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Health Care Series August 2010 | Vol. 17, No. 1 CDC Proposes Updated Guidance For Seasonal and H1N1 Influenza Also In This Issue The U.S. Centers for Disease Control and Prevention (CDC) proposed updated guidance on prevention strategies for seasonal influenza in health care settings, replacing both the current seasonal guidance and last year’s interim infection control guidance for the novel H1N1 virus. The new guidance continues to emphasize the importance of influenza vaccination, management of ill health care workers, droplet and aerosol-generating procedure precautions, surveillance, and environmental and engineering controls. It also now reflects the availability of a safe and effective vaccine for H1N1, which is being included in the 2010-2011 seasonal flu vaccine, CDC said. The prevention strategies can be applied across the entire spectrum of health care settings, including hospitals, nursing homes, physicians’ offices, urgent-care centers and home health care. Page 2 Safe patient handling programs can be adapted for use in home health and other settings . ........ 5 HazCom Expert Advises Safety Professionals on GHS, ‘Gray Areas’ While most of the work needed to achieve compliance with a new globally harmonized system (GHS) of hazard communication will fall on chemical manufacturers and distributors, employers should keep an eye on key dates and determine how the proposed changes will impact their hazard communication programs, says Glenn Trout, president of MSDSonline, a provider of on-demand material safety data sheets. Speaking to the American Society of Safety Engineers (ASSE) at their annual meeting in Baltimore, Trout also offered tips for complying with current HazCom requirements, particularly those “gray areas” intentionally left vague in the standard so employers could tailor their compliance to the specific situations in their workplaces. Page 3 Workers’ Comp Insurer Says Safe Lift Programs Can Reduce Injuries Safe patient handling (SPH) programs can reduce both the number and cost of injuries to direct care providers in nursing homes and other health care settings, a workers’ compensation insurance specialist said at the ASSE annual meeting in Baltimore. Jason Schaufenbuel, MPH, CSP, a regional manager for United Heartland (UH), told ASSE members in Baltimore that UH requires its nursing home and hospital clients to implement SPH programs as a condition of maintaining coverage. One key element in the program is a requirement that supervisors regularly perform one unannounced observation of a patient transfer by each direct care giver every quarter. Page 6 Safe Patient Handling Practice Tools Hazard Communication A safety consultant offers best practice takeaways at the ASSE annual meeting in Baltimore . ......................................................... 4 Infection Prevention CDC includes 13 specific prevention strategies in its proposed updated guidance on seasonal influenza in health care settings ........................ 5 Update Pages This month’s update includes: a clarification of OSHA’s policy on backup systems for online access to MSDSs; and a note on OSHA’s decision to drop a reexamination of the standard on ionizing radiation. Draft Norovirus Guideline CDC on June 16 requested comment on a new Draft Guideline on the Prevention and Control of Norovirus Gastroenteritis Outbreaks in Healthcare Settings. Proposed recommendations cover topics that include: sick leave policies for symptomatic staff, hand hygiene, environmental cleaning, use of personal protective equipment and special considerations for food handlers and other indirect patient care staff. The draft guideline and submitted comments can be viewed online at http://www.cdc.gov/ publiccomments. Contact Us Customer Service: 800 677-3789 Online: www.thompson.com Editorial: 202 872-4000 CDC Proposes to Update Guidance for Seasonal Flu, Replacing Interim Recommendations for H1N1 The U.S. Centers for Disease Control and Prevention (CDC) proposed updated guidance on prevention strategies for seasonal influenza in health care settings, replacing both the current seasonal guidance and last year’s interim infection control guidance for the novel H1N1 virus. The new guidance, proposed June 22 (75 Fed. Reg. 35497), continues to emphasize the importance of influenza vaccination, management of ill health care workers, droplet and aerosol-generating procedure precautions, surveillance, and environmental and engineering controls; however, it also now reflects the availability of a safe and effective vaccine for H1N1, which is being included in the 2010-2011 seasonal flu vaccine, CDC said. The prevention strategies outlined in the guidance can be applied across the entire spectrum of health care settings — including hospitals, nursing homes, physicians’ offices, urgent-care centers and home health care — but are not intended to apply to settings whose primary purpose is not health care. Fundamental Elements Preventing transmission of influenza virus and other infectious agents among patients, visitors and health care personnel (HCP) within health care settings requires a OSHA Guide for Health Care Facilities Managing Editor: Joan M. Flynn Senior Desktop Publishing Specialist: Lisa Cadotte The OSHA Guide for Health Care Facilities (ISBN 978-1-933807-35-5) (USPS 014-673) is published monthly by Thompson Publishing Group, Inc., 805 15th St., NW, 3rd Floor, Washington, DC 20005. Periodicals Postage Paid at Washington, D.C., and at additional mailing offices. POSTMASTER: Send address changes to: OSHA Guide for Health Care Facilities, Thompson Publishing Group, Inc., 5201 W. Kennedy Blvd., Suite 215, Tampa, FL 33609-1823. This newsletter for the OSHA Guide for Health Care Facilities includes a looseleaf update to the Guide. For subscription service, call 800 677-3789. For editorial information, call 202 872-4000. Please allow four to six weeks for all address changes. This information is designed to be accurate and authoritative, but the publisher is not rendering legal, accounting or other professional services. If legal or other expert advice is desired, retain the services of an appropriate professional. Copyright ©2010 by Thompson Publishing Group, Inc. multifaceted approach, according to the proposed guidance. The core prevention strategies include: •• administration of influenza vaccine; •• implementation of respiratory hygiene and cough etiquette; •• appropriate management of ill HCP; •• adherence to infection control precautions for all patient-care activities and aerosol-generating procedures; and •• implementing environmental and engineering infection control measures. HCP should don a facemask when entering the room of a patient with suspected or confirmed influenza, remove the facemask when leaving the patient’s room, dispose of the facemask in a waste container and perform hand hygiene. “Successful implementation of many if not all of these strategies is dependent on the presence of clear administrative policies and organizational leadership that promote and facilitate adherence to these recommendations among the various people within the health care setting, including patients, visitors and HCP,” CDC said. The guidance should be implemented in the context of a comprehensive infection prevention program to prevent transmission of all infectious agents among patients and HCP. Droplet Precautions, N95s and Special Considerations The guidance includes specific action recommendations focusing on familiar strategies, such as vaccination, surveillance and management of ill HCP, with an emphasis on screening and triage of symptomatic patients, adherence to respiratory hygiene and cough etiquette, and use of standard and droplet precautions (see Proposed Recommendations Summarized, Page 5). Regarding droplet precautions, the guidance states that HCP should don a facemask when entering the room of a patient with suspected or confirmed influenza, remove the facemask when leaving the patient’s room, See Flu Guidance, p. 5 2 August 2010 | OSHA Guide for Health Care Facilities Keep an Eye on Key GHS Dates, Update Labels On Secondary Containers, HazCom Expert Advises While most of the work needed to achieve compliance with a new globally harmonized system (GHS) of hazard communication will fall on chemical manufacturers and distributors, employers should keep an eye on key dates and determine how the proposed changes will impact their hazard communication (HazCom) programs, an expert advised safety engineers at their annual meeting in Baltimore. Glenn Trout, president of MSDSonline, a provider of on-demand material safety data sheets (MSDSs) and other safety resources, offered members of the American Society of Safety Engineers tips for complying with current HazCom requirements and preparing for proposed changes that could take effect as soon as 2011. Adopted in 1983, the hazard communication standard covers 100 million workers in 7 million U.S. workplaces, Trout said. Its purpose is to ensure that hazards of chemical substances are evaluated and that details about potential hazards and safe work practices are transmitted to employees. To comply with the standard, Trout said, all employers need to know what hazardous chemicals they have “on the floor” and communicate those hazards to employees. Navigating the Gray Areas HazCom is sometimes referred to as the “common sense regulation” because employers must apply its provisions to the unique circumstances of their own workplaces, Trout said. The U.S. Occupational Safety and Health Administration (OSHA) purposely wrote the standard to include “gray areas,” he explained. For example, the standard requires employers to keep MSDSs in a location “readily accessible” to employees, but it does not define what that term means. For guidance on compliance with gray areas, Trout advised, employers should look to the standard interpretation letters (SILs) that OSHA issues in response to situation-specific questions submitted by safety professionals and others. Employers who have a question about how to comply with the standard can check the OSHA website for relevant SILs. Readily accessible, for example, has been interpreted by OSHA to mean accessible within 20 minutes for some work environments. Trout recalled one SIL in which OSHA told a hospital that had 16 floors in its main building and numerous small outlying building to keep one set of MSDSs on each floor of the main building and one set in each of the outlying buildings. For many employers today, Trout said, providing workers with online access to MSDSs makes the most sense because it eliminates the need to constantly update and file paper copies in binders. Online access is considered permissible by OSHA as long as an employer has a backup system in place for use if the company intranet goes down (see ¶242 in the Guide). This backup can be electronic, such as a phone-and-fax-back system, or it can be paper copies in binders, he said. A rule of thumb, he said, is that if the employer retains MSDSs for more than 30 chemicals, it should go with an online system; for fewer substances, paper copies should suffice. A substance is removed from its labeled product packaging and put into a spray bottle ‘and nobody knows what it is.’ — Glenn Trout, president, MSDSonline Consumer Use Trout said he sometimes hears questions from employers such as whether a four-gallon drum of Windex is covered by HazCom or exempt as a consumer product (see ¶233). Employers seeking to avoid HazCom compliance in this way are “pushing into the gray area” he said. His advice is that it will be easier for them to get the MSDS for a substance than to argue the point with OSHA. If a housekeeper or laundry workers uses a substance normally covered by the exemption for consumer products in an industrial setting, the substance no longer qualifies for consumer use, Trout said. “Now, it’s covered by the standard.” Similarly, employers sometimes ask whether they need an MSDS for items that in most workplaces would not be covered by the HazCom standard, such as copy paper or even water. MSDSs for these products often are available, he explained, not because they are hazardous See HazCom Gray Areas, p. 4 Editorial Advisory Board Thomas H. Wilson, Esq. Chairman Vinson & Elkins, LLP Houston, Texas Fran Slater Feltovich, R.N. Methodist Hospital Houston, Texas August 2010 | OSHA Guide for Health Care Facilities Roger S. Kaplan Jackson Lewis Woodbury, N.Y. James W. Stanley FDRSafety LLC Nashville, Tennessee 3 HazCom Gray Areas (continued from p. 3) chemicals covered by the standard but because, from the vendor’s perspective, it is easier to provide the MSDS than to reassure a customer who fears that not having it could lead to an OSHA citation. The real compliance problems tend to arise around the use of unlabeled secondary containers in the workplace. A substance is removed from its labeled product packaging and put into a spray bottle, Trout said, “and nobody knows what it is.” This can lead to hazardous exposures. One oft-cited incident, he said, occurred in a school where someone put a blue liquid into an unlabeled container, then placed that container in the refrigerator — where staff mistook it for Kool-Aid and served it to children. The HazCom standard requires employers to ensure that secondary containers of hazardous chemicals are appropriately labeled to prevent such accidents from happening (see Best Practice Takeaways). Transition to GHS Trout advises employers to “keep an eye on GHS milestones,” as OSHA proceeds with its plan to amend the HazCom standard to align with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS), a system approved by the United Nations and intended to facilitate international trade in and reduce unnecessary and duplicative testing of hazardous chemicals (see Tab 200 in the Guide). OSHA published its proposed rule changes in September 2009, held informal public hearings in March and April, and could issue a final rule before the end of the year (see April 2010 newsletter, Page 2). The major compliance burden of the rule changes will fall on chemical manufacturers and distributors, who will have to revise chemical product labels to incorporate new standardized pictograms and warnings and also provide customers with the revised, standardized safety data sheets (SDSs) that will replace the old MSDSs. Employers, Trout said, will have to make sure that they have the latest SDSs from suppliers and also train employees on their use. Again, he added, the real problem for many employers will be ensuring that the secondary labels they have placed on containers of chemicals transferred from their original container at the work site are updated when the revised standard goes into effect. It also would be “prudent,” he advised, for employers to ensure that those containers are labeled in additional languages, such as Spanish, if any of their potentially exposed employees have limited proficiency in English. For More Information For more on HazCom compliance and changes expected under GHS, see Tab 200 in the Guide. Hazard Communication: Best Practice Takeaways Be prepared to show OSHA your written plan. “It’s not good enough to have your HazCom plan in your head,” Glenn Trout of MSDSonline says. It must be written, and “it’s the first thing OSHA will ask for when they walk in the door.” Employers can buy written plans, “but they must be tailored to your workplace,” he advises. The plan must reference your list of chemicals and describe how you train your employees and where you keep your MSDSs. Overlabel. Overlabeling is a good practice in most environments, Trout says, not just to ensure HazCom compliance but because it helps to avoid mistakes that could result in exposures, such as a new employee putting refrigerant into a container that should hold oil. When performing the HazCom chemical inventory, identify chemicals in pipes that have an outlet to which an employee could be exposed, he advises. If a pipe holds only water, label it as water to avoid any confusion. Provide blended HazCom training. Provide blended training — some in the classroom and some at the worksite — that is specific to your work environment. Generic training will not meet OSHA’s standards. Consider language needs. OSHA does not require employers to maintain MSDSs in a language other than English. However, Trout says, it is a best practice to make this information available in other languages for employees who have limited English proficiency. Regular HazCom training should be provided in employees’ native languages to ensure that all employees are fully aware of hazards and safe handling procedures. Get MSDSs in advance. Try to make sure that you have MSDSs in hand before you receive the first shipment of a new chemical in case you do not have a place to store it before it is used for the first time by employees. 4 August 2010 | OSHA Guide for Health Care Facilities Flu Guidance (continued from p. 2) dispose of the facemask in a waste container and perform hand hygiene. Based on local needs, facilities and organizations “may opt to provide employees with alternative personal protective equipment as long as it offers the same protection of the nose and mouth from splashes and sprays provided by facemasks (e.g., face shields and N95 respirators or powered air purifying respirators which would also protect against inhaling airborne particles),” the guidance states. The use of N95 filtering facepiece respirators is recommended for HCP involved in aerosol-generating procedures. Respirators must be provided in the context of a respiratory protection program that includes fit testing and training as required under the U.S. Occupational Safety and Health Administration’s respiratory protection standard (see ¶540 in the Guide). In addition, the guidance discusses special considerations for HCP who are at higher risk for complications from influenza, such as pregnant women, HCP age 65 and older, and HCP with chronic diseases such as asthma, heart disease and diabetes. For example, employers should consider offering work accommodations to avoid potentially high-risk exposure scenarios, the guidance states. Vaccination Recommendations Despite the recommendation to promote and administer seasonal influenza vaccine, the proposed guidance does not recommend mandatory flu vaccination for health care workers. “While some have mandated influenza vaccination for all HCP who do not have a contraindication, it should be noted that mandatory vaccination of HCP remains a controversial issue,” CDC said. However, the guidance states that tracking influenza vaccination coverage among HCP “can be an important component of a systematic approach to protecting patients and staff.” It also suggests strategies for improving HCP vaccination rates, including: Sick Leave The proposed guidance includes specific recommendations for managing HCP who show symptoms of the flu and states that facilities should develop sick leave policies that are non-punitive, flexible and consistent with public health guidance to allow HCP with confirmed or suspected influenza to stay home. Facilities also should ensure that all HCP, including those not directly employed by the facility, are aware of the policies. Written comments on the proposed guidance are due July 22; however, the notice states that comments received after that date “will be considered to the extent possible.” Comments may be submitted via e-mail to [email protected]. For More Information The Federal Register notice is available online at http://www.access.gpo.gov/su_docs/fedreg/a100622c. html. Proposed Recommendations Summarized CDC’s proposed updated guidance on prevention strategies for seasonal influenza advises health care facilities to: • promote and administer seasonal influenza vaccine to health care personnel (HCP); • take steps to minimize potential exposures; • monitor and manage ill HCP; • adhere to standard precautions; • adhere to droplet precautions; • use caution when performing aerosol-generating procedures; • manage visitor access and movement within the facility; • monitor influenza activity; • implement environmental infection control; •• providing incentives; • implement engineering controls; •• providing vaccine at no cost to HCP; • train and educate HCP; •• improving access, for example, by offering vaccination at work and during work hours; and • administer antiviral treatment and chemoprophylaxis of patients and HCP when appropriate; and •• requiring personnel to sign declination forms to acknowledge that they have been educated about the benefits and risks of vaccination. • take extra considerations for HCP at higher risk for complication of influenza. August 2010 | OSHA Guide for Health Care Facilities 5 Workers’ Comp Insurer Requires Clients To Implement Safe Patient Handling Programs Safe patient handling (SPH) programs can reduce both the number and cost of injuries to direct care providers in nursing homes and other health care settings, a workers’ compensation insurance specialist told a group of safety engineers at their annual meeting in Baltimore. Jason Schaufenbuel, MPH, CSP, a regional manager for United Heartland (UH), told the American Society of Safety Engineers (ASSE) June 15 that UH requires its nursing home and hospital clients to implement SPH programs as a condition of maintaining coverage. While researching the problem, the UH loss control team found that the nursing home losses were driven primarily by manual lifting and transferring of residents, repositioning in beds or chairs, residents going to nonweight-bearing status, assisting or transporting, and moving residents’ limbs. Tasks most often associated with injuries included: •• moving residents to and from wheelchairs and toilets, beds and bathtubs; •• lifting residents in bed; •• weighing residents; “What is your process for getting a fallen resident up off the floor? It better not be manual.” — Jason Schaufenbuel, regional manager, United Heartland •• changing residents’ thrombo embolic deterrent (TED) stockings; •• repositioning residents; and •• making beds. No Safe Method of Manual Lifting Moreover, he said, the program has reduced both the number and cost of claims. Studying 57 client accounts held for at least two years before and after implementing SPH, UH found a 37 percent reduction in the number of SPH-related claims. Moreover, claim costs for those SPH accounts dropped 39 percent compared with a 19 percent increase across all accounts. As a mono-line workers’ compensation carrier, the Milwaukee-based firm insures about 400 hospitals and nursing homes. Its website attributes its “rapid growth and success” to customized loss control services and managed claims handling and emphasizes the firm’s role in helping clients improve workplace safety. Carrier Notices Losses According to Schaufenbuel, UH’s interest in SPH programs began in 2002, when it noticed significant losses accumulating across its nursing home accounts, an industry sector long known for reporting significantly higher-than-average rates of back injuries and other musculoskeletal disorders (MSDs) caused by patient lifting. Rather than exiting the nursing home market, UH’s corporate leaders challenged the loss control staff to try to solve the problem. The solution they came up with was to require most health care clients, as a condition of maintaining coverage, to implement a comprehensive SPH program designed by UH based on a program developed by the Department of Veterans Affairs (VA). 6 After researching ways to make manual lifting tasks safer for nursing home workers, the loss control team concluded that although there are many ways to perform a manual lift, there is no safe way. No single method studied has proven to be effective, and regardless of how well workers are trained, all of the methods produce large forces on the spine and other joints, Schaufenbuel said. Eventually, UH adopted, with some minor changes, an approach put forth by the VA’s Veterans Integrated Service Network (VISN) 8 Patient Safety Center of Inquiry (PSCI) in Tampa, Fla., whose mission is to promote safe patient handling. The VISN approach relies on the use of mechanical lift equipment and other patient handling aids, program elements that support use of that equipment, employee training and a “culture of safety” in the work environment. The main elements of the SPH program that UH clients adopt are: •• written program; •• use of objective transfer criteria; •• quality assurance activities and reporting; •• initial and ongoing education and training; •• progressive disciplinary program; and •• equipment inspection and maintenance. August 2010 | OSHA Guide for Health Care Facilities See Safe Patient Handling, p. 7 Safe Patient Handling (continued from p. 6) The written program is an important element of SPH, Schaufenbuel emphasized. “Organizations need to document their commitment and expectations,” he said. The written program should describe: •• roles and responsibilities of all staff, including leadership, the director of nursing and maintenance; •• specific processes to be followed by staff when lifting or moving residents; •• equipment used in the facility, such as gait/walking belts, total body lifts, sit-to-stand devices and lateral transfer devices; and •• all other program elements. Any special circumstances that may arise in the facility also should be addressed in the written program, Schaufenbuel said. “What is your process for getting a fallen resident up off the floor? It better not be manual,” he said. The program also should state how staff will handle bariatric patients and residents who are combative. Using Transfer Criteria The use of objective criteria in determining how to safely transfer residents is a cornerstone of an effective SPH program, Schaufenbuel said. Often, he said, UH finds that caregiving staff in facilities do not understand why a resident needs a total body lift or a sit-to-stand as specified in the care plan. Yet these workers are often in the best position to determine how much assistance a resident needs over the course of a day, when physical fatigue may become a factor, he said. Accordingly, UH requires that direct care workers have the authority to make a transfer more assistive if they determine that the resident needs it. Institutions often resist this, he said, but the key is that caregivers have authority only to make a transfer more assistive, not less assistive, than what is specified in the care plan. When training staff in use of objective criteria, there are various systems to choose from, Schaufenbuel said. To provide an example, he said, if a resident is: •• unable to stand up from seated three times or stand in one place for 30 seconds, use a total body lift; •• able to do the above, but not march in place six steps at bedside, use a sit/stand device; •• able to stand and march, but not able to take step forward and back with each foot, use sit/stand device or wheelchair; •• able to do all of the above but with difficulty understanding and following directions, use a gait belt; and •• if able to complete all of the above, considered independent. Another useful and easy-to-remember system, he said, is the “4-second rule.” If a resident: •• can stand unassisted for four seconds, use a walking belt; •• can stand for 4 or less seconds with assistance, use a sit-to-stand device; or •• is unable to stand, use a total body lift. Checking Up on Training All new hires must undergo SPH training regardless of where they worked previously, Schaufenbuel said. Training must be provided: •• prior to assignment; •• whenever a staff member returns from a period of extended leave; and •• whenever needed based on direct observation of the employee or any incident that indicates the person is lacking in knowledge. Training must be hands on, and employees must demonstrate their competency. Both the trainer and the See Safe Patient Handling, p. 8 Applying SPH to Home Health and Other Settings Although most of UH’s health care clients are nursing homes and hospitals, Schaufenbuel said, the basic program elements can be applied to any setting. For home health providers, he said, the key is whether the employer is willing to invest in training employees and purchasing equipment that is suitable for use in patients’ homes. Such equipment is available on the market. Schaufenbuel acknowledged, however, that some health care settings present a greater challenge. Hospital emergency departments, in particular, have a higher incidence of staff injuries because of the need to transfer patients very quickly, for example, to obtain a radiograph or an MRI. UH is continuing to experience losses in that area and is trying to determine the best approach to solving the problem, he said. August 2010 | OSHA Guide for Health Care Facilities 7 Safe Patient Handling (continued from p. 7) UH staff will go into a facility to perform the observations if they believe management is not doing so. supervisor must “sign off” in written documentation that the employee has satisfactorily completed training. Training topics must cover: Maintaining and Inspecting Equipment •• use of mechanical lifts; •• use of lateral transfer devices; •• repositioning residents; •• pre-use visual inspection of equipment; and •• an explanation of the objective transfer criteria and how it is used. It is critical that facilities implement a quality assurance program for monitoring compliance with the SPH program policies and fostering continuous improvement, Schaufenbuel said. UH requires clients to have a quality assurance program that includes: •• unannounced observations by supervisors of staff making transfers, with at least one observation per staff member per quarter; •• evaluations of transfer incidents to determine what went wrong and why; •• monitoring of residents’ transfer needs; and •• annual evaluation of the program’s effectiveness. Following up on training with unannounced observations of staff is critical, Schaufenbuel said, adding that 8 All staff must be trained to visually inspect equipment before use, and the facility must set up an inspection program consistent with the manufacturer’s requirements, under the UH program. Maintenance staff in particular must be trained in how to inspect and maintain equipment, and they must understand that this is their responsibility to do so. One problem that sometimes arises is that facilities will invest in lift equipment, and train staff in its use, but the equipment ends up getting pushed aside or even locked away, Schaufenbuel said. This is not acceptable to UH, he said, and clients that do not use the equipment cannot remain insured. Involving direct care staff in the selection of equipment before it is purchased is one way to avoid ending up with equipment that they do not want to use, he suggested. Sometimes nursing facilities fear that patient-handling equipment kept on stand-by in hallways will cause them to fail a fire inspection. In such cases, he suggests that administrators make the effort to meet with the fire marshal to explain the situation and find an agreeable solution. For More Information The VISN 8 Patient Safety Center can be accessed online at http://www.visn8.va.gov/patientsafetycenter. August 2010 | OSHA Guide for Health Care Facilities