BSM Connection Distance Learning Course

BSM Connection Distance Learning Course OSHA: Bloodborne Pathogens and Hazard Communication Training 2010-2014, BSM Consulting All rights reserved.

Table of Contents OVERVIEW... 1 BLOODBORNE PATHOGENS... 1 Key Information: Bloodborne Pathogens... 1 Exposure Control Plan... 2 Protective Procedures (Work Practice Controls)... 2 Management of Blood Spills and Contaminated Surfaces... 4 Management of Regulated Waste... 6 Hepatitis B Vaccination Protocols... 7 Exposure Incident: Reporting and Evaluation... 7 Record Keeping... 8 HAZARD COMMUNICATION STANDARD... 9 Introduction to HCS Revisions... 9 New Labels... 10 Safety Data Sheet (SDS)... 11 CONCLUSION... 13 APPENDIX OSHA Glossary: Bloodborne Pathogens... 14 COURSE EXAMINATION... 17 2010-2014, BSM Consulting

OVERVIEW In 1971, the federal government of the United States created the Occupational Safety & Health Administration (OSHA) to prevent work-related injuries, illnesses, and deaths. The agency establishes safety standards and can levy fines against noncompliant companies. OSHA has established such standards for medical practices and facilities, and all health care businesses must comply with OSHA standards regardless of the number of employees or the location. Every employee must understand the guidelines set forth by OSHA. OSHA guidelines, standards, and regulations cover an extremely wide sphere of topics and subject areas. The primary objectives of this particular course are to acquaint medical office employees with the Bloodborne Pathogens and Hazard Communication Standards and to educate employees on the importance of compliance with these standards. The educational information in this course is intended specifically for the employee working in a medical office or clinic. Medical employees are required to participate in training, regardless of their job descriptions. OSHA training is required at the time of hire, and retraining is mandatory annually thereafter. In addition to the educational material provided by this course, consultation with practice management regarding specific policies and procedures in the practice is essential. BLOODBORNE PATHOGENS The term bloodborne pathogen refers to any microorganism present in human blood that can cause disease in humans. Bloodborne pathogens include, but are not limited to, hepatitis B virus (HBV) and human immunodeficiency virus (HIV), the cause of AIDS. Health care workers with direct exposure to blood and other potentially infectious material on the job risk contracting bloodborne infections from HBV, HIV, and other pathogens. According to OSHA, approximately 8,700 health care workers each year are infected with HBV, and 200 die annually from the infection. OSHA requires all health care workers to be educated and informed of exposure risk while performing job duties. Following the OSHA standards for protection and prevention greatly reduces risk for potential exposure to bloodborne infections. Understanding the OSHA standard for bloodborne pathogens is important to the protection of each employee. Any situation, question, or concern must immediately be brought to the attention of management. ARE TEARS DANGEROUS? Tears are not considered infectious. While HIV has been found in tears, it is not concentrated in an amount sufficient for transmission through tear fluid. Key Information Bloodborne Pathogens The following information will help health care personnel better understand bloodborne pathogens in the workplace: Routes of transmission. Bloodborne pathogens can enter the body via needlestick, cuts made by contaminated instruments or glass, or through abraded skin. They also can enter if a splash occurs on the eyes, nose, or mouth. Types of body fluid. Blood is the most risky fluid. Bloody body fluids are more risky than body fluids without blood. HIV-infected patient. The amount of circulating virus in patient blood is highest when the patient has advanced AIDS and/or is experiencing acute anti-retroviral syndrome. Almost all seroconversions (presence of HIV antibody in the blood) occur when the patient is symptomatic with a high viral load or has advanced AIDS. 2010-2014, BSM Consulting 1

Exposure Control Plan An exposure control plan (ECP) describes the rationale, policies, procedures, and interventions available for employees who have potential for exposure to blood or other potentially infectious materials during the normal course of work. Every practice or facility must maintain an ECP that includes the following information: 1. Identification of various job titles/duties and exposure levels (For example: Receptionist Limited exposure to infectious materials and waste) 2. Engineering and work practice controls a. Sharps containers and handling of sharps b. Use of personal protective equipment c. Housekeeping guidelines 3. Instructions for decontamination, transportation, and disposal of biohazardous material 4. Hepatitis B vaccination protocols 5. Exposure incident: reporting and evaluation 6. Evaluation of new, safer medical devices (sharps safety evaluation) 7. Hazard communication standards 8. OSHA/Bloodborne Pathogens Glossary EXAMPLES OF EMPLOYEE EXPOSURE DETERMINATION LOCATED IN THE ECP JOB TITLE(S) DEPARTMENT TASK Surgical Technician Surgical Assistant Clinical Exposure to infectious material and waste Receptionist Clerical Little to no exposure to infectious material and waste Medical Assistant Angiographer Clinical Exposure to infectious material and waste Scribe/Assistant Clinical/Clerical Exposure to infectious material and waste Protective Procedures (Work Practice Controls) To ensure the health and safety of all staff and patients, the medical practice provides and/or teaches employees about work practice controls that will greatly eliminate the risk of exposure to bloodborne pathogens while performing required job duties. The following procedures are required by the OSHA standard and by all medical practices, regardless of size: Handwashing Frequent handwashing is the single most important defense in preventing the spread of infection. Each employee is required to wash with hot, soapy water 1) after each patient contact, 2) after leaving the clinical area and returning to the job, and 3) after using the restroom. Handwashing after removal of gloves or other personal protective equipment is also required. For best results, wet hands with hot water, apply soap, and rub together for at least 20 seconds. (This is equivalent to singing the song Happy Birthday twice.) 2010-2014, BSM Consulting 2

The medical office is required to: Provide handwashing sinks that are readily accessible to all employees, or: Provide an antiseptic hand cleanser, antiseptic towelettes, or hand sanitizer. Note: Employees should wash hands with soap and running water as soon as is reasonable when antiseptic hand cleansers or towelettes are used. Cleaning Medical Equipment After each exam, it is essential that equipment in the exam room is cleaned and dried. Thoroughly wipe with alcohol any surface that came in contact with the patient. Be sure the alcohol is completely dry prior to reuse. At the end of the day and upon opening each morning, repeat this procedure. Many practices clean the equipment in the presence of the patient. When a patient has an infection, or if blood is visible on any surface, do not reuse equipment until it is properly cleaned with an appropriate disinfectant solution, such as Cidex. Contact your manager for assistance and follow the manufacturer s guidelines to avoid damaging sensitive medical instruments and to ensure that proper OSHA guidelines have been followed. Proper Handling and Disposal of Needles and Sharps Needles (and other contaminated sharps or scalpels) must not be bent, recapped, or removed from the syringe unless the practice can demonstrate that no alternative is feasible or that such action is required by a specific medical procedure. Remember: Shearing or breaking of contaminated needles is prohibited. Using needleless systems and self-sheathing needles to the extent possible is required by OSHA. If bending, recapping, or needle removal is necessary, the use of a mechanical device or a one-handed technique is required. Immediately after use, contaminated, reusable sharps (such as scissors, tweezers, scalpels, etc.) shall be placed in appropriate containers until properly cleaned and sterilized. Reusable sharps contaminated with blood or other potentially infectious materials may not be stored or processed in a manner that requires employees to reach by hand into the container. When soaking sharp instruments, place sharp end into the container with handle exposed for safe removal. Remember: Never attempt to reach into a sharps container for any reason! Disposable sharps containers must be: Puncture resistant. Labeled and color-coded (red) in accordance with this standard. Leakproof on the sides and bottom. Kept out of the reach of children or confused patients. Closed when contents reach the fill line indicator on the container. IMPORTANT REMINDER FOR ALL MEDICAL STAFF: Eating, drinking, smoking, and applying cosmetics or lip balm are prohibited in work areas where there is a reasonable likelihood of occupational exposure. Closed immediately prior to removal or replacement to prevent spillage or protrusion of contents during handling, storage, transport, or shipping. Disposed of properly. Containers may not be discarded in ordinary residential waste receptacles. Labeled with the universal biohazard label (typically on the container) and dated. 2010-2014, BSM Consulting 3

Storing Medications and Specimens Food and medications may not be stored in the same cupboard or refrigerator. Specimens (such as tissue for biopsy) must be placed in a leakproof container and labeled with name, date, and contents. Utilizing and Wearing Personal Protective Equipment Personal protective equipment (PPE) is provided to employees at no cost to the employee. The medical office typically performs only minor procedures in the office. The most common PPE worn by the clinical employee is gloves and a mask. Occasionally, eye protection and/or a lab coat may be worn. If splashing is possible, wearing goggles or a face shield as additional PPE is recommended. Familiarize yourself with the locations of required PPE in the clinic. PPE is considered appropriate only if it does not permit blood or other potentially infectious materials to pass through it. The concept of universal precautions is an approach to infection control and must be observed to prevent contact with blood or other potentially infectious materials. According to universal precautions, all human blood and certain human body fluids are treated as if known to be infectious for HIV, HBV, and other bloodborne pathogens. Under circumstances in which differentiation is difficult or impossible, all body fluids must be considered potentially infectious materials, and PPE should be used according to the potential exposure risk. Repairing and Replacing PPE The practice is responsible for providing, repairing, or replacing PPE as needed to maintain its effectiveness. Remove PPE if it becomes contaminated and before leaving the work area. Replace gloves if torn, punctured, contaminated, or compromised in any way. Applying and Wearing Gloves If there is an expectation for contact with blood or other potentially infectious materials, such as mucous membranes, nonintact skin, or when performing a procedure requiring infusion using a butterfly or an IV, gloves are required. Wear gloves whenever handling or touching contaminated or potentially contaminated items or surfaces. Disposable (single-use) gloves must be replaced as soon as practical when contaminated, torn, punctured, or when their ability to function as a barrier is compromised. Never wash or attempt to decontaminate disposable (single-use) gloves for reuse. Hypoallergenic gloves or other similar alternatives shall be readily accessible to those employees who are allergic to the gloves normally provided. Always remove soiled gloves by grasping the cuff and peeling the glove down (inside-out and over the hand) in case there is any infectious material present on the glove. Avoid touching the outside of the glove during removal. Require that gloves be worn if the employee has cuts, scratches, or other breaks in the skin. Place soiled PPE in an appropriately designated area or container for storage, washing, decontamination, or disposal. Management of Blood Spills and Contaminated Surfaces Each employee must become familiar with the policies and procedures for proper handling and removal of any potentially hazardous material. When an incident occurs that involves a blood spill or contaminated waste, employees must notify the supervisor. 2010-2014, BSM Consulting 4

Work surfaces that become contaminated must be decontaminated with an approved disinfectant, such as Cidex, after completion of all routine procedures and immediately after contamination or any spill of blood or other potentially infectious materials. Work surfaces must be cleaned at the end of the work shift. Broken glassware, which may be contaminated, must not be picked up directly with the hands. For cleanup, use a mechanical means, such as a plastic broom, brush and dustpan, tongs, or forceps. It is important to note that, due to potential risk, an employee who has not had the Hepatitis B vaccination series should not handle a blood spill or potentially contaminated material. A manager or supervisor should be contacted immediately for assistance. Spill Kit Each employee must know where the spill kit is located in the office. The practice may utilize a commercially designed spill kit or one produced by the practice for cleaning up contaminated waste. See the accompanying table for instructions in making a noncommercial spill kit. TIPS ON MAKING A SPILL KIT FOR THE MEDICAL OFFICE Containers PPE Absorbent Materials Tools Disinfectant/ Cleaning Solution (Recommended by CDC) Plastic container with sealable lid; five-gallon bucket or container (e.g., Rubbermaid container); (2) heavyweight five-ply trash bags; biohazard labels; (2) red biohazard bags. Two pairs of disposable gloves; mask, goggles or face shield; plastic or rubber shoe covers; lab coat or apron; Playtex rubber gloves. Spill pads, absorbent pads, such as linen savers with plastic back; paper towels for small spills. Plastic dustpan; plastic broom or brush; tongs/ forceps for handling broken glass. Diluted household bleach can be used to wipe and clean most equipment (check with manufacturer prior to use). EPA-approved disinfectants (such as Cidex) are to be used for blood spills. Read the label and carefully follow manufacturer s directions. Bleach dilution of 1:10 (1 part bleach to 10 parts water). Solution may not be effective after bleach is diluted for 24 hours. Note: Contact time for bleach is generally considered as the time it takes the product to air dry. The following steps will assist in cleaning up a blood spill or other contaminated waste: MANAGING BLOOD SPILLS Basic instructions for managing blood spills are as follows: Put on gloves. Remove any sharp objects with forceps or other mechanical device. Saturate the spill with a 1:10 bleach solution. Let stand 15 20 minutes. Wipe up the spill with a paper towel. Discard gloves and paper towels into a red biohazard bag. Red biohazard bags are indicated for non-sharps waste that is contaminated and distinguishable from general waste. They must be two-ply thickness and labeled with a biohazard symbol. These are to be disposed of in accord with local regulations regarding disposal of biohazardous materials. 2010-2014, BSM Consulting 5

Management of Regulated Waste An employee may be responsible for waste removal from the medical office. Therefore, all employees must learn to recognize and understand how to differentiate residential waste from biohazardous waste. The following table is designed as a tool to assist the employee with understanding the difference between residential and biohazardous waste. Residential waste or municipal waste may be discarded in the usual manner. Biohazardous waste contains blood or other potentially contaminated waste and must be handled according to OSHA standards described throughout this program. If there is any question or reason to suspect biohazardous waste, then the waste should be regarded as biohazardous and handled accordingly. A GUIDE FOR ASSISTING IN PROPER IDENTIFICATION OF MEDICAL WASTE Residential/Municipal Waste Biohazardous Waste (Use red biohazard bag for disposal) Paper towel used to dry hands following glove removal Used disposable gloves worn assisting doctor (no visible blood or other soiling) Drape used to cover Mayo stand no visible contamination; no soiling occurred during procedure Band-Aid or cotton ball used as pressure dressing after IV removal drop of blood Paper towel used to absorb blood from countertop prior to disinfecting surface Used disposable gloves worn by the surgeon during a lesion removal with a significant amount of visible blood Drape used to cover Mayo stand contaminated with blood from instruments and tissue samples Band-Aid or cotton ball or gauze saturated with blood following a procedure Documentation of Proper Removal of Hazardous Waste A licensed waste removal contractor is required to dispose of contaminated waste (biohazardous waste). A receipt must be provided to verify that the waste was removed from the office. Receipts must be kept on file to document proper waste disposal. After receiving a waste receipt, the employee must give it promptly to management for recording. In the medical office, biohazardous waste (such as blood, secretions, or tissue) must be placed inside a red biohazard bag, and then the red bag(s) and/or filled sharps containers should be placed into a biohazardous waste box. Biohazardous waste boxes are provided by the company that removes the box. Important Information on Chemotherapeutic Agents In the ophthalmic practice, chemotherapeutic agents are sometimes used and must be disposed of in a yellow container or, if used infrequently, add a yellow chemotherapeutic waste label to a red waste container. Contaminated Sharps: Discarding and Containment Contaminated sharps must be discarded immediately (or as soon as is feasible) in sharps containers, as described earlier in the section titled: Proper Handling and Disposal of Needles and Sharps. Never place full sharps containers and red bags into residential or municipal trash containers. Communicating Hazards Red bags or red containers with the biohazard symbol also may be used to provide a warning of regulated waste contents. The biohazard symbol shown here is used to identify potentially infectious material. Warning signs must be predominantly red or fluorescent orange with lettering and symbols in a contrasting color. Universal Biohazard Warning Symbol (All warning signs must contain the name of the infectious agent.) 2010-2014, BSM Consulting 6

Hepatitis B Vaccination Protocols For employees who have a risk to exposure, the best defense against HBV is vaccination. This vaccination must be offered shortly after hire as indicated by the job responsibilities for the ophthalmic employee. The employer is not required to provide the HBV vaccine to an employee who works in a job where the employee is not at risk for exposure. The vaccination for HBV is a series of three injections. The first dose is given followed by a second dose one month later. The third dose is administered six months after the initial dose. More than 90% of those vaccinated develop immunity to the HBV. The medical practice shall ensure that the health care professional responsible for the employee s HBV vaccination is provided a copy of the OSHA bloodborne pathogen regulation. The practice is not required to provide the HBV vaccination in the following situations: An employee has previously received the complete HBV vaccination series. Antibody testing has revealed that the employee is immune. The vaccine is contraindicated for medical reasons. The HBV vaccine is genetically engineered, nonreplicative, and safe. More than 90% of those vaccinated develop immunity to the HBV. If the employee initially declines Hepatitis B vaccination but later decides to accept the vaccination while still covered under the standard, the medical practice must make the HBV vaccination available at that time. Employees who decline to accept HBV vaccination offered by the employer are required to sign a statement appropriately documenting the declination. If a routine booster dose(s) of HBV vaccine is recommended by the U.S. Public Health Service at a future date, such booster dose(s) shall be made available in accordance with OSHA guidelines. Exposure Incident: Reporting and Evaluation Each employee must become familiar with the policies and procedures for proper handling and removal of any potentially hazardous material. An employee is considered to be exposed if injured with a contaminated needle, scalpel, or other sharp instrument or has direct exposure through a cut or break in the skin. If a mucous membrane is penetrated with contaminated blood or body fluids on a potentially infected person, this is considered an exposure incident. When an exposure occurs that involves a blood spill or contaminated waste, employees must immediately notify a supervisor. Immediately take these steps following exposure: 1. Remove bloodborne pathogen. EXPOSURE STEPS 2. Sharps exposure wash thoroughly with soap and water. 3. Mucous membrane exposure flush with copious amounts of water. 4. Report immediately to supervisor. 5. Report within one to two hours of exposure to the local emergency room or designated health provider for post-exposure evaluation and treatment. 6. Follow treatment plan of health provider, which may include prophylactic medication. Reporting Each incident must be investigated thoroughly and the circumstances surrounding the incident reviewed carefully. This investigation will include the reporting of information pertaining to engineering controls in place at the time of the incident, determining compliance with policies and procedures, description of any devices involved, determination of usage of proper PPE, location of the incident, type of procedure being performed, and a review of the employee s training. 2010-2014, BSM Consulting 7

Post-Exposure Evaluation Reporting an exposure incident right away is vital. Immediate intervention can forestall the development of HBV, HCV, or enable an affected employee to track potential HIV infection. Prompt reporting can help avoid spreading bloodborne infections to others. All exposure incidents will be kept confidential, and follow-up care and treatment, if required, will be maintained in the employee s confidential medical file. Below is a sample checklist: Date BLOODBORNE PATHOGENS POST-EXPOSURE CHECKLIST Post-Exposure Follow-Up Accident report (worker s comp form)/sharps Injury Report completed. Consent to test the source individual identified and obtained. Source individual tested for HCV, HBV, and HIV. Exposed employee tested for HBV, HCV, and HIV, if indicated. Exposed employee offered the HBV vaccination again, if initially declined. Employee referred to health care provider and given: o A copy of the accident report (worker s comp form)/sharps Injury Report o Results of the source individual s testing (if applicable) Health care provider given the source individual s test results. Written opinion from health care provider received within 15 days of the evaluation. Employee medical record is stored in a confidential location. Circumstances of the exposure incident are reviewed to determine whether modifications are needed to bloodborne pathogens policies and procedures. RECORD KEEPING OSHA requires accurate documentation of not only medical records, but also of training provided to employees. The sections below describe record keeping required by OSHA. Medical Records Medical records required by the OSHA standard shall be maintained in accordance with OSHA requirements. Furthermore, they shall be maintained within the employee s confidential medical record that is kept with the employee s supervisor or with human resources. Training Records Training records are completed for each employee upon the completion of this training course. These documents are kept for a minimum of three years. The training records include: Dates of training sessions Contents or summary of training sessions Names and qualifications of persons conducting the training Names and job titles of all persons attending the training Required Posting The practice is required to post a notice annually that informs employees of any accidents that have involved exposure risk. This Log of Work-Related Injuries or Illnesses is completed when an employee is exposed to potential contamination due to a needlestick or other injury involving a sharp (such as a scalpel). If an employee is cut or stuck with a clean sharp, no recording on the OSHA log is required. 2010-2014, BSM Consulting 8

An OSHA 300 log must be posted in a visible place from February 1 through April 30 each year. When an employee has an exposure incident, the OSHA 301 (incident report form) shall be completed and maintained by the employer. REVIEW The following is a review of several of the key takeaway tips contained in this portion of the course: 1. Always practice standard precautions assume all blood, bloody body fluids, and tissue are positive for bloodborne pathogens such as HIV, hepatitis B, and hepatitis C. 2. Obtain free hepatitis B vaccine and quantitative titer. 3. If exposure occurs, wash or flush area, report incident to immediate supervisor, and access emergency room within one to two hours of exposure. 4. Remember the risk rule of three: a. Hepatitis B: 30% b. Hepatitis C: 3% c. HIV: 0.3% 5. Use PPE according to protocols: a. Wear gloves to decrease inoculum from sharps injury. b. Wear gowns, face shields, and gloves to decrease extent of mucous membrane or skin exposure. 6. Eliminate risky practices: a. Do not recap needles. b. Do not overfill sharps containers. 7. Do not attempt invasive skills without training and/or supervision. 8. Dispose of sharps and other contaminated waste in identifiable biohazardous containers. HAZARD COMMUNICATION STANDARD Introduction to HCS Revisions In addition to the Bloodborne Pathogens Standard, OSHA has many other standards to protect employees in the workplace. The Hazard Communication Standard, or HCS, covers the proper handling, moving, and storage of hazardous chemicals in the workplace. Although hazardous chemicals are limited in ophthalmic practices and ambulatory surgery centers (ASCs), the danger is very real if an employee is exposed to a hazardous chemical. In March of 2012, OSHA made two significant changes to the Hazard Communication Standard and it is important that employees understand the new labeling elements and standardized format for the Safety Data Sheets (SDSs), formerly known as Material Safety Data Sheets (MSDSs). These new changes have been made to improve understanding of hazards associated with chemicals in the practice or workplace. The required training on the Hazard Communication Standard begins in December 2013 and continues through June 1, 2016. The goal of this portion of OSHA training is to prepare employees and to help them understand the changes. Likely, most employees have already seen the new labels on chemical products and along with any product purchased or brought into the facility there should be a Safety Data Sheet (SDS). 2010-2014, BSM Consulting 9

New Labels Labels on chemical products assist employees in doing their job safely. For example, labels are used to ensure proper storage or to quickly locate first aid information when needed by an employee or emergency personnel. Product Identifier New labeling includes the chemical name, code or batch number, and perhaps other pertinent information about the chemical. The manufacturer or distributor can decide the appropriate product identifier. The same product identifier must be on both the label and in Section 1 on the SDS (see information below on Identification). Signal Word A signal word is used to indicate the relative level of severity of hazard and alert the reader to a potential hazard on the label. There are only two signal words that will be used: DANGER and WARNING. Within a specific class, DANGER is used for the more severe hazards, and WARNING is used for the less severe hazards. Note: Each label will only contain one signal word no matter how many hazards a chemical may have. If one of the hazards warrants a DANGER signal word, while another warrants the signal word WARNING, then only DANGER should appear on the label. Pictogram OSHA s required pictograms must be the shape of a square set to a point and include a black hazard symbol on a white background with a red frame sufficiently wide enough to be clearly visible. A square red frame without a hazard symbol is not permitted on the label. OSHA has designated eight (8) pictograms under this new standard for application to a hazard category. 2010-2014, BSM Consulting 10

Hazard Statement(s) Hazard statements describe the nature of the hazard(s) of a chemical including, where appropriate, the degree of the hazard. For example: Causes damage to kidneys through prolonged or repeated exposure when absorbed through the skin. All of the applicable hazard statements must appear on the label. The hazard statements are specific to the hazard classification categories and chemical users should always see the same statement for the same hazards, no matter what the chemical is or who produces it. Precautionary Statements A precautionary statement is a phrase that describes recommended measures that should be taken to minimize or prevent negative effects resulting from exposure to a hazardous chemical or improper storage or handling. Name, Address, and Telephone Number The manufacturer, distributor, or importer must have this information on the label. Whenever a chemical has multiple hazards, different pictograms are used to identify the hazards. You should expect to see the appropriate pictogram for the corresponding hazard class when working with chemicals in performing your job duties. The precautions on the label are closely related to the Safety Data Sheet (SDS). Safety Data Sheet (SDS) The HCS requires chemical manufacturers, distributors, and importers to provide Safety Data Sheets (SDSs) to communicate the dangers of hazardous chemical products. As previously mentioned, the SDSs were formerly known as Material Safety Data Sheets (MSDSs). The content included in the Safety Data Sheets (SDSs) is valuable information to provide to new employees who will use or handle hazardous chemicals or material. Sections 1 8 of the Safety Data Sheet (SDS) provide general information about the chemical including, identification, hazards, composition, safe-handling practices, and emergency-control measures (e.g., firefighting). This information should be helpful to those that need to obtain the information quickly. Sections 9 11 and 16 contain other technical and scientific information, such as physical and chemical properties, stability and reactivity information, toxicological information, exposure control information, and other information including the date of preparation or last revision. The SDS must also state that no applicable information was found when the preparer does not find relevant information for any required element. To be consistent with the UN Globally Harmonized System of Classification and Labeling of Chemicals (GHS), the SDS must also contain Sections 12 15. However, OSHA will not enforce the content of these sections because the content is associated with matters that are handled by other agencies. Employers must ensure that SDSs are accessible to employees at all times. As of June 1, 2015, the HCS will require new SDSs to be in a uniform format and include the section numbers, the headings, and associated information listed under these headings: Section 1 Identification. This includes: Product identifier. Manufacturer or distributor name. Address. Phone number. Emergency phone number. Recommended use. Restrictions on use. 2010-2014, BSM Consulting 11

Section 2 Hazard(s) identification. This includes: All hazards regarding the chemical. Required label elements. Section 3 Composition/information on ingredients. This includes: Information on chemical ingredients. Trade secret claims. Section 4 First-aid measures. This includes: Important symptoms/effects, both acute and delayed. Required treatment. Section 5 Fire-fighting measures. This includes: Suitable extinguishing techniques. Equipment. Chemical hazards from fire. Section 6 Accidental release measures. This includes: Emergency procedures. Protective equipment. Proper methods of containment and cleanup. Section 7 Handling and storage. This lists precautions for safe handling and storage, including incompatibilities. Section 8 Exposure controls/personal protection. This includes: OSHA's Permissible Exposure Limits (PELs). Threshold Limit Values (TLVs). Appropriate engineering controls. Personal protective equipment (PPE). Section 9 Physical and chemical properties. This lists the chemical's characteristics. Section 10 Stability and reactivity. This lists chemical stability and possibility of hazardous reactions. Section 11 Toxicological information. This includes: Routes of exposure. Related symptoms. Acute and chronic effects. Numerical measures of toxicity. Section 12 Ecological information* Section 13 Disposal considerations* Section 14 Transport information* Section 15 Regulatory information* 2010-2014, BSM Consulting 12

Section 16 Other information. This includes the date of preparation or last revision. *Note: Since other agencies regulate this information, OSHA will not be enforcing Sections 12 15 (29 CFR 1910.1200(g)(2)). The Hazard Communication Standard applies to workers in the ophthalmic practice and the ASC. Depending upon your policies and procedures, products will vary from facility to facility. CONCLUSION All employees must take necessary precautions while performing job duties to limit the risk of exposure to bloodborne pathogens and hazardous chemicals. While OSHA sets forth safety guidelines and the practice provides the associated training and safeguards, it is up to each employee to understand and embrace these safe practices while carrying out job responsibilities. Employees must remember to report any hazard or potential risk to management immediately and to follow established safety guidelines to protect both patients and employees. 2010-2014, BSM Consulting 13

APPENDIX 2010-2014, BSM Consulting 14

OSHA GLOSSARY: BLOODBORNE PATHOGENS TERM NAME Bloodborne Pathogen Contaminated Contaminated Sharp Disinfectant Engineering Controls Exposure Incident HBV HCV HIV Needleless System Occupational Exposure OPIM OSHA Parenteral PPE DEFINITIONS A disease-causing microorganism present in human blood that includes, but is not limited to: hepatitis B virus (HBV), hepatitis C virus (HCV), and the human immunodeficiency virus (HIV). The presence, or the reasonably anticipated presence, of blood or other potentially infectious materials on an item or surface. Any object with blood, bloody body fluids, other body tissues, or other potentially infectious materials that can penetrate the skin, including, but not limited to: needles, scalpels, broken glass, broken capillary tubes, and broken plastic. A chemical agent that inactivates most recognized pathogenic microorganisms. Devices that isolate or remove the bloodborne pathogen hazard from the workplace. They include sharps containers, self-sheathing needles, and safer medical devices, such as sharps with engineered sharps-injury protection and needleless systems. A specific event occurring during the performance of an employee s duties involving eye, mouth, other mucous membranes, non-intact skin, or parenteral contact with blood or other potentially infectious tissue or material. Hepatitis B virus. Hepatitis C virus. Human immunodeficiency virus. A procedural device that does not use needles for: 1) the collection of bodily fluids or withdrawal of body fluids after initial venous or arterial access is established; 2) the administration of medication or fluids; or 3) any other procedure involving the potential for occupational exposure to bloodborne pathogens due to percutaneous injuries from contaminated sharps. Reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that occurs during the performance of an employee s duties. Other potentially infectious materials. Includes body fluids; any unfixed tissue or organ from a human; cell tissue; organ cultures; HIV-, HBV-, and HCV-containing culture medium or other solutions; blood, organs, or other tissues from experimental animals infected with HIV, HBV, or HCV. Occupational Safety & Health Administration. OSHA s mission is to prevent workrelated injuries, illnesses, and deaths. Since the agency was created in 1971, occupational deaths have been cut by 62%, and injuries have declined by 42%. Piercing of mucous membranes or the skin barrier through such events as needlesticks, cuts, and abrasions. Personal protective equipment. Specialized clothing or equipment worn by an employee for protection against a hazard. General work clothes (e.g., scrubs, uniforms, pants, shirts, or blouses) not intended to function as protection against a hazard are not considered personal protective equipment. PPE includes, but is not limited to: gloves, mask, gown, apron or lab coat, shoe covers, goggles, face shield, etc. 2010-2014, BSM Consulting 15

Regulated Waste Sharps With Engineered Sharps Injury Protections Standard Universal Precautions Sterilize Sterilization Work-Practice Controls 1) Liquid or semi-liquid blood or other potentially infectious material; 2) any contaminated item that would release blood or other potentially infectious material in a liquid or semi-liquid state if compressed; 3) any item that is caked with dried blood or other potentially infectious material and is capable of releasing these materials during handling; 4) a contaminated sharp; and 5) pathological and microbiological waste containing blood or other potentially infectious material. A non-needle sharp or a needle device used for withdrawing body fluids, accessing a vein or artery, or administering medications or other fluids, with a built-in safety feature or mechanism that effectively reduces the risk of an exposure incident. The practice of taking necessary precautions with ALL patients, instruments, and materials as though they are carriers of a bloodborne pathogen. This includes avoiding contact with patients bodily fluids by wearing PPE, such as gloves, goggles, and face shields. The use of a physical or chemical procedure that destroys all microbial life, including highly resistant bacterial endospores. The multi-step process of destroying all microorganisms, including bacterial endospores. Those procedures put in place to reduce the risk of exposure by modifying behaviors. Workplace controls that reduce the risk of infection include handwashing, sharps disposing, lab specimen packaging, laundry handling, and contaminated material cleaning. 2010-2014, BSM Consulting 16

COURSE EXAMINATION 1. OSHA stands for: a. Occupational and Safe Health Administration. b. Ophthalmic Standards for Health Care Administration. c. Ophthalmic Safety Has Advantages. d. Occupational Safety and Health Administration. 2. Training on the revised Hazard Communication Standard must begin by and end by which of the following dates? a. Beginning December 1, 2012 and ending July 30, 2015 b. Beginning December 1, 2013 and ending June 1, 2016 c. Beginning December 1, 2012 and ending June 1, 2016 d. Beginning December 1, 2013 and ending July 30, 2015 3. Immunization is provided for employees with occupational exposure for what disease? a. Hepatitis A. b. Hepatitis B. c. Hepatitis C. d. Hepatitis D. 4. What is the single most important method to prevent the spread of infection? a. Washing your hands. b. Covering your cough. c. Using a biohazard container for contaminated products. d. Using disinfectants to clean surfaces. 5. What is PPE? a. Policies, Procedures, Equipment. b. Personal Protective Equipment. c. Personal Provider Elements. d. Protection Produced Elements. 6. The two new changes in the HCS are: a. SDS and label elements. b. MSDS updates and label elements. c. Hazardous chemicals and label elements. d. MSDS and hazardous chemicals. 7. Labels must now include new information including: a. Product identifier. b. Histogram. c. MSDS sheets. d. Email address. 8. A common household product that can be used to kill bloodborne pathogens is: a. Ammonia. b. Lysol. c. Bleach. d. White vinegar. 2010-2014, BSM Consulting 17

9. Which of the following should be disposed of in a red biohazardous bag? a. Used gauze with a drop of blood following infusion. b. Used gauze used with a visible drop of dried tears. c. Used gauze saturated with blood. d. Used gauze worn postop under eye shield. 10. Which of the following should be avoided where there is a likelihood of occupational exposure? a. Eating. b. Documenting in the medical record. c. Touching a potentially infected patient. d. Wearing canvas shoes. 11. The following color is used to identify biohazardous material: a. Blue. b. Yellow. c. Red. d. Black. 12. Pictograms used on labels must be: a. Set in the shape of a square with a red outline, black symbol, and white background. b. Set in the shape of a square with a blue outline, black symbol, and white background. c. Set in the shape of a flame with a red outline, black symbol, and white background. d. Set in the shape of an hexagon with a red outline, black symbol, and white background. 13. When referring to a theory of universal precautions for infection control: a. All blood and other potentially infectious materials are handled as if they were known to be infectious. b. All dressings are disposed of in a biohazardous bag, regardless of the amount of soiling. c. All employees are immunized against hepatitis. d. All patients with eye infections are asked to wear gloves. 14. Spill kits contain all but one of the following: a. Blanket. b. Absorbent pads or material. c. Cleaning agents. d. Biohazard bags. 15. An example of a contaminated sharp would be: a. IV tubing. b. A syringe with a needle. c. Broken glass. d. A used scalpel. 16. Which of the following is considered PPE? a. Surgical shoes. b. Surgical mask. c. Surgical tape. d. Surgical locker. 2010-2014, BSM Consulting 18

17. If there is uncertainty as to how to handle a blood spill, the most important action is to: a. Notify 911. b. Notify your manager. c. Notify the front desk. d. Notify OSHA. 18. The Bloodborne Pathogens Standard requires the practice to have written guidelines for the employees protection and reference. These guidelines are referred to as: a. Employee Handbook or Guide. b. Policy and Procedure Manual (PPM). c. Exposure Control Plan (ECP). d. Emergency and Disaster Plan (EDP). 19. The Bloodborne Pathogens Standard is one of several standards established by the federal government. The enforcement agency for compliance with the Bloodborne Pathogens Standard is: a. FEMA. b. DEA. c. CDC. d. OSHA. 20. If a chemical has multiple hazards, only the pictogram of the most damaging hazard will be displayed on the label. a. True b. False 2010-2014, BSM Consulting 19