Teaching your staff about biosafety.
The final rule from the Occupational Health and Safety Administration to protect health care workers and other employees from exposure to bloodborne pathogens at last appeared in the Federal Register on Dec. 6, 1991. These new regulations, which took effect on March 6, 1992, outline in detail what employees must be taught about the hazards of working with potentially infectious materials and what precautions must be taken to prevent or minimize exposure.
The rules are less overwhelming than they seem at first glance. The actual standard consists of only seven pages, preceded by 171 pages of discussion. Furthermore, OSHA made few changes from the proposed standard, which, for the most part, was already being enforced under the "general duty" clause.
This article will discuss employee training requirements under the new regs and offer suggestions for making educational sessions more effective - even fun. Articles in subsequent issues of MLO will cover the procedures that laboratorians are expected to follow in the workplace and how professionals are setting up their biosafety records to comply with OSHA'S standard.
* Training. According to the standard, any employee who may have contact with blood or other body fluids must receive free biosafety training during working hours. New employees should be given classes as part of their initial orientation; other staff members should be offered instruction immediately or as soon as they transfer to a department where they may be exposed to potentially dangerous materials.
Training must be fully implemented by June 4 of this year, followed by annual refresher courses. Although it's not mandatory, some employers require training for all employees, including top administrators. This way, in case a nonlaboratorian comes in contact with dangerous materials while passing through the lab, appropriate precautions will be taken.
During a telephone interview, James W. Stanley, regional administrator for OSHA, emphasized to MLO that training sessions must be "meaningful" - that is, presented in a way that will be clearly understood by those being taught. Their language, extent of literacy, and educational level is to be taken into consideration.
OSHA has stipulated that training sessions provide "an opportunity for interactive questions with the person conducting the training session." Simply sending laboratorians to watch a videotape or asking them to sign a form stating that they have read the safety policy will not suffice.
Instructors must be "knowledgeable" about the subject matter. They must demonstrate the use and location of all personal protective equipment. The sessions should include a review of work practice and engineering controls such as portable benchtop biosafety shields.
In the past, instruction in cleaning and disinfecting workstations and protective equipment, such as face shields and goggles, has often been neglected. That cannot happen any more. Formalized training must also include what to do in case of a spill or exposure involving blood. Emphasis should be placed on the importance of washing hands after removing gloves and lab coats and of wearing a completely buttoned lab coat at all times while in the laboratory.
All aspects of biosafety training must be documented. OSHA'S attitude resembles that of most agencies that conduct inspections: If it isn't documented, it didn't happen. Records must contain the dates on which training was provided, a summary of the content of each class, the names and qualifications of all instructors, and the names and job titles of all employees who attended. (Part Ill of this series will discuss such documentation in more detail.)
OSHA inspections are analogous to tax audits in that employers never know when a representative will visit the lab. Therefore, it is vital that training documentation be accurate, up to date, and readily available at all times. These records must remain on file for three years.
* Exposure-control plan. By May 5, 1992, every employer will be required to have a written plan designed to eliminate or minimize worker exposure. The document must include all job classifications and job tasks in that place of employment that could lead to occupational exposure and the names of workers at risk of exposure to infectious materials.
The plan should outline the employer's hepatitis B vaccination program, which must be in place by July 6 of this year. Employers are required to offer, at their expense, a vaccine to any worker who may at any time be exposed to potentially infectious materials. Staff members may waive their right to the vaccine by signing a form; however, they are entitled to change their minds, at which point they must be given a vaccine as soon as possible.
Documentation on this program should include the names of employees who have received the vaccine and those who have refused it, a tactic for initiating appropriate medical follow-up, and a plan for counseling if exposure takes place. All of this must be communicated to the employee upon initial employment or transfer to a position involving potential exposure and then at least annually thereafter for the duration of employment at that facility.
* Teaching tips. Frequently lab managers conduct training sessions by reviewing regulations without making the lesson relevant to employees at the bench. With some creative planning, however, biosafety training can be an enjoyable experience. Here are some suggestions for keeping your students attentive and eager to learn.
Presenting a simple slide show at your first session is a good way to begin training. Photographs are invaluable in enhancing the quality of your presentation. if you choose this route, take pictures of your own facility. Employees need to be shown the actual setting and equipment they will use. They will enjoy seeing themselves and their colleagues "in action" and will identify more closely with the instruction than they would with generic pictures.
Vary the format. Don't use only slides or videotapes, or spend the entire time lecturing at a podium. Props break up the monotony of a verbal presentation and provide another dimension of learning. To show how the proviral DNA of the human immunodeficiency virus incorporates into the human host DNA, we use toy railroad tracks painted different colors.
Demonstrate proper procedures step by step. Encourage employees to learn them through hands-on activities; people are less likely to forget procedures that they have performed themselves. After showing employees how to remove gloves without contaminating their hands we give each participant a pair and ask them to practice until they get it right.
We stress that contaminated broken glassware must never be picked up with the hands, even if gloves are worn. Then we simulate a spill and demonstrate cleaning up broken test tubes with tongs or forceps, discarding debris in a sharps container, and disinfecting the contaminated area. Again, employees participate.
It is helpful to provide information beyond what is strictly needed for protection in the workplace itself. We explain to our classes all the ways in which HIV and HBV can be transmitted - those related to sexual activity and IV drug use as well as modes of occupational exposure. To wake up our audience, we deliberately place this discussion in the middle of the presentation. When you talk about sex, you get everyone's attention!
* There will be a quiz. To gauge retention of key areas, we administer a biosafety quiz before each training session and again immediately afterward (Figure 1). The quiz includes only a few challenging questions. We believe that it is more constructive to make training fun and spark employees' interest than to intimidate them or highlight their ignorance. Participation is the goal.
Employees grade their own tests. Although the tests are filed away as proof to OSHA that training has taken place, the scores are not recorded and employees are not penalized for doing poorly. They have presumably learned from their incorrect answers. During a preliminary study of 179 employees who took the quiz, the median score was 66% for the pretest, 99% for the post test, and 93% in a retest 30 days later.
* Commonsense safeguards. A major criticism of the universal precautions created by the Centers for Disease Control is that they are too vague and therefore difficult to teach. The proper use of universal precautions requires employing common sense as well as basic biosafety principles based on individual work environments.
[paragraph] Warning labels. OSHA has mandated that employers must use warning labels and signs to communicate hazards to employees. For example, fluorescent orange or orange-red labels bearing the international biohazard symbol must be placed on refrigerators, freezers, containers of medical waste, and other containers used to ship potentially infectious materials. In some instances, red bags and red containers may be used instead of labels.
[paragraph] Gloves. Besides learning to use gloves routinely when processing specimens, laboratorians must be reminded that as long as their gloves are on, they will contaminate whatever they touch. Those who answer the telephone while wearing gloves will contaminate not only their own faces but also those of whoever subsequently uses the phone, gloved or not. The other side of the issue is important to note as well; some laboratorians place labels on telephones saying, "Clean instrument - NO gloves."
We teach lab workers the "clean hand-dirty hand" technique. We show them how to hold a test tube rack with a gloved hand while opening a door with the other hand, which is ungloved. This practice makes it safer for the next person who touches the door without wearing gloves.
[paragraph] Lab coats. Laboratorians must be taught when to wear lab coats and when to take them off. OSHA has stated that "all personal protective equipment shall be removed prior to leaving the work area." Once the agency starts handing out hefty fines for ignoring this mandate, laboratory workers will think twice before wearing their lab coats to the cafeteria.
* Practice what you preach. Following biosafety rules should become a habit for all employees at your facility. All too often, management makes a firm commitment to biosafety during the training process and then fails to follow up on procedures or stick to the rules themselves. As long as managers and supervisors enforce health and safety policies consistently, professionalism prevails; otherwise, employees are apt to become lax.
OSHA'S new standard will help change the face of the clinical laboratory profession. These lifesaving regulations are long overdue.
Reprints of the final rule, "Occupational Exposures to Bloodborne Pathogens," can be obtained through the OSHA Office of Publications, U.S. Department of Labor, Room N 3101, 200 Constitution Ave., NW, Washington, DC 20210. The agency's telephone number is (202) 523-9667.
[1.] Department of Labor, Occupational Safety and Health Administration. Occupational exposure to bloodborne pathogens; final rule (29 CFR 1910. 1030). Federal Register, pp. 64004-64182, Dec. 6, 1991. [2.] Brown, J.W., and Haider, M. Universal precautions and biosafety in the clinical laboratory: A model for training laboratory personnel. Abstract #9090, presented at the 117th Annual Meeting of the American Public Health Association, Chicago, Oct. 24, 1989. [3.] Centers for Disease Control. Update: Universal precautions for prevention of transmission of HIV, HBV, and other bloodborne pathogens in health-care settings. MMWR 37:377-388, 1988.
Dr. Brown, a member of MLO'S Editorial Advisory Board, is director of microbiology and of health and environmental affairs at Roche Biomedical Laboratories, Raritan, N.J , where Blackwell is associate manager of health and environmental affairs.
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|Title Annotation:||part 1; compliance with new Occupational Safety and Health Administration regulations on infectious wastes|
|Author:||Brown, James W.; Blackwell, Helen|
|Publication:||Medical Laboratory Observer|
|Date:||Apr 1, 1992|
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