Contaminated Laundry OSHA Standard

Contaminated Laundry

Contaminated Laundry, as outlined in the Blood-borne Pathogen Standard definitions, as: laundry which has been soiled with blood or other potentially infectious material or may contain sharps.

Potential Hazard 

Exposure to blood or other potentially infectious materials through contaminated laundry that was improperly labeled, or handled.

Possible Solutions 

Follow the procedures outlined in the Blood-borne Pathogens Standard handling contaminated laundry such as:

• Handle contaminated laundry as little as possible with minimal agitation.
• Bag contaminated laundry at the location of use. Do not sort or rinse laundry at the location where it was used.
• Place wet contaminated laundry in leak-proof, and color-coded or labeled containers, at the location where it was used.

Whenever contaminated laundry is wet and presents a reasonable likelihood of soak-through of or leakage from the bag or container, the laundry shall be placed and transported in bags or containers which prevent soak-through and/or leakage of fluids to the exterior.

Contaminated laundry must be placed and transported in bags or containers labeled with the bio-hazard symbol or put in red bags.

In a facility that utilizes universal precautions in the handling of all soiled laundry-alternative labeling or color-coding is sufficient if it permits all employees to recognize the containers as requiring compliance with universal precautions.

Use red bags or bags marked with the bio-hazard symbol, if the facility where items are laundered does not use universal precautions for all laundry.

Contaminated laundry bags should not be held close to the body or squeezed when transporting to avoid punctures from improperly discarded syringes.

Normal laundry cycles should be used according to the washer and detergent manufacturer's recommendations.

Are Your Disinfecting & Sterilizing Procedures OSHA Compliant?

OSHA Standard Disinfection and Sterilization

According to OSHA standards, disinfection and sterilization procedures should be used for all reusable instruments, devices and other items that are contaminated with blood and/or other potentially infectious materials (OPIM).

Your practice should use the following definitions as guidelines for appropriate sterilization and/or disinfection procedures:

Disinfection levels and sterilization

High level disinfection:

Must be used on all semi-critical care items that could be damaged by heat sterilization. Use a product labeled “disinfectant/sterilant” and leave the items immersed for the shorter time recommended by the manufacturer. (The longer time is used for “cold sterilization”.)

Intermediate level disinfection:

Must not be used on semi-critical care items. Use it for disinfection of non-critical care items that are contaminated with blood or OPIM. A bleach solution (1 part bleach to 10 parts water) is strong enough but must be mixed fresh daily. Wipe the item to be cleaned with the bleach solution (or a commercial disinfectant) and allow it to air dry.

Low level disinfection:

Not necessary for non-critical care items that have not been contaminated with blood or OPIM. Proper cleaning is usually sufficient. To use a low-level disinfection, wipe or spray an EPA registered disinfectant on the surfaces of the cleaned items and let them air dry.

Sterilization:

Destroys all microorganisms (including viruses) and their spores. Sterilization can be accomplished by the use of steam (steam autoclave), dry heat, chemicals under pressure (chemical autoclave) or an EPA registered product that is labeled “disinfectant/sterilant” (sometimes referred to as “cold sterilization”).

Critical Care Items

Critical care items:

All instruments and/or devices that are introduced directly into the bloodstream. They touch bone or penetrate tissue. All of these items must be sterilized.

Semi-critical care items:

Instruments that touch mucous membranes but do not touch bone or penetrate tissue. Sterilize them or, if the items are damaged by heat, use a high-level disinfection process following the manufacturer’s guidelines.

Non-critical care items:

Equipment and environmental surfaces that will come into contact with intact skin only. Floors, exam tables, crutches, and countertops are examples of non-critical care items. Use intermediate-level disinfection for non-critical care items. (Cleaning alone is sufficient unless the items are visibly contaminated with blood.)

Biological monitoring is a “spore test” and is the only way to ensure that heat sterilization is effectively killing all types of microorganisms. Check with the manufacturer of sterilizer for the proper spore test. Mail the exposed test spores to an appropriate microbiology lab for testing or check them in a special incubator designed for that purpose. 

Create a Culture of Safety and Avoid OSHA Fines

Boosting Employee Safety and Avoiding OSHA Citations

Although it’s impossible for employers to mitigate against every conceivable hazard in the workplace, there are five critical steps that every employer should take to improve safety in the workplace—and avoid costly OSHA citations.

●        Conduct an Internal Safety and Health Audit

One of the most effective ways for an employer to identify and eliminate safety hazards in the workplace is to conduct a safety and health audit. Employers should closely examine every aspect of their workplace to ensure they’re in full compliance with OSHA standards and best practices.

Employers must take care, though, in the way they conduct and document such audits.

In an inspection, OSHA may demand to see audit reports and use them to identify potential hazards in the workplace, essentially using the employer’s proactive audit against it and issuing citations based on hazards identified but not yet remedied.

Employers can protect their internal audit reports from disclosure to OSHA by working with counsel in conducting their audits. The audit report is then protected from disclosure to OSHA by the attorney-client communication privilege.

●        Create a Strong Safety Culture

A robust and authentic safety culture is critical for ensuring employee health and safety. Management at all levels should be involved in creating this culture, actively communicating with employees and being physically present where employees do their jobs. Such actions demonstrate to employees that employers are serious about safety, increasing employees’ commitment to safety and their overall job satisfaction. By doing this, employers have the opportunity to observe potential hazards with their own eyes and discover other potential hazards through conversations with employees.

Employers should assure employees that safety is a priority and that suggestions for improving safety in the workplace are not only welcome, but encouraged. By providing open lines of communication with employees, employers again encourage a commitment to safety at all levels of the organization and significantly improve the odds they will learn of a potential problem.

Employees are often the first to identify a potential hazard, and having regularly worked in a particular area, they have insightful suggestions about how problems can best be resolved. When an employee identifies a potential hazard, the employer should assess the situation promptly and respond to the issue in a timely manner.

●        Ensure That Safety and Health Documentation Is Current and Well Communicated

All employers must provide to their employees essential safety information, such as how to evacuate in an emergency. OSHA also requires employers to provide a range of written guidance to employees regarding the essentials of safely performing their work.

Every employer should regularly review its OSHA documentation requirements, which may change from time to time. Recently, for example, OSHA updated the Hazard Communication Standard to align with the GHS. Having determined the extent of their documentation requirements, employers should review their documents and ensure that they are thorough and up to date. Finally, employers should make sure that employees fully comprehend the documentation, know how and when to use it, and understand the reason for maintaining it. This helps to ensure employee safety and gives employees another opportunity to provide suggestions and point out information that’s missing from the documents.

●        Train Employees in Safety and Health, Regularly and Comprehensively

OSHA standards include a number of training requirements. OSHA often cites employers for failure to train employees on relevant safety and health information and failure to ensure that employees understand the training. This is avoidable.

Employers must provide comprehensive training to employees in a way that employees can fully comprehend. A simple way to ensure compliance with this requirement is to administer a quiz at the conclusion of the training, requiring employees to demonstrate their comprehension of the information that was relayed to them. Many employers require employees to achieve a high score on such quizzes (e.g., 90 to 100 percent). If employees are unable to reach the required score on the first try, they should be given the opportunity to be retrained and take the quiz again. Employers should keep records of all safety and health training provided to employees and should keep quizzes and other related materials on file. Simply being able to provide these documents to OSHA in the event of an inspection will go a long way toward proving that the employer has complied with OSHA’s training requirements.

●        Protect Contractors and Temporary Workers, Too

Employers should make every effort to ensure that all employees working in their facilities are safe – contractors and temporary workers included. Many tragic incidents can be avoided by ensuring that everyone is on the same page when it comes to safety. Although this task may sound daunting, it is another essential element of creating a truly safe working environment.

OSHA has instructed its compliance officers to expand the scope of inspections to include temporary workers who may have been exposed to a hazard identified by OSHA. This instruction led to a 322 percent increase in inspections involving temporary employees in 2014. In only 15 percent of those inspections, citations were issued to the temporary agencies—but countless citations were issued to host employers, often for failing to train temporary workers properly or to provide them with the safety gear provided to permanent employees, leaving temporary workers at an increased risk of harm.

(EBGL website)

Safety in the Laboratory

Laboratory OSHA Safety Culture

                                                           

The safety culture varies greatly from laboratory to laboratory. Most lab employees these days know that eating food or drinking in the lab is against most, if not all, lab regulatory agency rules and guidelines. However, it is surprising that many do not seem to understand that gum chewing or using hard candy or throat lozenges is also not permitted in a laboratory setting.

                                                           

OSHA’s Bloodborne Pathogen Standard specifically states “Eating, drinking, smoking, applying cosmetics or lip balm, and handling contact lenses are prohibited in work areas where there is a reasonable likelihood of occupational exposure.” Obviously, the goal of this regulation is to prevent employees from obtaining infection via ingestion. A secondary goal is to limit hand to mouth contact while working in the laboratory. So far there has been no mention of gum or cough drops in the standards.

                                                           

In the National Research Council’s Prudent Practices in the Laboratory (1995), it states “Eating, drinking, smoking, gum chewing, applying cosmetics, and taking medicine in laboratories where hazardous chemicals are used should be strictly prohibited.” In the Clinical and Laboratory Standards Institute’s document Clinical Laboratory Safety (GP-17 A3, 2012), it states “Food, drink and substances that provide potential hand-to-mouth contact (including chewing gum and lip balm) are prohibited in technical work areas.”

                                                           

Most inspectors of the laboratory will cite the lab for gum chewing or the like. An employee may respond that the gum was placed into their mouth outside the lab, but proving that would be difficult at best. It is an inappropriate and unsafe practice, and it should not be allowed.

                                                           

Again, limit hand-to-mouth or hand-to-face contact in the laboratory. What about telephone use? There are speaker options for phones that can help, but some labs are too noisy for that type of use. Disinfect phones often if that is the case.

As with any other safety regulation, if you explain it to staff, and if you make it easy to comply, your safety culture will improve. Educate your staff about these guidelines and standards and why they exist. Unfortunately, many workers fell victim to harmful infectious diseases before these regulations were developed. Don’t let your staff become another part of those unfortunate lab safety statistics.