[MCOH-EH] [Bulk] OSHA REGULATIONS

[Cunha, Bruce E.]

Dr. Hodgson

The e-tools are helpful to a lot of folks.  I routinely refer employees to this site when they may need a better understanding of regulations and compliance topics.  They do assist in providing a good overview of safety and health topics.  I understand the time and effort it takes to keep these up-to-date, and anything we can do to assist with review and/or change recommendations, I am happy to assist with.


If I might ask you another topic that I just saw on the OSHA Newsletter for this week.

Can you give the group some information on the following?

OSHA to convene small business review panel on infectious diseases
[Petrie dishes]

On Wednesday June 4, OSHA announced that it will convene a Small Business Advocacy Review panel to choose representatives of small entities who will provide their perspectives on a possible Infectious Diseases standard. The SBAR panel will identify small business representatives potentially affected in order to obtain their advice and recommendations about the potential impacts of the Infectious Diseases rule. The panel's written report will be made publicly available.
OSHA is considering the need for a standard to ensure that employers establish comprehensive controls to protect workers from hazardous exposures to infectious diseases on the job. The rule is intended to cover a wide range of healthcare and related workplaces including: hospitals; ambulatory care centers; long-term and home health care facilities; laboratories, and medical waste handling facilities. Representatives of small entities, including small businesses, not-for-profit entities, and local governments involved in workplaces such as those listed above who are interested in participating should contact Charles McCormick by e-mail (McCormick.Charles at dol.gov<mailto:McCormick.Charles at dol.gov>) or by phone (202-693-1740).
This would appear to be something that this group would be very interested in.

Is the consideration for this proposed standard to primarily impact healthcare?   My own opinion would be that if this is the case, this would bring up the same issues we addressed with OSHA with the proposed TB regulation.  That is:  Is there scientific evidence that healthcare workers are any more impacted by infectious diseases than the general public?  Given that we put a significant amount of effort in keeping our employees healthy, and already implement a variety of measures to eliminate/reduce exposure to infectious diseases, would a regulation reduce that potential any more?

Will the proposed standard impact other industries? My routine example is the person working the checkout at your local Walmart.  This worker is far more exposed to persons with infectious diseases than a healthcare worker in my institution is.


Bruce E. Cunha RN MS COHN-S
Manager, Employee Health and Safety
Marshfield Clinic
Marshfield WI.

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From: MCOH-EH [mailto:mcoh-eh-bounces at mylist.net] On Behalf Of Hodgson, Michael - OSHA
Sent: Tuesday, June 17, 2014 2:05 PM
To: MCOH/EH
Subject: Re: [MCOH-EH] [Bulk] OSHA REGULATIONS

Hi, thanks very much.  Your address suggests you are a NIOSH user, not a direct health care practitioner / employee.  Who are your stakholders?

So it would be really interesting, given our staffing issues, to get comments and suggestions back.  I can argue for leaving this up if there’s a groundswell.  We had created a home health care e-tool and were about to put it up but saw some problems with the old pages.  If those of you who recognize problems with the pages point them out, we can likely do something…

Michael

From: MCOH-EH [mailto:mcoh-eh-bounces at mylist.net] On Behalf Of Novak, Debra A. (CDC/NIOSH/NPPTL)
Sent: Tuesday, June 17, 2014 2:34 PM
To: 'mcoh-eh at mylist.net'
Subject: Re: [MCOH-EH] [Bulk] OSHA REGULATIONS

Please do not remove the Hospital eTool...I agree it needs updating but based on my stakeholders it is widely used!

From: Hodgson, Michael - OSHA [mailto:Hodgson.Michael at dol.gov]
Sent: Tuesday, June 17, 2014 02:22 PM Eastern Standard Time
To: MCOH/EH <mcoh-eh at mylist.net<mailto:mcoh-eh at mylist.net>>
Subject: Re: [MCOH-EH] [Bulk] OSHA REGULATIONS

Interesting that this is considered still useful. There are some pretty outdated pieces and we were thinking of taking it down.  Does this group think it’s still worth keeping?


Michael

Michael J. Hodgson, MD, MPH
Chief Medical Officer and Director, Office of Occupational Medicine
Occupational Safety and Health Administration
Department of Labor
200 Constitution Ave, NW Rm 3457
Washington DC 20210



From: MCOH-EH [mailto:mcoh-eh-bounces+hodgson.michael=dol.gov at mylist.net] On Behalf Of Senior, Cathy (DRMC)
Sent: Tuesday, June 17, 2014 1:59 PM
To: 'MCOH/EH'
Subject: Re: [MCOH-EH] [Bulk] OSHA REGULATIONS

Love this tool.  Thanks for sharing.

Cathy Senior RN BSN CDE
Employee Health Director
Penn Highlands DuBois
100 Hospital Avenue
P.O. Box 447
DuBois Pa 15801
Phone 814-375-3392
Fax 814-372-2610
cesenior at phhealthcare.org<mailto:cesenior at phhealthcare.org>
www.phhealthcare.org<http://www.phhealthcare.org>

From: MCOH-EH [mailto:mcoh-eh-bounces at mylist.net] On Behalf Of Kathy Dayvault
Sent: Tuesday, June 17, 2014 1:26 PM
To: 'MCOH/EH'
Subject: Re: [MCOH-EH] [Bulk] OSHA REGULATIONS

Look at the blood borne pathogen exposure regulation. I use the hospital etool…. It helps you find specifics faster.

https://www.osha.gov/SLTC/etools/hospital/index.html

BBP reg: https://www.osha.gov/SLTC/etools/hospital/hazards/bbp/bbp.html


  *   Employer should establish and maintain both medical and training records [29 CFR 1910.1030(h)(1)<https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10051> and 29 CFR 1910.1020<https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10027>].
     *   If an exposure incident occurs, employer should add reports to the medical record to document the incident, including testing results following the incident, follow-up procedures, and the written opinion of the health care professional.
        *   Medical Records must be preserved and maintained for each employee with an occupational exposure to bloodborne pathogens [29 CFR 1910.1030(h)(1)<https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10051#1910.1030(h)(1)>] and for at least the duration of employment plus 30 years. They must be kept confidential (not disclosed without written permission of employee, except by law) and separate from other personnel records and must also include:
           *   The employee's name and social security number, hepatitis B vaccination status, including the dates of vaccination and medical records related to the employee's ability to receive vaccinations.
Hope you find this helpful…. Very quick resource once you click on the hazard that you want.


Kathy Dayvault, RN, BSN, MPH, COHN-S/CM

Independent OHN Consultant




From: MCOH-EH [mailto:mcoh-eh-bounces+kdayvault11=att.net at mylist.net] On Behalf Of Senior, Cathy (DRMC)
Sent: Tuesday, June 17, 2014 1:08 PM
To: 'MCOH/EH'
Subject: [Bulk] [MCOH-EH] OSHA REGULATIONS

Can anyone direct me where I can find the OSHA regulation pertaining to the Duty to ensure privacy of employees exposed to blood and body fluid.  I know some facility use psuedo names in order to protect their employees privacy when the test are done in their facility.  I want to do this, however our lab is not agreeable as they are not sure how to register the employee and keep everything straight.   The lab informed me that they checked the state regulations (we are in PA) and there is nothing that says we must give psuedo names.  Therefore , I am looking for any information that would assist my mission to provide privacy to our employees.  I thought there was an OSHA regulation if the test was done within the facility such as the rapid HIV suds test that we could not use their name.  Can anyone direct me on this?
Cathy Senior RN BSN CDE
Employee Health Director
Penn Highlands DuBois
100 Hospital Avenue
P.O. Box 447
DuBois Pa 15801
Phone 814-375-3392
Fax 814-372-2610
cesenior at phhealthcare.org<mailto:cesenior at phhealthcare.org>
www.phhealthcare.org<http://www.phhealthcare.org>


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