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American Academy of Provider Offices and Laboratories
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OSHA Outpatient Healthcare Policies
and Procedures Manual Bibliography
Resources for this manual are governmental agencies: OSHA (Occupational Safety and
Health Administration) and the CDC (Centers for Disease Control). OSHA standards
referred to in this material include:
1. Bloodborne Pathogen Standard 1910.1030
2. Hazard Communication Standard 1910.1200
3. Respiratory Protection 1910.134
4. Lockout/Tagout 1910.147
5. Personal Protective Equipment 1910.132
6. Non-ionizing Radiation 1910.97
7. Occupational Exposure to Hazardous Chemicals in Laboratories 1910.1450
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Comprehensive OSHA Compliance Checklist
__
__
__
__
__
__
__
__
__
__
__
__
__
__
__
__
__
__
__
Commitment of management documented
Safety Coordinator designated
Safety Coordinator responsibilities established
Safety Committee formed
Worksite Hazard assessment completed
Written compliance program developed addressing hazards found during
hazard assessment
__ Bloodborne pathogens
__ Hazardous chemicals
__ Fire and electrical hazards
__ Radiation
__ Laser safety
__ General safety
__ Emergency action plan
__ Workplace violence
__ Tuberculosis
__ Ergonomics
__ Other ______________________
__ Training
OSHA poster displayed
Written program approved by management
OSHA Manual reviewed and signed by Safety Coordinator and Management
Representative
Training program developed to meet all needs, based on hazard assessment
Training provided and documented
__ Initial
__ Annual
Fire extinguishers professionally serviced annually
Fire extinguishers checked visually each month
Exit route diagrams posted
Meeting place assigned
Bloodborne Pathogens Risk Identification performed
__ Initially
__ Annually
Safer Medical Devices
__ Evaluated
__ Chosen
__ Implemented
__ Re-evaluated annually
HBV vaccine offered to all employees who are at risk for exposure as
determined by Risk Identification
Record keeping
__ HBV vaccination documentation (shot records, declination, or titer) for
all applicable employees (see above)
__ Designated healthcare professional to do exposure follow-up
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__ Hand washing facilities, sharps containers, and biohazardous waste
containers where needed
__ Chemical list completed
__ MSDSs obtained and organized
__ All chemical containers labeled
__ Tuberculosis Risk Assessment
__ Initial
__ Annual
__ TB Control Plan in effect
__ Personal Protective Equipment Assessment
__ Initial
__ Annual
__ PPE provided and replaced or maintained
__ Used as instructed
__ Eyewash Station
__ Installed
__ Checked and flushed weekly
__ Commercial laundry service obtained and informed that some linens may be
contaminated
__ Reliable waste removal company contract verified
__ Spill kit obtained or assembled
__ First Aid kit readily available
__ CPR mask or ambu bag available
__ Record keeping
__ File for each employee with: employee’s name, job description, Social
Security number
__ HBV vaccination (see page 1)
__ Training logs
__ All occupational illnesses and injuries documented on 301 Form or
workers comp form
__ Sharps Injury Log if applicable
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Disposal of Home-Generated Sharps: State Guidelines
Alabama: The Alabama Department of Environmental Management (ADEM) publishes a brochure entitled
“Handling and Disposal of Medical Waste – A Household Guide for Alabamians.” The guidance recommends
that:
• Home-generated needles, syringes, lancets, and other sharp objects should be placed in a hard plastic
container such as a liquid soap, bleach, or fabric-softener bottle, or a metal container with a screw-on (or
tightly secured) lid. Sharps should not be placed in glass or clear-plastic containers.
• The lid should be reinforced with heavy-duty tape before disposal.
• Sharp objects should not be placed in any container that will be recycled or returned to a store.
• Containers should be marked “Not For Recycling.” Containers should never be labeled with the terms
“medical waste” or “infectious waste” because those terms only apply to health care professionals.
• Containers used to dispose of sharp objects should be kept away from young children and pets.
• Filled containers should be disposed of as frequently as other garbage.
Alaska: No written guidance on the disposal of household-generated syringes.
Arizona: The Arizona Department of Environmental Quality (DEQ) has developed the following
guidelines: http://www.azdeq.gov/environ/waste/solid/ic.html#sharps
The guidelines include these recommendations:
• Medical sharps should be placed in either a medical sharps container purchased from a pharmacy or health
care provider, or in a heavy-plastic or metal container.
• The container should be puncture-proof with a tight-fitting lid.
• Household containers, such as plastic detergent bottles, can be used if heavy-duty tape is used to secure the
lid to the container and the words “Not Recyclable” are written on the container with a black indelible marker.
The guidelines include these warnings:
• Do not use a clear or glass container.
• Do not over-fill the containers.
• Keep container out of reach of children and pets.
• Always wash your hands after handling or touching medical sharps.
Arkansas: No guidance for individuals on how to safely dispose of used syringes.
California: California has not published community syringe disposal guidance. A new law on disposal of
syringes by home users was passed in January 2007. (See the new law in its entirety at
http://www.leginfo.ca.gov:80/pub/05-06/bill/sen/sb_1301-1350/sb_1305_bill_20060712_chaptered.html.)
In addition, most household hazardous waste facilities in the state of California accept sharps from the
community. Contact your local HHW facility to see if sharps are collected and how are they to be contained.
See the Los Angeles website at http://www.lacsd.org/info/hhw_e_waste/default.asp.
Colorado: Colorado offers guidance on disposing household-generated syringes through two bulletins created
by the state’s Department of Public Health and Environment, Hazardous Materials and Waste Management
Division. These bulletins are entitled Household Medical Waste Management and Infectious Waste
Management. The bulletins include the following recommendations.
Needles, syringes, lancets, and other medical sharps should be:
• Placed in strong plastic or metal containers with screw-on or tightly secured lids. (Examples include empty
bleach bottles, liquid detergent bottles, plastic milk jugs, or coffee cans. Strong tape should be used to secure
the lids of coffee cans.)
• Once the container is full and sealed, it can be placed in the regular household trash.
The bulletins also include these warnings:
• Recyclable containers should not be used as sharps containers.
• Glass should never be used as a sharps container.
• All infectious waste should be stored out of reach of children and pets.
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Connecticut: The Connecticut Department of Environmental Protection, Bureau of Waste Management, does
not provide written guidance for community syringe disposal. However, the Bureau staff recommends that
before disposing of used syringes in the regular household trash, home users properly package them by:
• Placing syringes in rigid, puncture-resistant, opaque containers such as bleach or liquid detergent bottles;
• Labeling the containers with the words “Do Not Recycle” and “Sharps”; and
• Securely sealing the containers with heavy-duty tape.
The staff also recommends that individuals contact hospitals, clinics, pharmacies, or other facilities to find out if
they collect packaged used syringes.
Delaware: No written guidance on the disposal of household-generated syringes.
Florida: The Department of Health publishes a document entitled Safe Disposal of Sharps at Home. The
guidance states:
● In order to reduce accidental needle sticks, the Florida Department of Health encourages individuals to find
out how their county health department recommends disposing used sharps. To see if a program exists in your
county, go to http://www.doh.state.fl.us/environment/community/biomedical/sharps.htm.
● If you reside in the State of Florida and there is no sharps disposal program in your county, the Florida
Department of Health and the Florida Department of Environmental Protection have developed the following
disposal guidelines for home-generated biomedical waste:
- Consult a health care professional about the possibility of accepting home-generated waste for disposal in
the health care facility’s biomedical waste stream. This will insure that properly trained and equipped
individuals handle these materials.
- Contact the local United States Post Office branch for a list of approved biomedical waste mail-back
services. Biomedical waste is placed into containers provided by these services and mailed to a facility for
treatment. If these options are not available, the Florida Department of Environmental Protection recommends
that individuals follow the guidelines below.
► Place needles, syringes, lancets, and other sharp objects into hard plastic or metal containers
with a screw-on top or other tightly securable lid (e.g., an empty paint can or liquid-detergent
container). Before discarding, reinforce the top with heavy-duty tape.
Do not put sharp objects in any container you plan to recycle. Do not use clear plastic or glass
containers. Check with your local waste collection service to make sure these disposal procedures
are acceptable in your county.
► All sharps should be disposed of in rigid puncture-resistant containers such as liquid detergent
bottles, bleach bottles or metal containers.
For more information, contact: Florida Department of Health, Bureau of Community Environmental
Health/HSEC, 4052 Bald Cypress Way, BIN A08, Tallahassee, FL 32399-1710. Telephone number: (850) 2454277.
Georgia: No guidance for the safe disposal of community sharps.
Hawaii: The Hawaii Department of Health’s Office of Solid Waste Management has posted a fact sheet
entitled Proper Disposal of Home Care Waste
(http://hawaii.gov/health/environmental/waste/sw/pdf/medwaste.pdf). The guidance recommends the
following:
● Place needles, syringes, lancets and other contaminated sharps in any strong leak-proof plastic containers,
such as empty bleach, laundry detergent or dish soap containers. The container should have a small opening
so that no one is able to stick their hand into it.
● The container must also be clearly marked “BIOHAZARD.” Used needles and other contaminated sharps
are NOT recyclable. Keep the sharps container separate from other materials that you set aside for recycling.
● You do not have to recap, purposely bend, break or otherwise manipulate needles before inserting them
into the disposal container. Drop all parts into the container.
● Sharps should be sterilized or be chemically disinfected prior to disposal. Once your container is full, fill the
container with a solution of one part bleach and ten parts water. Allow the needle to soak in this solution for
20 minutes. Then, pour the solution into the sink and use heavy-duty tape to seal the cap before placing the
disposal container into the garbage.
● BE SURE to keep all containers with discarded sharps out of the reach of children and pets.
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For more information, contact your local Department of Health.
Idaho: The Idaho Department of Environmental Quality publishes guidance entitled Eliminating Household
Hazardous Waste. The guidance contains the following information for medical waste (sharps):
Potential Hazards:
The medical waste items most often generated by households in Idaho are disposable hypodermic syringes
and needles (called sharps) used for home medications in the treatment of diabetes, allergies and other
diseases. Other types of medical wastes produced by households are cultures and stocks, biological waste
and pathological waste. Improper disposal of sharps can injure garbage haulers and landfill workers or, if it is
contaminated with infectious disease organisms, it can transmit communicable diseases.
Disposal:
Sharps and other medical wastes are characterized as infectious waste and should be disposed of separately
from household garbage. Contact your garbage hauler, local government, solid waste department or public
health department to obtain proper disposal containers and service information for packaging and collection in
your area.
Contact the Idaho Department of Environmental Quality‘s Pollution Prevention Program at 208-373-0502.
Illinois: Illinois has not created a formal policy on the disposal of syringes used by individuals at home.
However, the Illinois Environmental Protection Agency, Bureau of Land, publishes guidance on its web page
under the heading “Potentially Infectious Medical Waste (http://www.epa.state.il.us/land/wastemgmt/factsheets/general-regs.html). With regard to disposing of medical waste from homes, the guidance
states:
Potentially Infectious Medical Waste (PIMW) does not include medical waste generated in a household. If a
person chooses to place this medical waste in their household trash, the following guidelines help protect the
trash haulers, landfill workers, and others who may come in contact with the waste. First, the medical waste
should be placed in a sturdy container such as a sharps container from the pharmacy, a laundry detergent
bottle, or a soda bottle. When the container is full, the lid should be put on the container and taped in place.
The container should then be marked “Do Not Recycle” and then placed in the regular trash.
The Bureau of Land also gives contact information for other agencies that may regulate syringe disposal:
● Illinois Department of Public Health (http://www.idph.state.il.us/) (217) 785-2629.
● Illinois Environmental Protection Agency, Bureau of Land, Beverly Albarracin, (217) 524-3289.
Indiana: Indiana has not developed its own written guidance on safe disposal of syringes used by individuals
at home. Instead, this state recommends EPA’s former guidance on at-home syringe disposal:
• Place needles and syringes in a hard plastic or metal container with a screw-on cap or tightly secured lid.
• Reinforce the lid of the container with heavy-duty tape.
• Label the container “Do Not Recycle.”
• Do not place the container with materials to be recycled.
• Do not use containers made of glass or clear plastic.
• Keep these containers out of the reach of children and pets.
Iowa: No guidance on safe disposal of used syringes. Individuals are advised to contact local solid waste
authorities for safe syringe disposal procedures.
Kansas: No guidance on the disposal of syringes used in households.
Kentucky: The Kentucky Department for Environmental Protection, Division of Waste Management, has
created a document entitled, Medical Waste Management. This document provides guidance on how to safely
dispose of sharps (syringes and lancets). The guidance provides the following recommendations:
• A commercially available disposal system can be purchased through your local pharmacy.
• An alternative is a hard plastic container such as an empty laundry detergent bottle.
• Label the container to indicate that it contains sharps.
• Communicate with your garbage collector that you will be setting out sharps containers on a regular basis.
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Louisiana: The Louisiana Department of Environmental Quality provides guidance on how individuals can
safely dispose of syringes. The guidance states:
While used needles, syringes, lancets and other sharp implements may be safely disposed with other solid
wastes from the home, it is important to exercise care in packaging needles, syringes, and lancets for disposal.
The safe packaging of these wastes may be accomplished very simply in the home.
• Use a rigid plastic bottle with a tight fitting cap, such as an empty laundry detergent or fabric softener bottle,
to store and dispose of sharps.
• When the bottle is full, cap it tightly, and place it with your other solid waste for disposal.
• Needles and syringes need not be recapped.
• Do not put sharp objects in any container that will be recycled or returned to a store.
Maine: The Department of Environmental Protection (DEP) for the state of Maine has developed a document
entitled Household Biomedical Waste Management. The document provides guidance to residents on how to
safely dispose of household-generated syringes. Please follow this link for more
information: http://www.maine.gov/dep/rwm/biomedical/iphousehold.rtf. Telephone: (207) 287-7854.
Maryland: The Maryland Department of the Environment (MDE) has developed a document called
Maryland Envirothon 2001 Resource Packet and Study Guide for Urban Non-Point Pollution—
Household/Home Site. This document provides guidance on how to safely dispose of medical waste, including
syringes used at home. The document recommends that sharps be:
• wrapped securely in paper or other material;
• placed in tough plastic or metal containers with tightly sealed lids, such as detergent containers or coffee
cans; and
• placed safely in the trash can.
It also includes these warnings:
• Sharps cannot be recycled.
• Sharps should only be properly disposed of.
• Sharps should not be tossed in the trash haphazardly.
• Sharps should not be placed in soft containers such as milk jugs or cartons that can be easily punctured.
It also suggests that individuals get more information on pharmaceuticals and medical wastes (including
sharps) by visiting these two topics on the U.S. Environmental Protection Agency website:
• Pharmaceuticals and Personal Care Products
• Community Options for Safe Needle Disposal
Massachusetts: NOTE: Massachusetts is in the process of redefining needle disposal laws for patients
injecting at home. The Department of Public Health and the Department of Environmental Protection are
working together to develop new disposal options for Massachusetts residents. Until the new laws are
implemented, follow the recommendations below:
The Massachusetts Department of Environmental Protection (MA-DEP) provides guidance about safe syringe
disposal on its website, Recycling: Home Medical Waste
(http://www.mass.gov/dep/recycle/hazardous/medical.htm). The guidance describes handling and disposal
options for home pharmaceuticals, sharps, and other medical wastes such as soiled bandages and medical
gloves.
The guidance provides these recommendations:
• Keep sharp objects such as needles, syringes, and lancets in secure containers out of the reach of children.
Do not use glass.
• Place all sharp objects such as needles, syringes, and lancets in rigid plastic or metal containers with a
screw-on or secure lid. Detergent or soda bottles are good. Reinforce the lid with heavy-duty tape. Label
container NOT FOR RECYCLING and dispose of in the trash.
For more information, check with the Visiting Nurse Association or the MA Department of Public Health,
Division of Community Sanitation at (617) 727-2660.
The Massachusetts Department of Public Health (MA-DPH) has also published guidance entitled Home Guide
for Proper Disposal of Needles and Lancets (http://www.state.ma.us/dph/dcs/syring.htm). The guidance gives
the following tips and recommendations:
• Obtain a puncture-resistant plastic or metal container such as an empty detergent or bleach container with a
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screw-on or tightly secured lid, or an empty coffee can.
• Many local pharmacies also sell home sharps containers.
• Place used lancets, needles, and syringes in container.
• Drop sharps in container immediately after use.
• Dispose of syringes as one unit.
• Tightly seal the container when 3/4 full.
• When you are using a coffee can, reinforce the lid with heavy duct or electrical tape (you should completely
cover the lid with tape to prevent punctures).
Contact your local board of health for trash disposal ordinances and further instructions.
Warnings:
• Do not use clear plastic or glass containers.
• Do not attempt to remove, bend, break or recap the needle.
• Store out of reach of children.
Michigan: Michigan state published a PDF for reference at http://www.michigan.gov/documents/deq/whmstsw-sharps-collection-list_196524_7.pdf.
Minnesota: The Minnesota Pollution Control Agency published guidance on home needle disposal at
http://www.pca.state.mn.us/oea/hhw/sharps.cfm.
Mississippi:
• Persons receiving health care from a home health agency are advised to determine whether
these services provide a means of disposal for syringes or information on proper disposal methods.
• Persons are also advised to contact their local pharmacy or physician for syringe collection services or
sharps disposal containers.
If the services or persons listed above cannot provide assistance in the disposal of syringes, individuals are
encouraged to manage household medical waste in the following manner:
• Place sharps in hard plastic, puncture-resistant containers such as bleach, fabric softener and liquid soap
bottles or metal containers with securely fitting lids.
• Soak sharps in a bleach solution that is one part bleach and ten parts water.
• Do not place sharps in containers that will be recycled or returned to a store.
• Do not place sharps in clear plastic or glass containers.
• Do not label the containers as “Medical Waste” or “Infectious Waste.” If the sharps container already has a
label, place the container in a plastic bag that is securely fastened.
Missouri: The state of Missouri has not developed written guidance on the disposal of household generated
syringes.
Montana: Montana does not provide written guidance for community syringe disposal.
However, representatives from the state’s Department of Environmental Quality, Community Services Bureau,
recommend that individuals place used syringes in sharps containers purchased from pharmacies and check
with their local health department to determine a safe means of disposal.
Nebraska: In 2000, the Waste Management Division of the Nebraska Department of Environmental Quality
(DEQ) developed a fact sheet entitled Handling Household Medical Waste (Click on "Publications/Forms" "Integrated Waste Management" - "Fact Sheets" - "Handling Household Medical Waste"). This fact sheet
provides guidance to residents on how to safely dispose of household-generated “infectious waste," including
syringes. The DEQ defines infectious waste as "any medical waste that is capable of causing disease in
another human being if that person comes into contact with the waste."
The guidance includes these recommendations:
• Place the waste in a rigid or semi-rigid puncture-resistant and leak-proof container.
• Mark the container prominently with the universal biohazard symbol.
• Label the container "Infectious Waste" or "Biohazard Waste."
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• Seal the container.
• Ensure that the outside of the container is free from contamination.
DEQ also recommends that any type of sharp medical waste such as needles or lancets should be sealed in a
puncture resistant container whether it is infectious or not. This will protect family members and waste handlers
from possible cuts or punctures.
Nevada: Nevada does not currently provide written guidance on community syringe disposal.
New Hampshire: The New Hampshire Department of Health and Human Services provides written guidance
on safe syringe disposal in a brochure at http://www.des.state.nh.us/factsheets/sw/sw-31.htm.
New Jersey: The New Jersey Department of Health and Senior Services publishes guidance at
http://www.state.nj.us/health/eoh/phss/syringe.pdf.
New Mexico: New Mexico’s Environment Department, Solid Waste Bureau, has developed a document called
Solid Waste Bureau Guidance on Disposal of Medical Sharps Generated in Private Homes; Disposal Tips for
Home Health Care.
This document provides tips on how to dispose of syringes used during home health care. The guidance
includes these recommendations:
• Place needles and syringes in a hard plastic or metal container with a screw-on cap or tightly secured lid.
• Reinforce the lid of the container with heavy-duty tape.
• Label the container “Not for Recycling.”
The guidance includes these warnings:
• Do not place the container with materials to be recycled.
• Do not use containers made of glass or clear plastic.
• Keep these containers out of the reach of children and pets.
• Place the container in a cardboard box, secure the cardboard box with tape, and dispose of the box in the
household trash.
To get a copy of Solid Waste Bureau Guidance on Disposal of Medical Sharps Generated in Private Homes,
contact:
New Mexico Environment Department
Solid Waste Bureau
P.O. Box 26110
Santa Fe, New Mexico 87502-6110
Tel: (505) 827-2924
New York: Two New York state agencies publish the same guidance on community syringe disposal:
1. New York State Department of Health, Expanded Syringe Access Program (ESAP) – “Household Sharps:
Dispose of Them Safely” (http://www.health.state.ny.us/diseases/aids/index.htm)
2. New York Department of Environmental Conservation
The guidance states:
Millions of individuals with serious health conditions manage their care at home. For example, people with
diabetes use syringes and needles to inject their own insulin, and lancets to test their blood glucose every day.
These syringes, needles and lancets are called "household sharps." Household sharps must be properly
contained and discarded to protect trash handlers and waste treatment workers against disease or injury.
Careful disposal also prevents re-use of syringes that can transmit the human immunodeficiency virus (HIV), or
hepatitis B or hepatitis C
(http://www.nyhealth.gov/diseases/aids/harm_reduction/needles_syringes/sharps/directory_sharpscollection.ht
m#directory). In New York State, all hospitals and nursing homes must accept household sharps. Contact local
hospitals and nursing homes for days and hours of acceptance, location of sharps collection sites and type of
containers that will be accepted.
Containment
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Contain the used sharps safely in your own home:
• Use a puncture-resistant plastic container with a tight-fitting screw top. A plastic soda bottle or bleach bottle
will work. Some pharmacies sell small plastic sharps disposal containers. Don’t use glass, because it can
break. Coffee cans are not recommended, because the plastic lids come off too easily and may leak.
• Label the container clearly. Write "Contains Sharps" with a waterproof marker directly on the container or on
masking tape that is placed on the container.
• Put used syringes, needles or lancets immediately into your container. Screw on the top.
• Don’t clip, bend or recap the syringes, needles or lancets because you could injure yourself.
• If you are away from home or there are no sharps containers available, carefully recap all syringes, needles
or lancets and place them in a plastic bag to carry home or to a sharps collection site.
- The person who uses the syringes, needles or lancets should place them directly into a container.
- Keep the container away from children!
- When the container is three-quarters full, screw on the cap tightly. Seal it with heavy-duty tape to be extrasafe.
Disposal
There are different options for getting rid of sharps. Some cities and towns have more options than others.
Here are the best bets for safety, health and protection of the environment.
• Call your health care provider, pharmacy or clinic to find local hospitals or nursing homes that accept properly
contained sharps for disposal. The hospital or nursing home receiving such containers must dispose of the
sharps properly.
• Ask your diabetes educator or local American Diabetes Association chapter about sharps collection programs
in your area.
• Call your local public works department or trash collector. (Check the blue pages of the telephone book for
their numbers.)
Some communities have special household medical waste collection or drop-off days.
• Call your local health department and ask for the health educator. Ask about sharps collection programs in
your county.
New York State law allows disposal of household sharps with household trash. Local laws, however, may
prohibit this. Consult your local public works department, sanitation department or trash collector for
information about laws that apply in your area.
Remember: Do Not Put the Sharps Container Out With The Recyclable Plastics. Sharps Are Not Recyclable.
North Carolina: The Waste Management Division of North Carolina’s Department of Environment and
Natural Resources (DENR) has developed a document on medical waste entitled Look Here First
(http://wastenot.enr.state.nc.us/SWHOME/look97.htm), which includes a section on safe disposal of syringes
used in the home.
Individuals who use syringes at home are urged to put them in a container that is “rigid, leak-proof when in an
upright position, and puncture-resistant.” This container may then be labeled and packaged in accordance with
any relevant U.S. Occupation Safety and Health Administration (OSHA) requirements.
North Dakota: North Dakota has not established regulations for disposing infectious waste.
Ohio: The Ohio Environmental Protection Agency (EPA) publishes guidance on its infectious waste web site
http://www.epa.state.oh.us/dsiwm/pages/iwpro.html
The guidance suggests the following:
A person who generates sharps waste ("sharps" include lancets, hypodermic needles, syringes, scalpel
blades, and non-household glass articles that have been broken) for the purpose of their own care or treatment
in their home is considered a home sharps user. For example, this would include an insulin-dependent diabetic
or a terminally ill person being cared for and given injections by family members. Disposing of loose needles
and syringes into the household waste poses a risk to family members and solid waste workers who must
handle the waste. While Ohio law allows the disposal of sharps used by an individual for purposes of his/her
own care or treatment in their home into the solid waste stream, it is important to recognize the hazard they
pose to solid waste workers. Solid waste workers handle waste containers without knowledge of the contents.
It is recommended that home-generated sharps be packaged into a rigid container and marked with the word
“Sharps” prior to disposal into the solid waste stream. Common household containers which meet the
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description of rigid are liquid detergent & bleach bottles, two-liter pop bottles, and coffee cans (if the lid is
securely taped to the can). In addition, the person may contact their local health department or hospital to
inquire if they would accept the home-generated sharps.
The Ohio EPA also publishes a fact sheet that expands upon its published guidance. “Disposal Tips for
Household Generated Sharps” (http://www.epa.state.oh.us/dsiwm/document/guidance/gd_462.pdf) provides
information under the following headings.
• What are sharps?
• Who are home sharp users?
• What are my alternatives to a purchased sharps container?
• What are some other disposal alternatives for sharps?
• Can I put “sharps” into the trash?
• Why is it allowable to throw “sharps” into the trash and not properly package them?
• If I choose to package my “sharps” in a plastic bottle, will the bottle get recycled?
Oklahoma: Solidification of sharps is required for small quantity generators (under 60 pounds). Oklahoma
does not provide written guidance on community syringe disposal. However, the Department of Environmental
Quality, Land Protection Division, recommends that individuals who use syringes at home place their syringes
in rigid, puncture-proof containers, such as a liquid detergent bottle, and then fill the container with a matrix,
such as cement or plaster.
Oregon: The Oregon Department of Environmental Quality (DEQ) has a fact sheet on disposing of infectious
waste, including sharps, entitled Infectious Waste Disposal In Oregon.
(http://www.deq.state.or.us/lq/sw/infectiouswaste/index.htm).
The guidance provides the following information:
• Sharps placed in containers can be put in a landfill without being treated (by incineration or autoclaving) if the
containers are:
► tightly closed and sealed;
► leak-proof;
► puncture-resistant; and
► clearly identified as infectious waste.
Landfill operator must store these containers in a separate area of the landfill.
• Rigid plastic sharps containers are available from many pharmacies, as well as medical supply stores, some
garbage hauling companies, or licensed biomedical waste management companies.
• Individuals can also drop off filled sharps containers at DEQ-sponsored Household Hazardous Waste
Collection Events. (For more information, call 800-732-9253.)
• Additionally, individuals may contact a licensed medical waste management company for information about
pickup and disposal of sharps.
The guidance provides the following warning:
We are pleased to provide the information in this fact sheet to help you understand more about infectious
waste in Oregon. Ultimately, however, it is YOU, as a generator of infectious waste, who is responsible for
seeing that your waste is collected, handled, stored, treated, and disposed in accordance with all federal, state
and local regulations. Questions? Contact the DEQ office closest to your facility.
For additional information about which facilities in the greater Portland metropolitan area accept treated
infectious waste and the types of waste that can be placed in garbage, contact:
Metro's Regional Environmental Management Department (503) 797-1650.
For information about Metro's Sharps Container Exchange Program, contact: Metro Recycling Hotline (503)
234-3000.
Oregon Department of Human Services –
The Oregon Department of Human Services, Health Division, also provides similar information on disposing of
infectious waste. This brochure, Infectious Waste Disposal,
(http://oregon.gov/DHS/ph/acd/infectwaste/infect1.pdf), is a guide for all those who generate used sharps,
including individuals.
American Academy of Provider Offices and Laboratories
12
Pennsylvania: The state of Pennsylvania has not developed written guidance on the disposal of householdgenerated syringes.
Rhode Island: The Diabetes Foundation of Rhode Island, in conjunction with the Rhode Island Department of
Health and other public and private sector organizations, has developed a community sharps collection
program with guidance for individuals called Sharp Smart: The Nation’s First Statewide Residential Needle
Disposal Program (soon to be named Eureka).
The guidance states:
“…SharpSmart is a program that provides small household containers, called sharps containers, to hold your
needles and lancets, and collection receptacles located throughout Rhode Island for you to safely throw away
your full Sharps containers…”
If you want to make sure that you are disposing of your sharps the right way, follow these simple rules:
DO use a container that is puncture-resistant and is not see-through
• 1 gallon bleach or liquid detergent bottles
• sealed and taped coffee can
• sharps container (preferred container)
DO keep containers in areas that are child and animal proof.
DON’T put sharps in soda cans or bottles, juice bottles, glass containers, or milk cartons.
DON’T put sharps containers in your recycling bin.
DON’T flush needles or lancets down the toilet. (Sharps that are flushed down the toilet may end up on our
beaches and riverbanks.)
DON’T throw loose needles or lancets in the recycling bin, trash, or SharpSmart receptacle.
DON’T empty the sharps container in the SharpSmart receptacle. Throw away the full container.
A list of sharps collection locations in Rhode Island is published on the SharpSmart web page (soon to be
renamed Eureka).
South Carolina: The South Carolina Department of Health and Environmental Control has developed a “Get
the Point” program that provides guidance on safely disposing of used syringes at home. The guidance
provides these recommendations:
• Sticker – Label an empty two-liter soda bottle with the warning “DO NOT RECYCLE” using either a
purchased “pre-made” warning sticker or one that you make.
• Store – Carefully put each of your used syringes into the bottle.
• Seal – Put tape over the closed bottle cap when the bottle is full.
• Safe Disposal – Dispose of the filled bottle in your household trash.
Now your syringes are safely held in a container that protects people from needle sticks and is unlikely to
break open on its way to the landfill.
The guidance includes these warnings:
Remember • Keep your container out of reach of small children and pets!
• Never flush your syringes down the toilet!
• Don’t fill your container to the top! Allow two to three inches between the syringes and the neck of the soda
bottle.
• Put a lid on it! After you use a syringe or lancet, put it directly into a two-liter soda bottle with a tight cap.
• Pitch it! When the soda bottle is full and tightly sealed, throw it out in the trash.
South Dakota: South Dakota has not published guidance for individuals on safely disposing used syringes.
However, the state’s Department of Environment and Natural Resources encourages individuals to disinfect
used sharps before placing them into a rigid, puncture-resistant container and disposing of them in the
household trash.
Tennessee: The Tennessee Department of Environment and Conservation has not developed syringe
disposal guidance for individuals who use syringes at home.
Texas: Texas has not published information to guide individuals in safely disposing of syringes used at home.
However, the Texas Natural Resource Conservation Commission and the Texas Department of Health
recommend using guidance contained in the U.S. Environmental Protection Agency’s former needle disposal
American Academy of Provider Offices and Laboratories
13
recommendations which include the following:
• Place needles and syringes in a hard plastic or metal container with a screw-on cap or tightly secured lid.
• Reinforce the lid of the container with heavy-duty tape.
• Label the container “Not for Recycling.”
The guidance includes these warnings:
• Do not place the container with materials to be recycled.
• Do not use containers made of glass or clear plastic.
• Keep these containers out of the reach of children and pets.
Utah: The Utah Department of Environmental Quality, Division of Solid and Hazardous Waste, Solid Waste
Section provides guidance, entitled "Infectious Waste Management" provides the following guidance for
individuals who use syringes during home health care:
Infectious waste generated by home health care activities is not regulated by the state. Local health
departments may have rules that differ from state rules. Please contact them for specific rules. However, the
following procedures should be followed to minimize the potential risk from exposure to infectious waste.
• Isolate sharps in leak-proof, rigid, puncture-resistant containers such as a plastic soft drink bottle, a plastic
milk bottle, or a sharps container commercially available at many pharmacies.
• When the container is full of sharps, the lid should be tightly secured and taped on. The sharps container may
then be placed in the regular household waste container for curbside collection.
Vermont: Vermont provides guidance for handling and disposing of medical waste, including syringes.
Medical waste is regulated under the state’s Regulated Medical Waste Procedures. The guidance suggests
placing sharps in hard plastic, opaque containers, such as a detergent bottle, and disposing of the container in
the regular household trash.
The Vermont Department of Health Diabetes Program also has created a consumer booklet entitled Learning
to Live Well with Diabetes. This booklet provides guidance on how to dispose of needles and syringes.
The guidance provides these recommendations:
• Place needles, syringes, lancets and other sharp objects in hard plastic opaque containers with a screw-on or
tightly secured lid, for example, a detergent bottle.
• Before discarding the container, be sure to reinforce the lid with heavy-duty tape. This container goes into the
regular household trash.
• You may even want to label the container: "NOT FOR RECYCLING."
For copies of this booklet,
Email: [email protected]@[email protected]
Virginia: Virginia has no published guidance for individuals on safe disposal of syringes used at home.
Washington: The state of Washington has not published any state-level guidance for individuals on how to
safely dispose of used syringes.
West Virginia: The West Virginia Department of Health and Human Resources, Public Health Sanitation
Division, provides management guidelines for disposing of household generated syringes in a brochure
entitled “A Household Guide for the Proper Disposal of Syringes and Sharps”
(http://www.wvdhhr.org/wvimw/pdf/syringe_disposal.pdf).
The guidance includes these recommendations:
• Place syringes and needles in hard plastic or metal containers that have screw on caps or tightly fitting lids
(Examples include: liquid detergent bottles, bleach bottles, or coffee cans. If a coffee can is used, reinforce the
lid with heavy-duty tape.)
• Place the container in close proximity to where you will be using the syringes.
• Place the sharps directly into the container immediately after use.
• When the container is nearly full, add a sanitizing solution made by adding one teaspoon of 5.25% bleach to
one pint of water and then seal the container.
• Label the container, “Not Recyclable Treated Sharps” with a permanent marker.
• Place the container in a plastic bag and seal the bag with tape.
• Place the bag in the garbage.
The guidance includes these warnings:
American Academy of Provider Offices and Laboratories
14
• Do not place syringes in clear plastic or glass containers.
• Be sure to store the containers in a secure location that is both child and animal proof.
• Do not recap, remove, bend or break the needle.
Wisconsin: The Wisconsin Department of Natural Resources (WI-DNR) has developed a brochure, Disposing
of Household Sharps (PUBL WA-804), which explain the health risks of unsafe syringe disposal, provides four
steps to safe packaging, and describes disposal options. The state encourages hospitals, fire stations, and
other community facilities to establish syringe container collection programs. To foster this effort, Wisconsin
provides information about sharps collection stations throughout the state (cover sheet [PUBL WA-808a] and
list of facilities [PUBL WA-808b])
Disposing of Household Sharps includes the following information:
Used Sharps Pose Health Risk
As the number of home health care patients rises, sharps (needles, syringes and lancets) are increasingly
being mixed in with household garbage and recyclables or flushed down the toilet. These sharps pose a health
risk to garbage haulers and workers in recycling facilities who might be accidentally stuck by them. All
"needlestick" injuries demand expensive testing, cause long-term emotional stress and increase the risk of
exposure to infectious diseases such as Hepatitis B and HIV from contaminated needles.
To reduce such health risks, the state adopted rules in 1994 about how to package, treat and dispose of
sharps, including household sharps. Sharps must be packaged safely and treated either by incineration at a
licensed medical waste incinerator or by methods which render the sharps non-infectious and both broken and
unable to be reused. Sharps must be treated before they are disposed of in a landfill. Other infectious waste
generated at home may be bagged and put out with the regular trash.
Four Steps to Safe Packaging
Follow these four steps for packaging your used, or discarded unused sharps:
1. Clip the needle points with needle clippers, or recap or re-sheath discarded sharps to help prevent “needle
sticks.” Recapping needles is discouraged in hospitals and other health care facilities because medical
workers might stick themselves with contaminated needles, but individuals who administer their own
medications are not at risk from their own needles.
2. Place the sharps in rigid puncture-resistant containers with secure lids or caps. Acceptable containers
include commercially-available sharps containers or heavy plastic detergent or bleach bottles with screw caps.
Unacceptable containers include coffee cans (their lids are too easily punctured), plastic milk jugs, plastic
bags, pop cans or soda bottles. Note: DO NOT add bleach to the container. Bleach may not completely
disinfect needles, and it could spill and injure you or waste handlers.
3. Visibly label the sharps container with the words “biohazard,” “infectious waste” or “sharps,” or with the
biohazard emblem. It’s also a good idea to label detergent bottles with the words “Do not recycle” so that they
are not accidentally included with recyclables.
4. When the container is full, sealed and labeled, store it out of reach of children and dispose of it properly. Do
not put the container out with the trash or with recyclables. Instead, take it to a registered “sharps collection
station” or make other arrangements if such stations aren’t available.
Disposal Options
Ask your local doctor or clinic, diabetic support group, pharmacy, hospital, public health department, solid
waste or streets department or environmental services department about local options. Some of them may be
registered sharps collection stations. You may also call your local DNR office (ask for the waste management
specialist) or the American Diabetes Association (1-888-342-2383) for locations of registered sharps collection
stations. Registered sharps collection stations may only charge fees to recover costs, such as costs for the
container, transportation and treatment. Some offer the service for free.
If there are no local sharps collection programs, you may take sharps directly to a licensed infectious waste
treatment facility or contract with a licensed infectious waste hauler to transport them for you. (People
transporting more than 50 pounds per month must get a license from the DNR). Ask your doctor where she or
he sends sharps, or look in the yellow pages under “waste disposal” or “medical waste.”
Another option provided by some disposal companies is a mail-in sharps disposal program. The company
provides containers and packaging which meet U.S. Postal regulations. Additional sharps collection
information can be downloaded at http://dnr.wi.gov/org/aw/wm/faclists/SharpsCollection033108.pdf
Wyoming: Wyoming has not established regulations for the disposing of infectious wastes. However, it does
provide recommendations for its management and disposal in a document entitled Infectious Waste
American Academy of Provider Offices and Laboratories
15
Management…Questions, Answers and Options.
The document provides these infectious waste management options:
• Treat the infectious waste, if possible, through technologies that include incineration, steam sterilization,
thermal inactivation, gas/vapor sterilization, irradiation sterilization, and chemical disinfection.
• Dispose of infectious waste at a landfill provided the operator is notified and the facility accepts such wastes.
• Contact a commercial infectious waste contractor to transport the infectious waste to a treatment or disposal
facility. (Persons may contact the Wyoming Department of Environmental Quality for a listing of local
contractors.)
The document provides these recommendations for infectious waste disposal at a landfill:
Contact the manager of the local waste management system for any additional disposal requirements.
• Treat infectious waste prior to disposal if this is possible.
• Place sharps in rigid containers that are appropriately labeled.
• Notify all persons handling infectious waste as to its presence.
• Dispose of infectious waste in specially designated areas, if possible.
• At the landfill, cover infectious wastes with at least six inches of soil as soon as possible.
To get Infectious Waste Management…Questions, Answers and Options, contact the Wyoming Department of
Environmental Quality, Solid & Hazardous Waste Division (WDEQ/SHWD) at (307) 777-7752.
American Academy of Provider Offices and Laboratories
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INCIDENT/CORRECTIVE ACTION REPORT
PHYSICIAN NAME:
OFFICE:
DATE:
DEPARTMENT:
INDIV. OR EQUIP. INVOLVED:
PROBLEM:
DATE OF INCIDENT:
CORRECTIVE ACTION:
RESOLUTION:
DATE OF RESOLUTION:
INITIALS:
COMMENTS:
OTHER:
American Academy of Provider Offices and Laboratories
17
HAZARD COMMUNICATION REGULATIONS
The Hazard Communication Regulations can be confusing. Which chemicals must be included on your
Chemical List and which can be omitted? This should help! (Lists are not all inclusive, just examples.)
Put these on your list and get MSDSs:
Omit these if you use them as you would at
home:
Acetone (might be nail polish)
Albuterol
All Antineoplastic Drugs
Aluminum Chloride
Ammonia Ampules
Atropine Sulfate
Benadryl
Benzocaine
Betadine
Bleach
Botox
Butane Gas
Celestone
CitriCide, CitriFoam, CitriGuard
Cyanocobalamin
Cytology Fixative
DepoMedrol
Enzymatic Detergent
Estradiol
Ethyl Oxide
Formalin/Formaldehyde
Gentian Violet
Glutaraldehyde—Cidex, Metricide, Omnicide,
etc.
Hydrogen Peroxide 30%
Insulin
Isopropyl Alcohol
Kenalog
Lidocaine, Zylocaine, Marcaine, etc.
Lysol Professional Products
Mercury in Blood Pressure Cuffs or
Thermometers (if present)
Methanol, Denatured Alcohol
Monsel’s/Ferric Subsulfate
Nitrous Oxide Gas, Compressed Oxygen Gas
Phenol
Professional Disinfecting Wipes—Caviwipes,
Sani-Wipes, Sani-Cloths
Professional Janitorial Products
Propane
Silver Nitrate Applicators
Testosterone
Tincture of Benzoin
Trichloracetic/Bichloracetic Acid
Ultrasound Transmission Gel
X-ray Fixer and Developer
Air Fresheners
Aspirin, Tylenol, Ibuprofen
Carpet Cleaner
Copier Toner
Cosmetics
Detergent and Fabric Softener
Dishwashing Liquid or Powder
Floor Cleaner from the Discount Store
Food and Beverages, including Glucola
Furniture Polish—e.g., Pledge
Hand Soap, Hand Sanitizer, and Lotion
Hydrogen Peroxide 3%
Liquid Correction Products (Wite Out; use is
forbidden by Medicare)
Most Eye Drops and Ointments
Mr. Clean, Formula 409
Neomycin/Triple Antibiotic Ointment
Personal Use Items brought by Employees
Petroleum Jelly; K-Y Jelly
PPD for TB Skin Testing
Saline
Sealed Sample Medications
Sterile Water, Deonized Water
Surface Wipes from the Discount Store
Tablets and Capsules
Toilet Bowl Cleaner
Toothpaste and Mouth Wash
Vaccines: HBV, Flu, etc.
WD-40
Window Cleaner (such as Windex)
American Academy of Provider Offices and Laboratories
CAVEAT
If you have large quantities of these
chemicals, if you use them differently than
the manufacturer’s intended use, or if you
use them differently or in greater volumes
or frequency than the way you would use
them at home, put them on the list and get
the MSDS.
If an OSHA inspector perceives a chemical
as a hazard, s/he will cite the employer for
failure to have the MSDS. Please see OSHA
clarification concerning chemicals in the
Hazard Communication section of the
OSHA Manual.
18
Methicillin Resistant Staphylococcus aureus
Methicillin Resistant Staphylococcus aureus, or MRSA, has reached epidemic proportions. It is known in the
healthcare industry as a “superbug.” MRSA is now a problem worldwide.
MRSA started out as common Staphylococcus aureus, or S. aureus, a very common bacterium living on the
skin and in the nasal passages of many humans, usually causing no problems. However, when the bacteria
enter the skin through a wound, a surgical procedure, or an instrument inserted into the body, it may become
pathogenic and cause an infection. This is especially common when the patient has had surgery or an injury or
is immunocompromised.
Penicillin has traditionally been the antibiotic of choice. However, there is now a new subset of S. aureus:
Methicillin Resistant Staph. aureus, or MRSA, for which penicillin is ineffective. MRSA is often not susceptible
to additional forms of penicillin, including oxacillin. This does not make the bacteria more contagious or more
virulent, just more difficult to treat.
In addition to MRSA, there is VRE, or Vancomycin Resistant Enterococcus. S. aureus also has a vancomycin
resistant form: VRSA. There is also the INH-resistant Mycobacterium tuberculosis, drug resistant gonorrhea,
and even drug resistant HIV.
According to some sources, there are several reasons bacteria may develop antibiotic resistance. The most
common seems to be an over- exposure to antibiotics.
1. Antibiotics have been overprescribed in the past. Antibiotics are not effective against viruses, and
physicians have generally discontinued prescribing them for colds and other viral infections. The thought
behind prescribing antibiotics for viruses was to prevent concurrent bacterial infections due to the toll the
virus takes on the immune system.
2. When the symptoms subside, patients may discontinue the medication. This allows those bacteria that
have not been killed to develop resistance and multiply.
3. There is the possibility of overprescribing a particular antibiotic, which may also lead to resistance. Some
studies are trying to show that a shorter course of the antibiotic might be just as effective as the traditional
7—10 day course but with a lower chance for resistance to develop.
4. Antibiotics are often fed to animals to fatten them up for the market or to prevent infections in areas with
poor hygiene. These antibiotics are then found in the meat and in the water system.
MRSA is primarily transmitted by skin contact: contact with infected skin or with contaminated surfaces or
items. It is often transmitted from person to person in hospitals and long-term care facilities, where it is
described as a Healthcare Acquired Infection (HAI). MRSA is also transmitted in crowded living conditions and
where hygiene is poor, and it also may be airborne. When an uninfected person gets the infection from a
person who is infected, it is usually through skin contact and is considered a secondary infection. This is often
called “Community Acquired MRSA.”
MRSA is usually a skin infection but may also be in the bones, joints, bloodstream, heart valves, urinary tract,
and lungs. As a skin infection, it may start as small red bumps, like pimples or boils, and may be mistaken for
spider bites. If untreated, it then becomes deep, painful abscesses and spreads to other parts of the body. It
may also cause cellulitis, impetigo, follifulitis, furunculosis and infected lacerations. It may turn into necrotizing
fascilitis, or “flesh eating bacteria.”
Symptoms are useful in the diagnosis of MRSA, especially if they continue despite continued antibiotic
therapy. However, the most definitive diagnosis has traditionally been a culture of tissue or nasal secretions,
coupled with a needed sensitivity. It takes up to 48 hours. There are some faster tests, however. Bectin
Dickinson (BD) has a culture plate that yields a result in 24 hours, and Geneohm Sciences has developed a
plymerase chain reaction–based test that will give a result within two hours, using a single nasal swab.
American Academy of Provider Offices and Laboratories
19
According to one source, as many as 90,000 Americans die each year from HAIs, with MRSA being the
number one offender. Approximately one out of 20 Americans in hospitals will acquire an HAI. The cost per
year is between $5 billion and $10 billion, seven times the cost without the HAIs. A MRSA infection increases
the chance of a hospital-related death by 7%. Men are twice as likely as women to develop MRSA.
Even though MRSA cannot be effectively treated by the penicillins, there are other antibiotics that may be
effective. Vancomycin, considered the “last line of defense,” is usually used, but now MRSA is becoming
VRSA. An antiseptic wash or liniment may be used to remove the MRSA from the skin and nose, even when it
has not become problematic, to perhaps prevent a difficult-to-treat infection. Most practitioners also surgically
drain the infected sites.
Merck has recently developed a new super antibiotic, only the third new type of antibiotic in 40 years.
Platenimycin is produced by Streptomyces platensis and actinomycetes bacteria. It inhibits many Gram
positive organisms, including many Staph strains such as MRSA, with almost no negative side effects.
Prevention is always better than a cure! Handwashing, disinfecting surfaces and items, and personal protective
equipment are good measures. Prevention of drug resistance, including MRSA, begins with prudent use of
antibiotics. Healthcare practitioners are doing their part by prescribing antibiotics when necessary. Patients
need to understand that antibiotics are not always useful, so patient education is important.
Healthcare workers can help prevent MRSA and other HAIs by following traditional infection control measures:
1. Always wash your hands after caring for each patient. Use antimicrobial soap and water if your gloves were
visibly contaminated or if your hands became contaminated without gloves.
2. Wear gloves! If you know a patient has an infectious disease, also wear a gown, and if the disease may be
airborne (as with TB and MRSA), wear a mask as well.
3. Carefully dispose of gloves and any disposable patient items used during patient care - within that room if
possible.
4. Clean surfaces in the patient care area daily with commercial disinfectant or 1:100 bleach (1 Tbsp. of
bleach in 1 gal. of water).
5. Launder reusable linens in hot water ( >160º) and add bleach.
CA-MRSA
An equally disturbing problem is CA-MSRA, or Community Acquired MRSA, a major cause of skin disease in
the United States. It usually occurs in places with crowded living conditions and/or poor hygiene, including
gymnasiums and locker rooms, jails and prisons, and military facilities. Unlike the HAI version, CA-MRSA
produces a toxin that destroys living tissue and white blood cells.
The Clorox Company has a new product, Clorox Pro Quaternary All-Purpose Disinfectant Cleaner, registered
with the Environmental Protection Agency to kill germs. Clorox says it will kill both healthcare-associated and
community-associated MRSA as well as many other disease-causing agents, including Hepatitis B and C, HIV1 and –2, SARS, and E.coli. According to Clorox, their new product is also a powerful cleaner.
The Centers for Disease Control is promoting a campaign to prevent the development of resistance from a
clinical angle:
1.
Prevent infection
2.
Diagnose and treat infection effectively
3.
Use antimicrobials wisely
4.
Prevent transmission
Complete information about the campaign is located on the CDC’s website, www.cdc.gov.
American Academy of Provider Offices and Laboratories
20
FREQUENTLY ASKED OSHA QUESTIONS
1. Are we required to provide employee TB skin testing?
Possibly not. OSHA does not have a formal tuberculosis standard but may use the General Duty Clause to
cite employers who are not adequately protecting employees from recognized hazards. Federal OSHA
currently relies on its compliance directive from 1996, which essentially exempts dental procedures unless
performed in a hospital or a correctional institute and medical practices that are not performing high risk
procedures (bronchoscopy, intubation, sputum induction, aerosolized treatments) on patients suspected or
confirmed for active tuberculosis infection.
The Centers for Disease Control and Prevention issued new guidelines in December 2005, stating that all
healthcare employers should provide initial TB testing for all healthcare workers. The CDC has no
enforcement authority. A few State OSHA programs have indicated that they are already following the new
recommendations: Alaska, Arizona, Massachusetts, Michigan, Nevada, New Mexico, South Carolina,
Vermont and Wyoming. However, we had no luck in verifying this on their web sites.
Washington’s State OSHA continues to use the older CDC guidelines, and Tennessee OSHA says they
will follow Federal OSHA’s lead. To date, other State programs have not responded to our query.
2. May we have coffee cups at the nurses’ station?
Whether you can have food and/or beverages in areas within the medical or dental practice depends not
upon what you call the area but rather how you use the area.
 If injections are administered at the nurses’ station, or bandages are changed there, for example,
no food or beverages are allowed.
 If the nurses’ station is used only for administrative tasks, such as talking to patients over the
phone or completing paperwork, food or beverages would not be forbidden by OSHA. However,
keep in mind all the other issues, such as general untidiness, insects, and potential damage to
computers and important papers.
3. Does OSHA allow employees to take home scrubs to launder them?
The purpose of the scrubs rather than a descriptor determines the answer.
 If the scrubs are used as personal protective equipment, the employer must purchase and
maintain or replace them. This means the employees must wear street clothing from home,
change into the scrubs at the practice, and change from scrubs to street clothing before leaving.
The employer must launder them on-site or send them to a commercial linen service.
 If, however, the scrubs are your uniform and you will add another garment, such as a labcoat or
gown over the scrubs, that extra garment becomes the personal protective equipment which must
be purchased and maintained or replaced by the employer. In this case, employees may launder
scrubs at home.
 Perhaps a more difficult determination—is it a part of your uniform or is it personal protective
equipment? Again—how is it used? If you remove it or cover it when performing tasks that may
cause splattering, that extra garment is your personal protective equipment, and the labcoat is part
of your uniform. If, however, the labcoat is meant to protect your other clothing—street clothes,
uniform, or scrubs—it is personal protective equipment and must be provided by and maintained
or replaced by the employer.
4. The last OSHA Bulletin stated that we are not required to maintain a Sharps Injury Log because we
are not required to maintain the OSHA 300 Log. Does this exempt us from documenting sharps
injuries?
American Academy of Provider Offices and Laboratories
21
Absolutely not! Employers are required to document details of all sharps injuries! The documentation
must include at least all information required for sharps injury logs. In the Bloodborne Pathogen section of
the DoctorsManagement OSHA Manual, there are forms for this purpose.
Some State programs DO require all healthcare facilities, including medical and dental offices with 11 or
more employees, to maintain the OSHA 300 Log. This includes Minnesota OSHA.
5. How often are we required to have OSHA training?
OSHA requires training for all employees when they are first hired (prior to being exposed to the hazards),
anytime new hazards (new chemicals, for example) are added to the work environment or the individual’s
job responsibilities change resulting in exposure to different hazards, anytime the regulations change, and
each year.
6. How should we discard expired medications?
OSHA does not address the disposal of wastes. The Environmental Protection Agency (EPA), the
Resource Conservation and Recovery Agency (RCRA), and various State agencies do. Your very best
resource for your locality is your waste hauler. Waste haulers are highly regulated themselves and will not
give you information that may put them at risk if you, their customer, does something inappropriate. Some
waste haulers will tell you to place expired medications in the biohazard bags, while others will tell you to
package it separately and label the container “Chemical Waste.” It depends upon local regulations and how
the waste hauler ultimately disposes of the waste.
7. Does OSHA require Hepatitis A Vaccine for healthcare workers?
Not at this time. HVA is transmitted through contaminated food and water, meaning that you are more
likely to be exposed through ingesting contaminated restaurant food than through patient care.
8. Does OSHA allow health care workers to wear “Crocs”?
Here is an excerpt from a letter from OSHA dated July 17, 2006, responding to this question. The same
response pertains to sandals, open-toe shoes, clogs, and flip flops.
“You had a specific question relating to the use of "Crocs" Brand shoes (those that have a partially open
heel but a covered toe) in a pharmacy setting. You asked for OSHA to interpret its guidelines on foot
protection.
OSHA does not have a specific policy, or guidelines, on the wearing of open-heeled shoes. However,
OSHA does have regulations pertaining to personal protective equipment, and more specifically, to
protective footwear. They are found at 29 CFR 1910.132 and 1910.136 (copies enclosed). 29 CFR
1910.136(a) requires the use of protective footwear when employees are working in areas where there is a
danger of foot injuries due to falling or rolling objects, or objects piercing the sole, and where there is a
possibility of the employee's feet being exposed to an electrical hazard.
In general, the standards require that foot protection be used whenever it is necessary by reason of hazard
of processes or environment which could cause foot injury. If you are exposed, however infrequently, to
those hazards during the course of your business activities, then, during that period of exposure, you
would be required to wear protective footwear. If an employee is not exposed to any hazards to the feet,
then the use of protective footwear would not be required.
Normally, the employer will determine which, if any, of the employees are exposed to a foot injury hazard.
Ultimately, the determination of appropriate footwear in the absence of any of the previously mentioned
hazards would be a matter for labor-management negotiation to which OSHA would not be a party.”
American Academy of Provider Offices and Laboratories
22
9. What are OSHA’s regulations about storing items under the sinks in the clinical areas?
We have been unable to find any OSHA regulations relating to the storage of items under the sink, nor
have we been able to link it to employee health and safety. This question seems to be triggered by
guidelines from some accrediting agency (possibly Joint Commission, formerly the Joint Commission on
the Accreditation of Health Care Organizations or JCAHO) or a managed care organization. One
explanation is that patient care items could be contaminated by potential leakage.
10. How often do we need to update our OSHA Manual?
OSHA requires all employers to evaluate hazards and produce a written protection program initially, and to
update the written program anytime the hazards change or when OSHA’s standards change. The last
standard change impacting healthcare was in 2001, with the release of the new Bloodborne Pathogen
Standard. The Hazardous Communications Standard requires employers to update their Chemical List
annually. The Bloodborne Pathogen Standard requires employers to review their exposure risk categories
every year to be sure they are still accurate and to update them if needed. This Standard also requires
employers to evaluate new safer medical devices periodically. Interpretations from OSHA indicate that this
means at least every year.
11. What are OSHA’s guidelines for tracking medication samples?
Again, this is a patient care issue, not an employee safety or health issue, and therefore it is not
addressed by OSHA at all. However, many managed care organizations and accrediting agencies are very
concerned about medication samples. Liability issues are involved as well. Because of the burden placed
on the doctors’ offices to keep up with samples, we have developed two tracking logs: one to document
your inventory and expiration dates, and the second to enable you to link lot numbers with patients in case
of a recall.
12. Does OSHA require us to have a special license to transport small amounts of biohazardous
waste from satellite offices to the central office for pick up by our waste hauler?
No. OSHA does not govern the transport of waste. The transport of hazardous waste, both biohazardous
waste and hazardous chemicals, is under the Department of Transportation (DOT) and the Environmental
Protection Agency (EPA). Your local EPA is your best resource for licensing questions. The federal
Hazardous Materials (HazMat) Regulations do not require placarding for private vehicles, such cars used
by home health agencies or laboratory couriers.
13. In one of the past issues of the OSHA Bulletin, you mentioned that OSHA is concerned with the
accuracy of information in the MSDSs. Will we be fined if OSHA inspects us and finds errors in our
MSDSs?
No. OSHA holds the manufacturer, not the employer or the distributor, responsible for the accuracy of the
information in the MSDS. However, if the distributor or employer has information indicating errors, he or
she should report that to the manufacturer and to OSHA. OSHA is working with manufacturers to improve
the reliability of this information.
14. Is there a safety needle for administering epidurals? We have not been able to find one, but
luckily we have not had any needle sticks. Would OSHA fine us?
Yes, there is a safety epidural needle, but we have not evaluated it or heard results from any practice that
has evaluated it. It is the “Periflex Safety Epidural Needle.” More information is available at
www.bbraunusa.com. OSHA requires every employer with employees at risk for exposure to bloodborne
pathogens to evaluate safer devices that are available and to use the ones that will work in their setting. If
there is only one manufacturer of a particular device, OSHA does not require the employer to use that
device. However, a perfect track record does not protect employees from poten- tial exposures in the
American Academy of Provider Offices and Laboratories
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future, so OSHA certainly could fine employers for failure to evaluate available devices at least every
year.
15.
How should we transport contaminated dental impressions?
According to “Guidelines for Infection Control in Dental Health-Care Settings-2003,” published in the
MMWR December 19, 2003/Vol. 52/No. RR-17, dental impressions must be handled as any other
biohazardous material. Impressions should be disinfected with an EPA-registered hospital disinfectant
that claims to be effective against tuberculosis. Ask the manufacturer of the impression material to
recommend a disinfectant that will not harm the material, then follow the instructions on the disinfectant’s
container (time, temperature, etc.). Rinse the impression thoroughly following disinfection.
If the impression cannot be disinfected, it must be handled with Universal Precautions. If it is to be
transported between locations by a commercial courier system, it comes under the Hazardous Materials
Regulations enforced by the Department of Transportation.
16. What are OSHA’s regulations concerning personal heaters?
OSHA does not govern personal heaters, but the local fire marshal does. Follow electrical safety
guidelines and use only those heaters approved by your local fire marshal.
17. What are OSHA requirements for Hepatitis B Vaccine?
Healthcare employers must offer Hepatitis B vaccination to all employees at risk for exposure to
bloodborne pathogens. The vaccine must be offered within 10 days of being assigned responsibilities
that pose a risk for exposure. It must be offered totally free of charge to the employee and under the
supervision of a healthcare professional authorized by State laws. There must be documentation that
the healthcare professional has evaluated the employee and determined that it is safe for the employee
to receive the vaccine. The employee has the right to decline the vaccine but must sign the declination
form.
The employer must provide a blood test 1- 2 months following the third shot. If the test does not show
that the employee is immune, the employer must offer a second series, following the same requirements
as for the first series. The employer must pay for the blood tests as well. If the employee still does not
show immunity, the employer must encourage the employee to seek further medical evaluation but is not
required to pay for it.
The employer must maintain documenation (shot records, test results, or signed declination) for the
duration of employment plus 30 years unless the employee stays with that employer less than 12
months from hire. In that case, the employer should offer the documentation to the employee when he
or she leaves. If the employee does not want the records, the employer should shred them.
18.
Is a routine booster dose of Hepatitis B Vaccine required?
This response is directly from OSHA.
“Because the U.S. Public Health Service (USPHS) does not recommend routine booster doses of
Hepatitis B Vaccine, they are not required at this time. However, if a routine booster dose of Hepatitis B
Vaccine is recommended by the USPHS at a future date, such booster doses must be made available at
no cost to those eligible employees with occupational exposure.”
19. Do we have to have an eyewash station?
If you have a chemical on the premises with a pH less than 2 or greater than 12, you must have an
eyewash station that is separately plumbed and operable with a foot pedal. Otherwise, a faucet adapter
American Academy of Provider Offices and Laboratories
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should suffice. Read your material safety data sheets! Many common chemicals used in healthcare are
eye irritants, requiring the employee to “flush with copious quantities of fresh water” or “flush for 15
mihutes with fresh water.” Hand-held squeeze bottles do not accommodate this requirement.
20. Do we have to use safer sharps? Can’t we just evaluate them?
Reponse from OSHA: (emphasis added)
“OSHA's bloodborne pathogens standard at 29CFR 1910.1030(c)(1)(iv) requires employers to evaluate
safer medical devices to eliminate or minimize employee exposure to blood or other potentially infectious
materials (OPIM). Employers must solicit input from non-managerial employees in the selection process
[29CFR 1910.1030(c)(1)(v)]. Engineering controls, including safety scalpels, must be implemented
where their use is feasible [29CFR 1910.1030(d)(2)(i)].
The Exposure Control Plan (1910.1030(c)(1)(i)) shall:

Reflect changes in technology that eliminate or reduce exposure to bloodborne
pathogens [1910.1030(c)(1)(iv)(A)].

Document annually consideration and implementation of appropriate commercially
available and effective safer medical devices designed to eliminate or minimize
occupational exposure [1910.1030(c)(1)(iv)(B)].

Solicit input from non-managerial employees responsible for direct patient care, who are
potentially exposed to injuries from contaminated sharps, in the identification,
evaluation, and selection of effective engineering and work practice controls and shall
document the solicitation in the Exposure Control Plan [1910.1030(c)(1)(v)].”
21. What are OSHA’s guidelines for the use of hand sanitizers?
Response on OSHA’s web site:
“The new Centers for Disease Control and Prevention (CDC) "Guideline for Hand Hygiene in HealthCare Settings" (Morbidity and Mortality Weekly Report, October 25, 2002) supports the use of alcoholbased hand rubs as an effective means for decontaminating hands in healthcare settings. Is this
consistent with the requirements for hand washing established in OSHA's bloodborne pathogens
standard?
Many of CDC's hand hygiene guidelines are for infection control and patient safety, which OSHA
standards do not specifically address. However, we feel that these guidelines which do address
occupational exposures to blood or other potentially infectious materials (OPIM) are consistent with
OSHA's bloodborne pathogens standard. In paragraph (d)(2) of OSHA's standard, the section that most
appropriately addresses "hand washing" in the scenario that you describe, the following is stated:
(v) Employers shall ensure that employees wash their hands immediately or as soon as feasible after
removal of gloves or other personal protective equipment. (vi) Employers shall ensure that employees
wash hands and any other skin with soap and water, or flush mucous membranes with water
immediately or as soon as feasible following contact of such body areas with blood or other potentially
infectious materials.
OSHA interprets this to mean that when an employee is removing gloves and has had contact, meaning
occupational exposure to blood or other potentially infectious materials (OPIM), hands must be washed
with an appropriate soap and running water. If a sink is not readily accessible (e.g., in the field) for
instances where there has been occupational exposure, hands may be decontaminated with a hand
cleaner or towelette, but must be washed with soap and running water as soon as feasible. If there has
been no occupational exposure to blood or OPIM, antiseptic hand cleansers may be used as an
appropriate "hand washing" practice.
Again, if there has been no occupational exposure to or contact with blood or OPIM (as defined in
[29CFR 1910.1030(b)]), the use of alcohol-based hand cleansers described in the CDC's October 2002
guidelines would be appropriate. The application of the standard and its specific elements must be put
American Academy of Provider Offices and Laboratories
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into place where there has been actual or reasonably anticipated exposure to blood or OPIM and does
not apply if no occupational exposure exists.
OSHA has consistently relied on the findings and recommendations of the CDC in developing good work
practices for those employees with occupational exposure to blood or OPIM and feels that the existing
standard does not compromise or contradict the recommendations included in the CDC's most recent
guidelines.”
22. What does OSHA require concerning disposal of contaminated sharps used in the home?
Homes are not governed by OSHA. Therefore, OSHA has NO guidelines for disposal of contaminated
sharps used in the home. However, this may be governed by state regulations. Please refer to
www.cdc.gov/needledisposal or call your solid waste dept. or public health department for advice.
US EPA Recommendations:
 Place in puncture-resistant container and seal
 Take to drop box or supervised collection site
 Consider
Mail back program
Home needle destruction devices
Syringe exchange program
23. What are OSHA’s regulations concerning the use of lighted candles in private practices?
OSHA does not govern the use of candles, but the local fire marshal may. The use of lighted candles is
forbidden in many public buildings. Yes, restaurants, spas and other establishments do use them.
24. Does OSHA forbid dentists from giving extracted teeth to patients or dental schools?
No. In fact, OSHA has two interpretive letters concerning that issue. Below are excerpts from those letters.
May 12, 1992
OSHA views natural teeth which may be used by dental students as specimens under 29CFR 1910.1030,
"Occupational Exposure to Bloodborne Pathogens." These must be handled with universal precautions
and are subject to the containerization and labeling requirements of the standard unless they are
appropriately decontaminated.
They must be placed in a container that prevents leakage during collection, handling, processing, storage,
transport or shipment. The container must be labeled with the biohazard symbol along with the word
"Biohazard" in the required contrasting colors (or color-coded) and closed prior to being stored,
transported, or shipped.
November 24, 1993
Under the Occupational Exposure to Bloodborne Pathogens standard (29CFR 1910.1030), OSHA
considers extracted teeth to be potentially infectious material when they are being disposed of, used as
diagnostic specimens, or sent to dental schools for student use. As such, they are to be handled in a
particular manner in order to prevent occupational transmission of disease to employees who come into
contact with them.
However, there is nothing in the standard that would prevent a dentist from giving patients their own
extracted teeth when the patient desires them since the intent of the standard is to prevent exposure of
employees to the blood of other individuals, not to protect individuals from their own blood. At the same
time, it would be unacceptable for a healthcare provider to require that a patient take all of the
contaminated items generated during their care in order to circumvent the standard's regulated waste
requirements.
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25. Is a car accident considered occupational if an employee is injured while traveling on behalf of the
employer, such as traveling between different worksites during the shift?
See the excerpt below from Determination of work-relatedness. (1904.5 )
Injuries and illnesses that occur while an employee is on travel status are work-related if, at the time of the
injury or illness, the employee was engaged in work activities "in the interest of the employer." Examples of
such activities include travel to and from customer contacts, conducting job tasks, and entertaining or
being entertained to transact, discuss, or promote business (work-related entertainment includes only
entertainment activities being engaged in at the direction of the employer).
26. We have heard about blunted suture needles. Our physicians have determined that these devices
have a negative impact on patient care. Would OSHA fine our practice for not using them?
OSHA has determined that sharp suture needles cause a significant number of employee exposures, and
that these exposures can be decreased by the use of blunted suture needles. Most surgeons in their
studies found these devices to be acceptable. “Where an employer has determined that the use of
available safer devices is not feasible, the clinical justification...must be documented in the facilities’
Exposure Control Plan, and the employer must implement alternative means of protecting surgical
personnel from percutaneous injuries. This is from “Use of Blunt-Tip Suture Needles…,” NIOSH
Publication No. 2007-132.
American Academy of Provider Offices and Laboratories
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Biomedical Waste Policy
Facility Name:
All states have some regulations concerning biomedical waste, but not all regulations require generators
to have a written plan. Several states have regulations requiring practices to establish and maintain a
Biomedical Waste Policy and to train employees on proper procedures.
States that require policies include but are not limited to the following: Alabama, Connecticut, Florida,
Maine (>50 lbs), Michigan, Minnesota (update every 2 years), Mississippi, Ohio (spill containment and
clean-up procedure), Virginia, Washington, and West Virginia. Fill in the blanks in the policy and train
your staff.
I. Purpose
The purpose of this plan is to ensure that this facility handles biomedical waste in compliance
with all applicable laws and with maximum employee safety. Our policy includes contracting with a
licensed waste hauler for the removal and proper destruction of all biomedical waste.
II. Personnel Training
Biomedical waste training will be provided for new applicable employees (those whose
responsibilities include biomedical waste handling) upon hire and for all applicable employees on an
annual basis. It will include the following topics:
 Definition and identification of biomedical waste
 Proper separation of biomedical waste from other waste
 Proper use of biomedical waste containers
 Labeling
 Storage and removal
 Procedure for decontamination of biomedical waste spills
 Contingency plan for emergency removal
 Contracted biomedical waste hauler
Employee training records are kept __________________________________ for a minimum of
three years. See sample record attached.
III. Definition, Identification and Segregation of Biomedical Waste
Biomedical waste is any liquid or solid waste that may pose a threat of infection to humans,
including non-liquid tissue, body parts, blood, blood products, and body fluids from humans and
other primates; laboratory and veterinary wastes which contain human disease-causing agents; and
discarded sharps. The following are also included:
(a) Used absorbent materials saturated with blood, blood products, body fluids, or excretions or
secretions contaminated with visible blood, and absorbent materials saturated with blood or
blood products that have dried.
(b) Non-absorbent disposable devices that have been contaminated with blood, body fluids or
secretions, or excretions visibly contaminated with blood, but that have not been treated by
an approved method.
Biomedical waste, both sharps and non-sharps, generated in this facility and their locations are listed
on the following page.
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BIOMEDICAL WASTE
ITEM
LOCATION
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IV. Proper Separation of Biomedical Waste from Other Waste
Only items meeting the definition of biomedical waste should be placed in biomedical waste
containers. Other hazardous wastes must be handled according to their nature. For proper disposal
of chemical wastes, refer to the safety data sheets. For radioactive materials, refer to the policy on
handling radioactive materials. General wastes, such as paper towels, empty wrappers, and leftover
food can be disposed of in regular waste containers.
V. Proper Use of Biomedical Waste Containers
a. All sharp items, including breakable glass, should be discarded into sharps containers.
Sharps containers are obtained from ________________________ and are stored
_________________________________. Only containers that meet OSHA regulations will
be used, and they will be located in each area where sharps are generated, listed here:
___________________
___________________
_________________
___________________
___________________
_________________
b.
Other biohazardous waste should go in the approved biomedical waste bags (“red bags”).
Red bags are acquired from _______________________________ and are kept
_________________________________________.
Documentation verifying the
construction of these items is filed _____________________________________.
VI. Labeling and Dating
All sharps containers, red bags, and outer containers bear the required biohazard symbol.
Properly trained employees will ensure proper labeling of all outer containers as required by
regulations and the waste hauler.
If required by the State or another agency, dates will be placed on the outside of the
containers based on the stricter regulations. This may mean:
___The date the first non-sharps item is placed in sharps containers or red bags
___The date sharps containers holding only sharp items are sealed.
Containers of biomedical waste may be stored in the facility for up to 30 days, after which it is
removed from the facility by a licensed waste hauler.
VII. Closure and Internal Transfer
All sharps containers must be sealed before they are transferred to the storage area for
removal by the waste hauler. All red bags must be tied before they are taken to the storage area for
pick up by the waste hauler.
Trained employees will prepare the large containers as instructed by the waste hauler,
ensuring that each container has a heavy-duty red liner prior to adding any of the smaller containers.
Trained employees seal the large container and add required labeling as instructed by the
waste hauler. This includes the name and address of this facility, which must be on the outside of
the large container, which will also bear the name and address, phone number and contact
information for the waste hauler.
IX. Internal Storage and Removal
All sharps containers and small red bags are transferred to the storage area, which is
_______________________________ and placed in the large containers for removal by the waste
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hauler. The waste hauler picks up the containers from this storage area, which bears the biohazard
symbol on its door.
VIII. Procedure for Decontamination of Biomedical Waste Spills
Only trained employees will clean up biomedical waste spills.
a. Don gown, gloves, and face protection (goggles and mask or full face shield).
b. Use a mechanical device such as broom and dust pan, forceps, or tongs) to pick
up solids and broken glass.
c. Add an absorbent to absorb liquids, allowing sufficient time for complete
absorption.
d. Scoop or sweep absorbed material into dust pan or container provided.
e. Place sharps or broken glass going into sharps containers and absorbed material
into red bags.
f. Clean the exposed area with soap and water, followed by a disinfectant, leaving the
disinfectant on the area according to the contact time specified on the container. The
disinfecting product is _____________________, and its contact time is
________________.
g. Seal containers and take to the storage area, placing them in the large containers.
IX. Contingency Plan for Emergency Removal
If we generate more waste than usual and need additional pickups, we will call the waste
hauler at ______________________.
X. Contracted Biomedical Waste Hauler.
This facility contracts with ___________________________________, a licensed waste
removal company, for the removal and proper destruction of biomedical waste. A copy of the
contract is located ___________________________________.
Waste Hauler’s Name:
Contact Individual:
Address:
Phone Number:
Fax Number:
XI. Documentation
Manifests generated by the waste hauler will be maintained for a minimum of three years.
They are kept _________________________________.
Approved by: __________________________________________
Title: _________________________________________________
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Biomedical Waste Training Acknowledgement
My signature below confirms that I have been trained on the Biomedical Waste Policy and that I
understand how to properly handle these materials.
______________________________________________
Signature
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Date
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Signature
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Date
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Date
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Date
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Guide for Reprocessing Instruments
Introduction
OSHA does not address patient safety at all! However, many medical and dental practices have expressed
the need for this information. This is not required as a part of your employee safety program, but it is integral to
patient care. Many more practices are now seeking accreditation, and most accrediting agencies require these
types of policies and procedures.
I. DECONTAMINATION / CLEANING PROCESS
1. If feasible, rinse instruments as soon as possible. Avoid excess soaking in water, unless instructed to do
so by the manufacturer. This can damage some instruments.
2. Place contaminated instruments in a clearly marked containment area. The “dirty” area should be separate
from the “clean” or sterilization area.
3. Place instruments in a container that meets the criteria as a sharps container and transport them to the
sterilization area.
4. Open or disassemble instruments before cleaning.
5. Soak in an enzymatic soak (for example: MetriWash, MetriClean 2, Metrizyme, Empower) or an ultrasonic
cleaner to reduce or eliminate scrubbing. Handling of soiled instruments should be kept to a minimum. Do
not use handsoap!
6. Scrub if necessary, preferably below the water level to minimize aerosolization. Always wear a gown, utility
gloves, and face protection while scrubbing.
7. Rinse with deionized water.
8. Thoroughly dry instruments with a clean towel or allow to air dry.
9. Inspect instruments for proper working order and cleanliness.
10. Use water-soluble instrument lubricant for hinged instruments and allow them to air dry.
11. Classify reusable instruments as critical, semi-critical, or non-critical.
12. Disinfect based on the level of disinfection needed, following the manufacturer’s guidelines.
II. NON-CRITICAL DISINFECTION
Noncritical items only contact intact skin, not mucous membranes or non-intact skin. These items require only
intermediate-level disinfection. Items eligible for this level of disinfection include stethoscopes, bedpans,
crutches, EKG leads, tabletops, floors, etc.
Appropriate disinfection chemicals include bleach (diluted 1:100), phenols, iodophors, hydrogen peroxide, and
quaternary ammonium solutions. These chemicals will kill most viruses and some bacteria but will not kill
tuberculosis, bacterial spores, and some resistant viruses.
The Centers for Disease Control and Prevention and the American Dental Association recommend the use of
disinfectants that will kill tuberculosis even for environmental disinfection (floors, for example).
To disinfect non-critical items:
1. Soak the instruments in the chemical for the length of time specified on the container.
2. Remove from the chemical and air or towel dry.
III. HIGH LEVEL DISINFECTION
High level disinfection is required for semi-critical items that will touch mucous membranes but will not enter
the vascular system or sterile tissue. Semi-critical instruments include flexible endoscopes, laryngoscopes,
speculums, endotracheal tubes, mirrors, amalgam condensers, respiratory and anesthesia equient.
High level disinfectants include 2% glutaraldehyde, bleach diluted 1:10, 70 - 90% ethyl alcohol, or hot water
(precleaning with detergent, followed by 165 water for 30 minutes). The choice must be based on the type of
material to be disinfected. Use only a product cleared by the FDA. Follow the
manufacturer’s guidelines for contact times, usually 10 - 45 minutes. Autoclaving is also effective but may
damage some instruments.
1. Soak the instruments in the chemical according to the time specified by the manufacturer.
American Academy of Provider Offices and Laboratories
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2. Remove the instruments from the chemical and rinse at least twice with sterile water.
3. Allow instruments to dry.
4. Place instruments in dated bags and store in a clean area, preferably in a cabinet or drawer, using care to
avoid contamination.
5. If not used within six months, reprocess.
IV. STERILlZATION
Sterilization is required for “critical“ instruments, those that will enter the vascular system, the bloodstream, or
sterile tissue. Examples include scalpels, forceps, bone chisels, scalers, burs, surgical instruments, and
catheters.
Sterilization destroys all forms of microbes (except prions). The most common techniques are chemical and
steam sterilization. Glass bead sterilization is available but has not been approved by the FDA.
A.
Chemical Sterilization
Chemical sterilization should be limited to instruments that cannot be heat sterilized because of the potential
hazards to employees and because the effectiveness cannot be monitored biologically. Examples of approved
chemical steriliants include glutaraldehyde, orthophthaldehyde, ethylene oxide gas, hydrogen peroxide, and
peracetic acid. These chemicals must be registered by the EPA and cleared by the FDA as capable of killing
M. tuberculosis. Examples include Cidex and Cidex OPA, Wavicide, Metricide, Omnicide, Sprocidin, Cetylcide,
Endospore, Sporox, Peract, and Procide.
Contact times vary between 7 and 12 hours. Some of these chemicals may be used for only 14 days.
Monitoring for effectiveness with chemical strips is recommended. To sterilize with chemicals:
1. Clean items by scrubbing or by using an enzymatic cleaner or Ultra Sonic cleaner.
2. Dry each item, either manually with a towel or allow to air dry. Placing wet instruments into the chemical
will dilute the chemical and reduce its effectiveness.
3. Open any hinged instruments. Place them into the liquid so that all instrument surfaces are covered by the
chemical.
4. Leave items in the solution for the time required by the manufacturer.
5. Remove the items from the chemical using sterile gloves or forceps. If you are wearing gloves, be careful
not to touch any non-sterile surface, such as the lid of the container.
6. Rinse the items with sterile water, preferably three times. Do not use tap water. Tap water is not sterile
and will contaminate the instruments.
7. Dry the items using sterile towels and store in a clean area where they will not become contaminated.
8. If the items will not be used immediately, wrap them in sterile packaging using sterile technique. Always
document the sterilization and expiration dates.
Reagent strips may be used to indicate the concentration of the active ingredient. They do not, however,
indicate the effectiveness of the process.
TIP:
Instead of risking continued exposure to the very hazardous properties associated with gluteraldehyde-based
products for pre-soaking or cold sterilization, consider these safer alternatives:
Sporax by Sultan Chemists: 800-637-8582
Cidex OPA by Advanced Sterilization Products: 888-783-7723
Compliance (formerly Endospor) by Metrex: 800-841-1428
Virox (an accelerated hydrogen peroxide-based product) by Virox
Technologies, Inc.: www.virox.com.
Sustainable Hospitals Project: [email protected].
B.
Steam Sterilization
Steam sterilization is the method of choice for items that are heat or moisture sensitive. Many steam
autoclaves are available in different sizes to meet your needs. Always pre-clean instruments and
follow the manufacturer’s guidelines for time, temperature, pressure, etc., as well as maintenance of
the autoclave.
Sample protocol for steam sterilization:
American Academy of Provider Offices and Laboratories
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1. Clean the instruments as described above.
2. Determine the required parameters of time, temperature, pressure, and moisture.
Remember to add to the time parameter the amount of time required for your autoclave to reach
the optimum operating conditions.
3. Make sure that all hinged instruments are opened and/or unlocked.
4. Package or wrap each item. Do not use staples, rubber bands, or paperclips to secure the
packaging. Use sterilizer package sealing tape.
5. Date each package with the date of sterilization and the expiration date.
6. Place the items in the autoclave and follow the manufacturer’s recommendations for time, etc. Leave
in the sterilizer until the process is complete.
7. Allow packages to cool, then inspect for damage.
8. Store packages in a low traffic area, preferably in a closet or covered cabinet. They should be stored
at least 8-20 inches from the floor, 18 inches from the ceiling, and 2 inches from the outside walls.
Never store medical or surgical supplies where they might get wet.
Chemical indicators, such as color-change tape or paper, should be used in each pack to indicate that the
packs have been processed. However, only biological spore monitoring indicates that the process was
effective. The Attest system by 3M is an example of spore monitoring. This should be done weekly and
documentation should be maintained.
Dry heat sterilizers follow a similar procedure, including spore monitoring. It is used for items that are moisture
sensitive, such as powders.
C.
Ethylene Oxide
Ethylene oxide gas sterilization is recommended for some items that are heat and moisture sensitive.
Manufacturer guidelines must be followed. The cycle time is usually 3-6 hours, followed by an aeration
time of 8-12 hours. Chemical tapes should be used with each pack to indicate pH, temperature, and
humidity. Spore monitoring should be used weekly to document effectiveness of the process.
D.
Expiration Dates
Expiration dates are based on the type of packaging materials used.
 Cloth or paper packs must be used or reprocessed within 30 days.
 Plastic/paper peel-down packs are good for six months.
Dentistry
Studies show that backwash in your air/water lines may result in bacterial colonization. Use antiretraction valves (one-way check valves) to prevent the backwash. Flush high-speed handpieces
for 20-30 seconds after each patient. Remove the handpieces and run water through the tubing
for several minutes each morning.
American Academy of Provider Offices and Laboratories
35
Daily Disinfection
Location _________________________________________________________________________ Year __________________
1
2
3
4
5
6
7
8
9
10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31
JAN
FEB
MAR
APR
MAY
JUN
JUL
AUG
SEP
OCT
NOV
DEC
American Academy of Provider Offices and Laboratories
36
WORKSITE HAZARD ASSESSMENT
Practice ___________________________
Date___________________
HAZARD
YES/NO
Signature ________________________
CONTROLS IN PLACE
SUGGESTED
CONTROLS/COMMENTS
I. BLOODBORNE PATHOGENS
A. Invasive procedures
B. Collecting/handling patient body
fluids, laboratory controls, etc.
C. Changing dressings
D. Handling soiled linen/biohazardous
wastes
E. Handling contaminated instruments
F. Administering injections, starting
IVs, removing sutures
G. Examination of body orifices
H. Catheterization/cauterization/
lacerations
I. X-ray of open wounds or oral
cavity
J. Cleaning contaminated surfaces
K. Food or beverages in or near
contaminated area
L. Presence/use of sharps without safety
devices
M. Sharps containers overfilled
N. Open sharps containers on moveable
carts
O. Unsealed sharps containers
transported
II. FIRE SAFETY/EVACUATION
A. Unmarked exits
B. Exits blocked (inside or outside)
American Academy of Provider Offices and Laboratories
37
WORKSITE HAZARD ASSESSMENT
Practice ___________________________
HAZARD
Date___________________
YES/NO
Signature ________________________
CONTROLS IN PLACE
SUGGESTED
CONTROLS/COMMENTS
C. Flammables present
D. Other fire hazards present
E. Keyed locks in exit doors
F. Damaged/stained ceiling tiles
III. ELECTRICAL
A. Outlets overloaded
B. Inoperable switches or outlets
C. 3-prong plug in 2-prong outlet
with adapter or alteration
D. Appliances, devices, or machines
used in an area where they might get
wet
E. Appliances/devices/machines
not grounded
F. Outlets near water without a GFCI
G. Damaged equipment
H. Damaged or frayed wiring
I. Improper cord positioning
J. Excessive extension cords
K. Unlabeled or inaccessible breakers
L. Fans and portable heaters
M. Broken or missing outlet or
switchplate/outlet covers
American Academy of Provider Offices and Laboratories
38
WORKSITE HAZARD ASSESSMENT
Practice ___________________________
HAZARD
Date___________________
YES/NO
Signature ________________________
CONTROLS IN PLACE
SUGGESTED
CONTROLS/COMMENTS
IV. LOCKOUT/TAGOUT
A. Electrical power to machines should
be locked out for maintenance or
repair
B. Appropriate signage is needed to
warn employees anytime a piece of
equipment should not be reactivated
V.
MACHINE GUARDING
A. Unsafe machinery
B. Unsafe work practices
C. Unprotected fan blades
VI. WALKING AND WORKING SURFACES
A. Slip or trip hazards
B. Obstacles in halls
VII. LASER/RADIATION/MRI
A. Laser procedures performed
1. Reflective surfaces present in the
room during laser procedures
2. Flammable (alcohol, O2,
anesthetic gases, etc.) present
during laser procedures
3. Goggles available
B. Radiology procedures performed
1. Unsafe equipment
2. Unsafe work practices
American Academy of Provider Offices and Laboratories
39
WORKSITE HAZARD ASSESSMENT
Practice ___________________________
HAZARD
Date___________________
YES/NO
Signature _______________________________
CONTROLS IN PLACE
SUGGESTED
CONTROLS/COMMENTS
3. Lead-lined protective equipment
available
4. Lead-lined protective equipment
stored properly
C. MRI
1. Hand sanitizer available
2. MRI-compatible fire extinguisher
available
3. Metals removed prior to entering
MRI room
VIII. HAZARDOUS CHEMICALS
A. Hazardous chemicals present
B. Incomplete or missing chemical
labels
C. Mouth pipetting
D. Odors
E. Pouring/mixing
F. Possible splashing
G. Improper chemical storage
H. Improper compressed gas tank
storage
I. Eyewash station needed
IX. TRANSPORTING BIOHAZARD WASTE
A. Transporting used sharps
B. Improper waste handling
American Academy of Provider Offices and Laboratories
40
WORKSITE HAZARD ASSESSMENT
Practice ___________________________
HAZARD
Date___________________
YES/NO
Signature _______________________________
CONTROLS IN PLACE
SUGGESTED
CONTROLS/COMMENTS
C. Improper sharps disposal
X. ERGONOMICS
A. Assisting patients:
1. Between wheelchair and
exam table or dental chair
2. Other
B. Awkward positions/posture
C. Pushing
1. Wheelchairs/Carts
2. Other
D. Telephone usage more than 4
hrs./day with no break
E. Computer terminal activities longer
than 4 hrs./day with no break
F. Other repetitive motions
1. Dental hygiene procedures
2. Ultrasonic procedures
G. Poor lighting
H. Limited space for work movements
I. Excessive static standing
J. Reaching/stooping/bending
twisting/squatting/required
American Academy of Provider Offices and Laboratories
41
WORKSITE HAZARD ASSESSMENT
Practice ___________________________
HAZARD
Date___________________
YES/NO
Signature _______________________________
CONTROLS IN PLACE
SUGGESTED
CONTROLS/COMMENTS
K. Climbing stairs/ladders
L. Fixed positions for long periods
M. Extension/elevation of arms
XI. WORKPLACE VIOLENCE
A. Poor lighting:
1. Hallway
2. Parking lot
3. Grounds
B. Aggressive patients/visitors
C. Aggressive co-workers
D. High crime location
E. Presence of drugs
F. Presence of cash
G. Past incidence of violence
XII. TUBERCULOSIS
A. Increase in TB patients in
community
B. TB patients seen in practice
C. High risk procedures performed:
1. Spirometry
American Academy of Provider Offices and Laboratories
42
WORKSITE HAZARD ASSESSMENT
Practice ___________________________
HAZARD
Date___________________
YES/NO
Signature _______________________________
CONTROLS IN PLACE
SUGGESTED
CONTROLS/COMMENTS
2. Bronchoscopy
3. Intubation
4. Induced sputum collection
5. Aerosolized treatments
6. Processing of sputum specimens
for TB testing
D. Employees with TB
XIII. RECORD KEEPING
A. Written Hazard Exposure Control
Plan
B. Poster(s) displayed
C. Personnel medical records
D. Training records
I certify that this assessment was performed as documented on each of the previous pages.
_________________________________________________
Employer
American Academy of Provider Offices and Laboratories
____________
Date
43
Personal Protective Equipment Hazard Assessment
Practice __________________________________ Date ________________ Signature ________________________
Applicable
Yes
Required Personal Protective Equipment
Task
No
Gloves - Specify
(medical, utility or
puncture-resistant)
Gown
Face Protection - Specify
(shield, goggles, or mask)
Bloodborne Pathogens (BBP)
Housekeeping
Giving injections
Drawing blood
Running blood tests
Handling urine
Processing stool specimens
Cleaning contaminated surfaces
Scrubbing contaminated instruments
Handling biohazardous waste
Changing bandages
Removing sutures
Surgical procedures
Dental procedures
Cleaning wounds
Examining body cavities
Invasive procedures
Examining skin abrasions/Bleeding
Removing instr. from heat sterilizer
American Academy of Provider Offices and Laboratories
44
Other
Personal Protective Equipment Hazard Assessment
Practice __________________________________ Date ________________ Signature ________________________
Applicable
Yes
Task
No
Required Personal Protective Equipment
Gloves - Specify
(medical, utility or
puncture-resistant)
Gown
Face Protection - Specify
(shield, goggles, or mask)
Hazardous Chemicals
Cleaning instruments/Surfaces
Chemotherapy (cancer)
Mixing/Pouring x-ray chemicals
Misc. chemical procedures
Radiation
Taking x-rays of wounds
Intraoral x-rays
Processing x-rays
Laser procedure
Tuberculosis
Care of TB patients
Cough-inducing procedures
Ergonomics
Phone/Keyboard duty > 4 hrs. with no
break
Repetitive motion
Awkward position
Heavy lifting
I certify that this assessment was performed as documented on each of the previous pages.
_________________________________________________
Employer
American Academy of Provider Offices and Laboratories
________________
Date
45
Other
Vaccine Storage: Best Practices
The Vaccines for Children (VFC) program is a federally funded program that provides vaccines free of charge
for children who might otherwise not get the recommended immunizations. VCF also provides excellent
guidance on proper storage of vaccines (vaccines for all ages – not just for children!).
The Centers for Disease Control and Prevention revised its guidelines of proper storage and handling of
vaccines in 2012 and is currently researching the most effective and economical methods for implementing
them. Meanwhile, several tools are available for those proactive medical practices that are ready to move
forward with ensuring efficacy of vaccines.
Why is vaccine storage so important? Failure to store vaccines properly can significantly reduce the
effectiveness of the vaccines, resulting in reduced immunity among the recipients as well as the loss of
thousands of dollars in materials.
Proper handling and storage begins with the manufacturer and continues through transportation to the
provider, storage at the provider’s office, on to the actual preparation and administration. For the purpose of
this article, we will focus on storage at the provider’s office.
When immunization vials are received at the provider’s office, they should be dated prior to the expiration
date (in date), cold and undamaged.
•
•
•
•
•
•
Upon receipt, check containers for expiration dates and signs of damage or inappropriate
temperatures. Make sure that the quantity will probably be used within the expiration date.
Vaccines should be received with some sort of barrier (bubble wrap or Styrofoam pellets, for
example) between the vaccine and the coolant. Diluents for varicella-containing vaccines should be
kept in a separate compartment.
Verify that the shipment was received within recommended transport times: forty-eight hours for
most vaccines; three days for varicella.
Check the contents against the packing slip to be sure they match.
When receiving lyophilized vaccines, check for the proper type and quantity of diluents. Make sure
the diluents are also in date.
If any discrepancies are found, contact the supervisor or vaccine coordinator immediately and isolate
the suspect vials, labeling them with “Do Not Use.”
As with all materials, the package inserts for vaccines provide invaluable information, including the
temperature range for storage. Refer to them often as information may change. While it may be intuitive that
temperatures above recommended storage temperatures can damage vaccines, temperatures that are too
cold can also damage these materials. Most vaccines that are meant to be stored in the refrigerator lose all
potency if frozen; few can be either refrigerated or frozen.
•
•
Vaccines to be refrigerated should be stored at 35ºF to 46º F or 2ºC to 8ºC.
Vaccines to be kept frozen should be stored at -50ºF to +5º F or -50ºC to -15ºC.
American Academy of Provider Offices and Laboratories
46
Here are the proper storage temperatures for most vaccines.
Store in Freezer
-58°F to +5°F or -50°C to -15°C
VAR*
HZV*
MMRV*
MMR*†
Protect from light (Varivax, ProQuad, M-M-R II, Hiberix, Gardasil, Fluarix, FluLaval,
Menhibrix, Menveo, Rotarix, and RotaTeq.
†Unreconsituted lyophilized MMR may be either frozen or refrigerated.
Store in Refrigerator
MMR*† HepA
35ºF to 46º F or 2ºC to 8ºC.
HepB
Hep A-Hep B
Hib*
Hib-HepB
Influenza (LAIV and IIV*)
IPV
Human papillomavirus (HPV2 and HPV4*)
Meningococcal-Containing Vaccines: Hib-MenCY* MCV4* and MPSV4
Pneumococcal (PCV13 and PPSV23)
Rotavirus* (RV1 and RV5)
Diphtheria toxoid- Tetanus toxoid- and Pertussis-containing vaccines:
DT, DTaP, DTaP-HepB-IPV, DTaP-IPV, DTaP-IPV/Hib, Tdap, Td, TT
The type of refrigerator/freezer used is critical in maintaining proper storage temperatures for these very labile
products. When selecting a unit, follow these guidelines:
•
•
•
•
•
Choose stand-alone units rather than combination freezer/refrigerators. If a stand-alone refrigerator is not
available, place water bottles, not vaccines, on the top shelf. Do not use the freezer for vaccines.
Avoid self-defrosting freezers, which may not reliably maintain the proper temperature.
Never use dormitory-style or bar-style units for vaccine storage; temperatures vary too much. Storing
vaccines purchased with public funds (example: Vaccines for Children) in this type unit is strictly
prohibited.
Consider purpose-built or pharmacy grade refrigerators or freezers. These are generally small enough for
use in smaller offices.
Make sure that the unit is large enough to hold a reasonable supply plus water bottles to help hold the
proper temperature. See more on this issue below.
The next consideration is where to place the refrigerator and/or freezer. Storage equipment should have
sufficient space around the unit (top, bottom, back and sides) to allow good air circulation. This generally
means 4-6 inches of clearance between the back of the unit and the wall plus 1-2 inches off the floor after
leveling. Nothing should block the cover of the motor, which may be on the back or the side. Refer to the
owner’s manual for more specifications.
Use a reliable electrical outlet for your freezer. Place a sign that reads “Do Not Unplug” near the plug and one
that says “Do Not Turn Off” near any switch, including the breaker.
How the unit is packed is also important.
American Academy of Provider Offices and Laboratories
47
•
•
•
•
•
Never allow food or beverages to be stored with vaccines! This results in frequent opening of the door and
consequential temperature fluctuation, and can result in cross-contamination. Place a sign on the outside
that reads “No Food or Beverages.”
If possible, do not store other medications or biologic products with vaccines. If there is no other choice,
store them on separate shelves.
Place water bottles in the refrigerator and frozen coolant packs in the freezer to stabilize temperatures.
Label water bottles “Do NOT Drink.” Place them against the inside walls and in the door racks. If the unit
has drawers at the bottom, remove them and place large water bottles there; vaccines must not be stored
on the floor. Place freezer packs along the walls, back and bottom of the freezer and in the door rack.
Leave spaces between all containers to allow for sufficient airflow. Do not pack items close together, and
do not overload the door so that it does not properly close.
Group similar types of vaccines together, with pediatric and adult versions of the same vaccine clearly
marked.
Once inactivated, vaccines cannot be used and must be discarded. Visual observations (except for obvious
damage, such as breakage, or clumping that does not go away when the vial is shaken) are not reliable, as
many damaged vaccines look perfectly fine. This means that temperatures must be meticulously monitored.
Each unit should have a thermometer of the correct temperature range and should be monitored at least twice
daily. Document each reading. If the reading is outside the acceptable range, adjust the thermostat and
document the new temperature about an hour later. Repeat until the correct temperature is achieved.
Document all corrective actions.
This process should be implemented after the unit is installed and water bottles/frozen coolants are added,
first allowing sufficient time for the unit to reach the desired temperature. This may take up to three days.
Make sure temperatures are stable before adding vaccines to the unit!
After the unit is stable at the correct temperature, add yet another sign that says: “Do NOT Adjust
Temperature Controls! Contact (Vaccine Coordinator) if Adjustment is Needed.” This will discourage too
frequent adjustments, which could actually result in the wrong temperature! Remember that if you must use
that combo unit, adjusting one thermostat can affect the other temperature as well. Do not turn off the freezer,
even if it is not in use, because this, too, can affect the refrigerator temperature.
•
If a storage unit malfunctions, call the manufacturer or an authorized service company.
Storage units, after stabilization, must be maintained according to the manufacturer’s instructions. All coils
and motors must be carefully cleaned monthly to prevent buildup of dust and dirt. It is best to temporarily
store vaccines in another unit so that the unit can be unplugged for cleaning. The inside of the unit should
also be cleaned with warm soapy water and dried. While cleaning, check the door seal and hinges for gaps or
damage.
•
Make sure the temperature is restored before returning vaccines to the unit.
Temperature monitoring is critical! Temperatures must be monitored at least twice daily: first thing in the
morning and last thing before the clinic closes. Thermometers must be calibrated. New thermometers should
have a Certificate of Traceability and Calibration Testing (or Report of Calibration). Calibration must be
verified annually by an entity that is accredited by the International Laboratory Accreditation Cooperation
(ILAC) Mutual Recognition Arrangement. Links for listings are available at cdc.gov. When the certificate
expires, the practice has three options:
•
•
•
Have the thermometers tested by an accredited laboratory
Purchase a replacement thermometer
Contact the immunization program for testing resources
The CDC recommends using a digital thermometer with a detachable probe that is kept in a glycol-filled
bottle, allowing the temperature to be downloaded without opening the door to remove the probe from the
unit. The probe should be located near the vaccines. Some VFC programs require a backup temperature
probe, so read the requirements if you are a VFC provider.
American Academy of Provider Offices and Laboratories
48
Continuous monitoring thermometers are preferred. They can help determine how long a unit’s temperatures
have been outside the specified range, recording all temperatures over time. Min/max thermometers will at
least inform the reader about the lowest and highest temperatures that were reached. Many thermometers
continuously log data and may be capable of a visual alarm (light changes color), an audible alarm within
hearing distance of the unit itself, or even sending alarms to cell phones, especially when the office is not
manned. Digital data loggers are typically battery operated and come in many styles and prices.
Avoid fluid-filled biosafe thermometers, bi-metal stem thermometers, food thermometers and mercury
thermometers. These may be difficult to read and may not be precise. Chart recorders may also be difficult to
read and require frequent paper changes.
In addition to temperatures, expiration dates must be monitored and documented. When a multidose vial is
first opened, mark it with that date. Label reconstituted vials with the date and time it was reconstituted.
Adhere to the open vial date as closely as the manufacturer’s original expiration date.
•
•
•
Never use expired vaccines.
Always use older items first. Checking expiration dates (manufacturer’s and user-added ones) daily will
help. Putting the older ones in front will facilitate this process.
Always store vaccines and diluents in their original containers, including outer packaging. This helps
manage the inventory and protects from exposure to light. Some diluents may be stored at room
temperature, but this requires careful matching of diluent to vaccine.
Anytime vaccine storage is less than ideal, and expiration dates are exceeded or items are damaged, the
affected items must be removed from the storage unit and marked “Do Not Use.” Document all information
available, including all temperatures, the length of time the vaccines may have been exposed to inappropriate
temperatures, and corrective actions implemented. Contact your vaccine coordinator as well as your vaccine
supplier and any publicly-funded vaccine program. Do not discard vaccines unless instructed to do so by your
immunization program or the manufacturer.
A good vaccine storage and handling program requires the following elements:
•
•
•
Effective staff training;
Appropriate transportation and storage equipment; and
Written policies and procedures
Laboratories must include storage requirements in their written procedures or refer to the manufacturer’s
instructions, which must be made available when the surveyor requests them. Temperatures must be
documented at least once per day, and the logs must be retained for a minimum of two years. This
information can be stored electronically, but be sure to back up your data at least daily. If you cannot locate
the records, it was not done!
American Academy of Provider Offices and Laboratories
49
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