Printer Friendly

Compiling employee safety records that will satisfy OSHA.

Your best defense against an OSHA inspection is accurate, detailed compliance documentation--the first thing inspectors would scrutinize if they visited your lab.

On the same day OSHA's blood-borne pathogens standard became effective, March 6, 1992, the agency published the companion document "OSHA Instruction CPL 2-2.44C." Every laboratory manager who has not already done so should obtain a copy from the area or regional OSHA office immediately. The document explains in straight-forward language what OSHA inspectors will be looking for when they visit clinical laboratories.

OSHA has now spelled out record-keeping requirements for all health care facilities. Employers who fail to learn and follow the rules will be asking for trouble. This article is intended as a general overview of the instruction document.

* For the record. OSHA's standard stipulates that an employer's exposure control plan (designed to eliminate or minimize worker exposure) must include exposure determination. Essentially, this means that employers must identify all personnel who will receive biosafety training, protective equipment, a series of HBV vaccines, and any other benefits required under the rules of the standard. The exposure control plan must be reviewed annually and updated to reflect any significant procedural changes in the department that could result in an occupational exposure.

Employers are being asked to assign all at-risk job classifications to one of two categories: jobs in which all employees are exposed to infectious materials and those in which some employees are at risk. Under the second category, specific responsibilities that could cause an exposure (such as performing procedures that involve vascular access, manipulating contaminated sharps, or handling deceased persons) must be delineated. For instance, in some small clinical laboratories, a receptionist, bookkeeper, or office manager occasionally may be asked to perform a task such as disposing of medical waste or transporting specimens from one area to another. Consequently, employers are responsible for listing these job classifications under the second category, identifying the tasks associated with a possible exposure, and naming all employees who hold such positions.

Great care must be taken to categorize jobs accurately. OSHA inspectors will survey this section of the plan closely.

* HBV safeguard. One of the most proactive features of the bloodborne pathogens standard is the mandate that employers make the hepatitis B vaccination available, free of charge, to all employees who work with infectious materials. This regulation goes into effect as soon as the worker has received biosafety training and within 10 working days after being assigned to a job involving occupational exposure.

Under no circumstances are workers to pay any out-of-pocket expenses for their vaccines. Employers may not ask staff members to use their health insurance for the vaccine unless any deductible or copayment is excluded. It is also forbidden to ask employees to foot the bill when vaccines are first administered and to promise to reimburse them if they remain employed for a certain period of time. Workers who resign during or after the vaccination process do not have to reimburse the employer.

Figure I outlines the step-by-step process employers must implement and enforce to insure compliance with OSHA's HBV prevention program. The agency has laid out strict documentation requirements. Under the new standard, employers are required to maintain special employee records on every worker who is eligible to receive a vaccination. A qualified health care professional should be assigned to head the program. This individual will compile data for the necessary records and oversee the program.

Among the details that must be documented are the worker's name and Social Security number, whether the employee has had a previous hepatitis B vaccination, the employee's physical ability to receive the vaccine, and, if applicable, dates on which the series was administered. The files are also to contain employees' medical records given to the program director and his or her written opinion on whether each worker should receive the vaccine. Biosafety training should be documented in a separate report.

The Hepatitis B Vaccine Declination statement, which can be found on the last page of the OSHA standard (Appendix A), must appear on the declination form signed by any employee who refuses the vaccine. No part of that verbiage may be altered.

* How long to keep files. An employee's medical records should be handled confidentially at all times by both the employer and the program director. These records must be kept on file for the duration of employment plus 30 years. Responding to objections from organizations such as the American Red Cross and the Academy of General Dentistry that the time requirement is extreme, OSHA notes in the standard that the provision is neither excessive nor impractical when viewed from the employee's perspective: "Retention of these records and exposure incidents is necessary to assist current and future healthcare professionals in assessing an employee's medical history and prescribing medical treatment."

The agency defends its position by pointing out that hepatocellular carcinoma, a rare but potential result of hepatitis B infection, may develop as long as 30 years later. Individuals who become HBV carriers or develop chronic hepatitis often are ill or infected for the rest of their lives.[1] The agency contends that its 30-year requirement is consistent with other OSHA standards mandating retention of occupational medical records.

While numerous professional and employee groups support the hepatitis B regulation, many employers have protested the financial burden they say it will impose. In response, OSHA has cited compelling evidence from the Centers for Disease Control in which annual casualties resulting from HBV infection are estimated at 8,700 infected health care workers, 2,175 clinical illnesses, 435 hospitalizations, and 194 deaths. The American Medical Association stated that "the loss of healthcare workers to hepatitis B virus overshadows the risk of AIDS and is almost entirely preventable."

* After exposure. The employer is expected to take immediate action when an employee reports an exposure incident. The worker must be directed to a qualified health care professional who will provide a confidential medical evaluation and appropriate follow-up consultations (Figure II). Throughout the entire follow-up cycle, it is mandatory that all actions be documented comprehensively.

Most hospital-based clinical laboratories already employ internal health services; these departments are likely to assume responsibility for follow-up after employee exposure. San Francisco General Hospital, in the forefront of health care worker exposure due to its extensive experience with HIV-positive patients, has run a 24-hour exposure hot line for employees since June 1989.

In contrast, many small, private clinical labs and physicians' office laboratories do not have employee health services available on site. Although staff pathologists and physicians are qualified to provide counseling, these facilities find it more practical and cost-efficient to use an outside medical service for this purpose.

Mitchell Chasen, M.D., medical director of Priority Medical Care in Bridgewater, N.J., runs an emergency medical service that specializes in occupational medicine. The group provides hepatitis B vaccinations and post exposure evaluations and follow-ups to health care professionals from various institutions. Dr. Chasen told MLO that it is "critical for counselors to take the extra time to answer employees' questions and address their concerns about occupational exposures." Helping employees to understand the facts, Dr. Chasen says, reduces their stress and fear.

Whenever Dr. Chasen notes any trends in employee exposures at a given facility, he said, he relays them to the employer in hopes of reducing or eliminating such injuries. In light of OSHA's new requirement that employee records be stored for 30 years beyond employment, Dr. Chasen emphasized that employers should reorganize their departments quickly, if necessary, to accommodate the increased quantity of paperwork they must now maintain.

* Payoff. Meticulous attention to biosafety records in the laboratory is well worth the effort. If inspectors are satisfied after examining your documentation that your department is complying with the standard, they may refrain from probing into your operations more deeply. On the other hand, haphazard or incomplete paperwork will invite further investigation of your safety procedures and could result in substantial fines, not to mention adverse publicity for your institution.

Taking record-keeping responsibilities seriously has another advantage as well. Many laboratorians, fearful of contracting AIDS and other serious diseases, are considering leaving the profession. Some already have. Employers who pay attention to all aspects of biosafety--documentation included--will improve employees' confidence and comfort. This in turn will enhance retention of valuable staff members.

Under OSHA's new standard, it is more vital than ever for employers to be well-informed, for their laboratories' sake as well as for their employees'. Employers who live by the adage "What I don't know won't hurt me" had better think again.

1. Department of Labor, Occupational Safety and Health Administration. Occupational exposure to bloodborne pathogens; final rule (29 CFR 1910. 1030), pp. 64004-64182. Federal Register, Dec. 6, 1991.
COPYRIGHT 1992 Nelson Publishing
No portion of this article can be reproduced without the express written permission from the copyright holder.
Copyright 1992 Gale, Cengage Learning. All rights reserved.

Article Details
Printer friendly Cite/link Email Feedback
Title Annotation:Occupational Safety and Health Administration; Complying with the New OSHA Regs, part 3
Author:Brown, James W.; Blackwell, Helen
Publication:Medical Laboratory Observer
Date:Jun 1, 1992
Previous Article:Technician or technologist? Sorting out overelapping roles in the lab.
Next Article:Thoughts on maternity leave from a mother-manager.

Related Articles
Here's how to keep your safety program on track.
Meet the safety regulators.
What is your OSHA IQ?
OSHA as a Regulator of Assisted Living.
RIMS and OSHA create partnership. (Property/Casualty).
Safety is not a job--but a way to work.

Terms of use | Copyright © 2017 Farlex, Inc. | Feedback | For webmasters