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ardous.’ Even if you are tight on space, you have to have that sticker properly delineated so it warns patients and staff about the contents.” Anne Dean, RN, founder of The

OSHA Inspections: Are You Ready?

Meeting OSHA requirements helps ensure the safety of patients and staff. BY ROBERT KURTZ

Editor’s note: This article is part two of a two-part series. Look for the first installment in the June issue.

Disposal of Biohazardous Waste ASCs must follow a number of impor- tant rules when handling or disposing of biohazardous waste, says Scott J. Trimas, MD, a facial plastic surgeon and otolaryngologist in Florida. These include a new Occupational Safety and Health Administration (OSHA) re- quirement that took effect July 1, 2012, which requires staff members who handle this waste to have additional training. OSHA also specifies ways to handle the waste before it is picked up, how to put the waste in the box and how to avoid spills when it gets picked

The place where the red bags and sharps containers

are supposed to be stored has to be a negative pressure room.”

—Anne Dean, RN, The ADA Group

up by your vendor, he says. “They want to make sure that when you pack- age the biohazardous waste, something isn’t happening to it en route.” ASCs may sometimes forget to

follow an older rule that requires the use of proper labeling of biohazard- ous waste, says Trimas. “You have to demarcate the waste either with an orange or red label that says ‘biohaz-

ADA Group, an ASC consulting firm, in DeLand, Florida, advises ASCs to check to see what type of container the facility is using to hold the bio- hazardous waste bags. “It’s supposed to be put into a leakproof container,” she says. “Carriers used to bring big corrugated cardboard boxes that had the biohazardous emblem on it. Then OSHA came out and said the red bag containers needed to be leakproof and puncture resistant. The first thing I saw was the waxed cardboard boxes. They were more leakproof but were still not puncture resistant. What we started seeing a few years ago are red garbage can-looking containers, which are re- ally great—they are clearly more leak- proof and puncture resistant. If your ASC is still using cardboard boxes, I would urge you to confront your car- rier and point out that they are neither leakproof nor puncture resistant and you need something far better.” ASCs should designate an area close to an exit for biohazardous waste pickup, Dean says. “Your biohazard- ous trash is supposed to be kept as near to an exit of the building as possible so that it doesn’t have to travel very far through the center and the person pick- ing it up doesn’t have to travel far to take it out,” she says. “And the place where the red bags and sharps contain- ers are supposed to be stored has to be a negative pressure room. Staff mem- bers should be trained on where to put this waste and that they should put it nowhere else.”

OSHA inspectors also are ask-

ing ASCs to present their hazardous waste manifests, which most states require to keep on file for at least three years. “ASCs need to keep the manifests on site,” Trimas says. “If an OSHA inspector comes in and wants


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