excluded. The Federal Register notice announcing the meeting will raise specific questions for consideration, particularly related to reclamation that is not under the control of the generator. Any revisions to the rule would be made through the full public rulemaking process. 

EPA is also planning to propose a rule to withdraw the Emission Comparable Fuels (ECF) rule, which became effective on January 20, 2009. The proposal will present the agency’s concerns and request comments from the public after publication in the Federal Register, planned for November 2009. After evaluating the public comments, the EPA will make a decision on whether to repeal the exclusion.

The ECF rule removed regulatory costs by reclassifying certain manufacturing byproducts as non-wastes. ECF is fuel that is produced from a hazardous waste, but which generates emissions when burned in an industrial boiler that are comparable to emissions from burning fuel oil. The materials must also be stored under an elaborate set of requirements. The final rule has been criticized for allowing hazardous waste to evade the hazardous waste regulatory system, and also for being difficult to administer. Industry members have also criticized it because of the detailed and prescriptive conditions for reclassification, which they believe will limit the rule’s use. 

More information on the Definition of Solid Waste rule: http://www.epa.gov/epawaste/hazard/dsw/rulemaking.htm

More information on the Emission Comparable Fuels rule: http://www.epa.gov/epawaste/hazard/tsd/td/combust/compfuels/exclusion.htm

Recently, Chuck Armstrong, Safety Manager for the City of Chicago, sent me a website to check out.  This short video http://www.hazmatsolutions.net/erg/ explains how to use an Emergency Response Guidebook (ERG).   Click on the quiz at the end of the presentation to test your knowledge.  

This video can also be used a part of a training class if your safety department is involved with hazardous materials.   

Thanks for passing this information to our readers.  If you have anything like this (which is not a commercial) let us know and we will give everyone the information to use.

It is interesting that in the 29CFR 1910, there are 2 parts that have similar, yet vastly different relationships.  Both parts deal with hazardous materials but the difference is only one (1) zero or is it?  1910 part 120 is the regulation for hazardous waste operations and emergency response, and 1910.1200 is the compliance regulation for hazardous communications. 

Hazardous communications almost always is in the top 5 of most frequently cited standards of OSHA violations.  The most common citation is for failing to have a written program 1910.1200(e) and failure to train employees 1910.1200(h).

So what does this mean?  Employers are required to have an updated MSDS (Material Safety Data Sheet) book on ALL hazardous chemicals/materials in the workplace.  The book should be available to all employees who work with these hazardous materials.  Each time a new or changed hazardous material enters the workplace the MSDS book should be updated.  In addition, all hazardous materials must be properly labeled with a similar 3 or 4 part hazardous label similar to the ones seen above.  Some labels include proper PPE (personnel protective equipment) to be worn when working with this hazardous material.

Another key part of the Hazardous Communication standard is the training.  The training 1910.1200(h)(3) shall include at least:

• Methods and observations to detect the presence or release of a hazardous material in the work area.
• Physical and health hazards of hazardous materials in work area
• Measures take for protection.
• Information including how to use the hazardous labels, MSDS sheets and where employees can get information.

To avoid compliance issues with the Hazcom standard, start with a hazardous materials audit and develop you policies and procedures.  Next write a Hazcom program that includes training, and then do the training.  Remember, every time a hazardous material changes or is introduced into the workplace, or a new employee is put into that environment you must train or retrain all involved.  Avoid the problems and avoid the fines.  Write the program and do the training.

I recently became aware of a journal (Fire Engineering) that has a variety of articles about fire, hazmat and safety. One the articles that came to my attention was by Steven M. De Lisi.   Mr. De Lisi retired after a fire service career spanning 27 years that included serving as a regional training manager for the Virginia Department of Fire Programs (VDFP) and most recently as the deputy chief for the Virginia Air Guard Fire Rescue.

His article, Hazmat Survival Tips: 10 Common Errors Committed During Incidents  addresses issues First Responders have dealing with a hazardous incident.  Today many companies have HazWoper trained personnel, many who might also find some interesting information within this article.  Hazardous incidents are becoming more common as more and more hazardous materials are being transported throughout the United States.  Companies need to make sure they are in compliance with both the US DOT (49 CFR parts 100-185) and OSHA (29CFR part 120).