FEATURE
to see the manifests, you need to be able to pull them up. OSHA won’t want to see you call your vendor for biohazardous waste management and ask them to fax a copy.”
Other Areas of Focus ASCs need to review several addition- al areas to ensure OSHA compliance. “You have to provide personal protec- tive equipment (PPE) and the train- ing for your staff,” says Gayle Evans, RN, president of ASC consulting firm Continuum Healthcare Consultants in Kennesaw, Georgia. “You have to document that, and you have to show how you handle staff who do not com- ply with the rules.” While you do not need an official OSHA officer, Evans says you do need someone to perform random in- spections. “They would check to ver- ify that people are doing what they’re supposed to be doing,” she says. “Per- forming a random audit does become the responsibility of the ASC.” Dean agrees. “We have a qual-
ity improvement study where I have somebody, usually a nondescript per- son, just wander around to see, for ex- ample, if the staff washing instruments or cleaning the scopes are wearing PPE,” she says. “This helps ensure that they’re following the guidelines, and identify when and why they are not.” Dean advises ASCs to
closely
monitor their ORs and procedure rooms to make sure no food or drink enters those areas. She also notes there should be no food or drink, be- sides water, in the patient care area. “That’s for vector control and infec- tion control as well,” she says. OSHA also has rules for eyewash stations and showers, Dean says. “When you look at the regulations, it says the eyewash station has to be within 10 seconds of any area for possible exposure. And it has to be hands-free. It needs to be on a sink and as close as possible to a possibly
24 ASC FOCUS JULY 2013
hazardous area. The station has to be tested weekly, and you have to test, at least annually, the water pressure and flow to make sure you have adequate flow and it is tepid water. You also need to make sure that the staff knows how to use the stations. At least once a year you should perform competency training, and also when a new person comes on board. “As for showers, by law, you must
have a shower in the ASC, and it must be accessible at all times and not used as a storage area,” Dean con- tinues. “With the surgery performed in ASCs, it’s unlikely that you would get a big splash requiring the use of a shower. A little while back I re- ceived an incident report that said an endoscopic cleaner had more or less exploded overnight, completely soil- ing a room and causing a little flood. That could have happened during the day, and someone could have been standing near the cleaner and had all of that fluid go on to them. I de- veloped a new relationship with the importance of keeping the shower accessible after that.” Trimas says ASCs need to remem- ber to document occupational expo- sures appropriately. “When you have an occupational exposure, you’re sup- posed to do a root cause analysis and
figure out why it occurred and what you can do to prevent it,” he says.
Quick Tips for Compliance Since several OSHA rules require ongoing training, evaluating and testing, Dean says ASCs may want to consider using a large calendar to note what needs to happen and when it needs to happen. “We use what we call an ‘activity calendar’ and it shows exactly when everything that needs to be done every month, every quarter and even once a year should take place,” she says. “This helps keep ASCs performing these tasks when they’re supposed to and reduc- es the likelihood that responsibilities will be put off until the end of the year or missed entirely.” Evans says it is important to keep training as easy to follow as possible. “Keep it simple, but make sure that you educate your staff,” she says. “To me, that’s it in a nutshell. Make sure your staff understands the impor- tance of compliance. “And make the staff a part of the decision process,” Evans continues. “This would include selection of the safety devices, PPE—making them a part of all of that and letting them choose what works for them. That will help get their buy-in.”
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