Safety enforcement actions are public
record and may end up in the local newspaper. Not the sort of brand enhancement the
organization is seeking.
Almost monthly we turn on the news to a
gruesome workplace shooting spree. OSHA
requires each employer to have a workplace
violence plan in place, with the requisite
If your facility has narcotics, or even
if someone might think your facility
has narcotics, there is an armed robbery
risk. Minimizing cash on hand is a good
practice. Protocols must be set, hardware (security cameras) put in place, and
employees trained, because the unthinkable
OSHA has an ergonomics safety standard
aimed at reducing the incidents of work-related musculoskeletal disorders (MSDs),
both accidental injury incidents and repetitive motion injuries. Management has a
responsibility to analyze each job and deter-mine the risks.
Healthcare is notorious for back injuries suffered while lifting and positioning
patients and for slip-and-fall accidents on
highly polished floors. OSHA requires engineering controls, work practice controls, and
personal protective equipment, all appropriate to the site. Appropriate training is
required, and there should be a feedback
loop. Injuries should be analyzed with an
eye toward preventing future injuries.
Universal precautions became a major issue
during the HIV/AIDS crisis, and by the late
1980s, universal precautions were in place
Blood-borne pathogens are infectious
microorganisms in human blood that can
cause disease in humans. The practice has a
very definite duty to protect employees from
these hazards, and also patients from secondarily acquired infections.
On a typical day, a healthcare facility is
rushed; on a non-typical day, chaos ensues.
Clinical staffers are almost always rushed,
phones are ringing, computers are beeping,
and patients are getting impatient. It is certainly easy to miss putting on a pair of gloves.
Or pass the hand washing sink.
Universal precautions are designed primarily to protect your employees, with a
secondary emphasis on protecting patients by
preventing cross contamination. And there is
a lot more to universal precautions than hands
Regulations and informational materials for
the entire OSH Act and especially blood-borne
pathogens are readily available online, 6 as
are state-specific regulations for states, which
supersede federal regulations.
The Centers for Disease Control (CDC)
has recommendations and research available,
and recommends “standard precautions” that
are more conservative than universal precautions. The regulations sort bodily fluids and
wastes into two categories: (1) blood and blood
products, and ( 2) other potentially infectious
The blood category includes blood, compo-
nents of blood, and products made with blood.
OPIM is defined by OSHA as:
…semen, vaginal secretions, cerebrospinal
fluid, synovial fluid, pleural fluid, pericar-
dial fluid, peritoneal fluid, amniotic fluid,
saliva in dental procedures, any body (sic)
fluid that is visibly contaminated with
blood, and all body fluids in situations