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Risky business: how health care facilities can minimize their hazmat liability.

RISKY BUSINESS

How health care facilities can minimize their hazmat liability.

HEALTH CARE FACILITIES are storehouses of materials used to combat illnesses from the common cold to AIDS and cancer. Many of these materials are made up of matter that, if handled improperly, may cause harm to handlers and bystanders. Consequently, these facilities are constantly in danger of litigation.

Establishing a comprehensive hazardous materials and waste management (HM/WM) program enables a health care facility to organize the risk management actions required to minimize its potential liabilities. The essential elements of such a program are risk assessment, risk reduction and control measures, and monitoring.

Risk assessment. The security manager should

* conduct a site inventory to determine which materials used in the health care facility and wastes generated are hazardous;

* determine which regulatory and accreditation requirements relate to the materials and wastes identified in the site inventory;

* conduct a compliance audit to determine the facility's degree of compliance with these regulatory and accreditation requirements;

* conduct a health risk audit to determine the actual or potential risks or level of exposure to employees, other occupants of the facility, and other members of the public from identified hazardous materials and wastes; and

* conduct a financial risk audit to identify the legal and financial risks associated with hazardous materials and wastes.

Risk reduction and control measures. Specific measures should be taken to minimize the risks to employees and the public. These include

* employee training on ways to minimize employees' own exposure, proper handling of materials and wastes, and right-to-know requirements;

* material substitution or procedural changes to minimize personnel exposure and potential environmental contamination;

* emergency preparedness and contingency planning; and

* documentation of all relevant activities.

Monitoring. Monitoring the outcome of these actions will provide data to augment further action, if necessary. Monitoring steps include

* development of a system for keeping current the materials and waste site inventory.

* development of a system for updating the regulatory requirement audit,

* development of a system for updating the compliance audit, and

* monitoring personnel performance if they are exposed.

An effective HM/WM program unites these essential elements--risk assessment, risk reduction and control measures, and monitoring--into a coordinated and efficiently implemented system. This program provides a plan for allocating resources and responsibilities.

Administering the program takes several tasks by the security manager. He or she needs top management's commitment to establish an HM/WM program. Management should issue a strong statement of commitment to the program's goals, perhaps through a formal statement from the board of trustees.

The following statement reflects the necessary degree of commitment and may be suitable for many facilities. It should, however, be reviewed carefully by relevant personnel, including legal counsel, and modified as desired before it is adapted.

"This institution is committed to maintaining and protecting the health and safety of its staff, patients, and visitors, as well as protecting the environment and the health and safety of the members of the surrounding community. We have, therefore, adopted a policy that commits this institution to compliance with the requirements of all relevant federal, state, and local laws and regulations and to establishing and maintaining a place of employment that is free of recognized hazards that could harm persons or property. This policy reaffirms our commitment to providing a safe environment for our staff, patients, and visitors. It will be instituted in the form of a hazardous materials and waste management program implemented within the framework of our existing safety and risk management activities."

At a minimum the statement should also cover

* the program's goals;

* the program's scope;

* how the program will apply to the staff, patients, visitors, and community;

* procedures to ensure compliance;

* a statement asking for individual departmental policies; and

* who will be responsible for reviewing the policies and procedures.

The next major task is to appoint an HM/WM program coordinator and assign program responsibilities. Ideally, the coordinator should be backed by hospital administration and the board of trustees. He or she should orchestrate the program to ensure it meshes smoothly with other related activities of the safety committee, the facility's risk manager, and the department managers.

Depending on the size of the facility, the HM/WM program coordinator may be a new, full-time employee, or the duties may be assigned to existing members of the staff.

The program coordinator or designated alternate should conduct or commission an inventory of the health care facility's hazardous materials and wastes. Helpful information for understanding what this task encompasses is contained in Occupational Safety and Health Administration (OSHA) Hazard Communication Standard.

The program coordinator should also perform or commission an analysis of the current regulatory requirements. This analysis should be updated at least once a year.

He or she should also evaluate the facility's degree of compliance with the current regulatory requirements. The departments that should be included in this analysis are central services, dietary, engineering, grounds, housekeeping, laboratory, oncology, pathology, pharmacy, the print shop, radiology, respiratory therapy, and surgery. This information, also, should be updated at least once a year.

Hazardous materials can be found in all these departments. Take the following examples:

* laboratory--solvents, acids, tissue treatments

* radiology--photographic chemicals

* print shop--ink, photographic chemicals, solvents

* housekeeping--solvents, cleaning agents

* grounds--pesticides, paints

* engineering--oils, fuels, gas

* dietary--cleaning agents

Various hazardous waste streams in the facility must also be documented by the program coordinator. He or she should note where these streams are, how they are used, how they are stored, how they are transported, and how and when they are disposed of. It is useful to establish policies and procedures for managing potential major releases of any hazardous material used in the facility.

At a minimum, the policies should contain instructions for immediate action, evacuation rules, cleanup procedures for both small and large spills, and reporting requirements. Once these policies are prepared, the coordinator should arrange for the proper disposal of all hazardous wastes and maintain a hazardous waste manifest file. He or she should review the regulations, identification requirements, handling practices, and methodology for managing distinctive types of waste.

The classes of waste include the following:

* hazardous chemicals--flammable, corrosive, chemically reactive, and toxic

* infectious wastes--lab wastes and cultures, pathological specimens, surgical specimens, equipment, instruments, utensils, material from patients' rooms, human dialysis waste, carcasses of animals and enclosures infected with etiological agents, and other wastes determined by infection control staff

* physically hazardous wastes--aerosol cans and CRTs

* radioactive wastes--isotopes from the laboratory and nuclear medication

* cytotoxic wastes--chemotherapy agents and by-products of prescriptions

All department managers should work with the program coordinator to explore using nonhazardous alternatives for all hazardous materials in the facility. These could include nonflammable anesthetics and less volatile chemicals. However, these may not be the least costly measures to reduce occupational exposures. The program coordinator should also explore methods for minimizing the volume of hazardous waste and finding alternative, more cost-effective methods for disposal of the facility's hazardous wastes.

In conjunction with the materiel management department, the HM/WM program should maintain a master file of material safety data sheets (MSDSs) for all hazardous materials used in the facility. Supervisors should be taught to find emergency telephone numbers, fire and explosion hazard data, health hazard data, precautions for safe handling and use, and control measures.

In conjunction with environmental services and all department managers, the program coordinator should ensure that all hazardous materials and wastes are stored and transported in the facility with due regard to their nature at all times. He or she should also review container labeling, accumulation rules, container integrity recognition, container and liner compatibility, closing and opening containers, and dating practices.

The program coordinator's responsibilities do not end at this stage, however. He or she should also arrange for periodic review of the facility's HM/WM policies and procedures by the safety committee, the infection control committee, and the radiation safety committee. The recommendations resulting from committee review of the HM/WM policies and procedures should be coordinated with the hospital-wide quality assurance function.

The risk manager and legal counsel play important roles since they should evaluate the legal and financial risks associated with the current or proposed management of the facility's hazardous materials and wastes. They should also look for precedent-setting materials in risky areas.

Department managers should provide appropriate documented training and continuing education to all employees who use or who are potentially exposed to hazardous materials or wastes. These training records should be maintained until three years after termination of employment.

At a minimum, these hazardous materials training courses should cover

* the Hazard Communications Standard (HCS)--a law stating employees' right to know--and its requirements;

* identification of hazardous materials in the workplace;

* where to find the hazardous materials evaluation policy, facility HCS materials, a listing of hazardous materials, and MSDSs;

* methods to detect hazardous materials;

* specific employer and employee protection methods;

* how to read and interpret MSDSs; and

* how to obtain further information.

Arranging for personal and environmental monitoring where needed is also an important duty of the department managers. Copies of these results should be forwarded to personnel or the employee health department. Department managers should also arrange for periodic employee health examinations.

Along with the materiel manager, the department manager should request MSDSs from all suppliers of hazardous materials to the department. He or she should then maintain an incoming hazardous materials log or register.

In conjunction with the program coordinator, department managers should develop emergency preparedness and contingency plans to respond to major releases of hazardous materials used or stored in the department.

Preventing accidental releases, detecting releases, raising the alarm, and performing on-site reporting, containment actions, evacuation procedures, and cleanup after a spill or release are all crucial tasks for today's health care facility security managers. By implementing the suggestions mentioned earlier, security managers, department managers, and HM/WM program coordinators can decrease the chance that their facilities will be exposed not only to hazardous material and waste disasters but also to litigation.

C. Ray Graves is the security coordinator of the Medical Care Program for Kaiser Permanente in Hayward, Ca. He is a hazardous materials/waste categorizer emergency responder and has extensive experience in program design, planning, implementation, compliance monitoring, and documentation management of hazardous materials and wastes in government, military, and health care environments. Graves is a member of ASIS.
COPYRIGHT 1990 American Society for Industrial Security
No portion of this article can be reproduced without the express written permission from the copyright holder.
Copyright 1990 Gale, Cengage Learning. All rights reserved.

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Title Annotation:hazardous materials
Author:Graves, C. Ray
Publication:Security Management
Date:Feb 1, 1990
Words:1706
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