Osha Compliance, Essay Example

Introduction

This paper posits to provide an OSHA compliance program for a hypothetical institution. The compliance program presented in this paper will be OSHA standard 1910 subpart k (medical and first aid) and 1910.1030 (blood borne pathogens). The compliance program will address subjects such as scope, purpose, responsibilities, procedures, training and disciplinary components. The hypothetical institution is Ultimate Research Institute (URI).The enactment of the Occupational Safety and Health (OSH) Act was guarantee safe and healthy working conditions for workers.

Several standards promulgate by the Occupational Safety and Health Administration (OSHA) clearly requires employers to train their employees on the safety and health facets of their jobs. Some OSHA standards require the employer to be responsible in limiting certain job assignments to employees who are qualified, proficient, or certified. These requirements mirror OSHA’s principle that training is a fundamental part of each employer’s health and safety program for shielding workers from injury and illnesses. Several researchers are of the opinion that new employees tend to have a higher incidence of accidents and injury than experienced workers. If lack of knowledge on precise job risks and of appropriate work practices is even partially to blame for this high injury incidence, then training will assist in providing a solution. Training in the appropriate performance of a job is money and time well spent, and the employer may view it as an asset rather than expenditure. It is usually an appropriate for an employer to keep documentation of all health and safety training. Records provide proof of the employer’s compliance with OSHA standards. Records can also provide an answer to one of the initial questions an accident investigator asks. The question relates to whether the injured employee is well trained for the task. OSHA’S blood borne pathogens standards protect employees who are engaged in occupations where they face imminent risk of exposure to blood or related potentially contagious materials (Centers for Disease Control and Prevention, 2010).

Ultimate Research Institute Blood borne Pathogens Exposure Control Plan

The U RI  Blood borne Pathogens Exposure Control Plan (ECP) has been implemented in accordance with the stipulations of the Occupational Safety and Health Administration’s (OSHA) Blood borne Pathogens (BBP) standard as codified at 29 CFR 1910.1030.  This standard addresses occupational exposure hazards to human body fluids that would contain blood borne pathogens like human immunodeficiency virus (HIV) as well as (HBV) hepatitis B virus in human healthcare environments.

The fundamental objectives of this ECP are to:

• Identify tasks and activities that involve the utilization of human-derived materials regarded as possibly contagious for BBP (occupational exposure determination);
• Provide data to affected supervisors as well as employees on regulations and procedures in regard to BBP;
• Protect employees affected from health risks connected to BBP;
• Provide data on suitable treatment as well as counseling to any affected employees exposed to BBP.

Principles to be applied in the event of probable exposure to when employees are potentially exposed to BBP:

• Reduce all exposures to BBP;
• Establish several engineering as well as work practice controls to eradicate or reduce employee exposure to BBP;
• Employ routinely universal precautions in the event that exposure to blood or possible contagious materials is anticipated.

Exposure Determination

The OSHA Blood borne Pathogens Standard stipulates that all personnel who have responsibilities which may expose them to blood or related potentially contagious material are identified and acknowledged in the ECP.

The U RI occupational safety and health personnel have identified the job classifications to include potential exposure to BBP. The exposure determination is made without consideration of the use of personal protective equipment.

Job categorizations which have a high probability for BBP exposure are recorded in the left hand column in the following table. The specific tasks that bear a Blood borne Pathogens exposure risk are recorded in the right hand column.

All personnel whose job categorization is recorded in the table, and who executes tasks recorded in the corresponding right hand column are regarded as having occupational exposure for BBP and must therefore be incorporated in the U RI BBP Exposure Control Program.

Information concerning job categorization factored in the provisions of the ECP will be revised yearly, based on data acquired from relevant departments.

N.B:

If any supervisor has a member of staff who has a convincingly anticipated hazard of BBP exposure but the member of staff’s job categorization is not captured in the table, the supervisor must notify the U RI Bio-safety Officer in (354) 123-4567 or the U RI Safety Officer in (354) 369-9632

Exposure Risk to the rest of Human Body Fluids (include wastewater)

A large amount of human waste products such as feces and urine are not commonly regarded as BBP-risk substances. Nonetheless these substances present a contagious disease transmission hazard. Therefore, contamination control-related guidance and implementation of hygiene-related practices are necessary for personnel whose tasks or research activities entail exposure or contact with these substances.

Broad Program Management

Areas of Responsibility

The three principal areas of accountability for Exposure Control Plan (ECP) include:

1. Exposure Control Officers
2. Supervisory staff (Supervisors, Managers as well as PIs);

Exposure Control Officers

The Exposure Control Officers are responsible for support and management of the BBP Compliance Program. The U RI Safety Officer and U RI Bio-safety Officer will serve as U RI’s BBP Exposure Control Officers. The U RI Occupational Health Nurse will support the Exposure Control Officers. Tasks entrusted to the Exposure Control Officers comprise:

• Supervision of the execution of the Exposure Control Plan;
• Developing, in collaboration with administrators, every additional BBP associated practices and policies required to support the effective execution of this plan;
• Reviewing, renew and improving the ECP at least on a yearly basis and when necessary;
• Gathering and maintaining an appropriate reference annals associated to BBP;
• Supporting supervisors as well as employees in the implementation and development of procedures planned to lessen BBP exposure hazards associated with site-explicit tasks;
• Identifying /or developing instruction resources, and providing instruction to the suitable extent;
• Understanding contemporary legal requirements relating to BBP;

Carry out periodic appraisals and inspection of settings where occupational exposure hazards is present to authenticate regulatory adherence.

Supervisory Personnel (including PIs, Managers as well as Supervisors)

Supervisory personnel are in charge of conformity in their areas. They shall work jointly with the

Exposure Control Officers as well as their staff to guarantee that:

• every member of staff in their jurisdiction who are at risk of exposure to BBP obtain preliminary training and yearly retraining in BBP.
• Appropriate exposure control measures are followed;
• Appropriate personal protective equipment is accessible and in good working condition for every employee at risk of exposure to BBP;
• An employee who experiences an occupational exposure episode to blood or related potentially contagious substances is given post-exposure medical services.

Program-related documentation is accessible at the work site and is up to date with regulatory requirements.

Employees

Employees who bear occupational exposure hazards for BBPs are responsible for adhering to procedures and practices as stipulated in the ECP.

Methods of Compliance

Principal Investigators as well as Supervisors are responsible for guaranteeing compliance with the U RI Exposure Control Plan. The plan deals with the following areas:

• Engineering controls;
• Principles of Universal Precautions;
• Post-exposure incident response;
• Personal protective equipment;
• Work practice controls;
• Housekeeping procedures.

Each area will be evaluated with employees in the initial as well as refresher BBP training, and employees will obtain site-specific instruction associated with BBP exposure control. The Exposure Control Officers will give initial as well as refresher instruction, while site-specific training will be carried out by the employee’s supervisor or selected trainer and will be recorded by use of a checklist form to be signed by the trainer as well as the employee upon conclusion. A duplicate of this form must be kept on file by the Principal Investigators/supervisor for regulatory review, if necessary.

Work Practices

Supervisors are in charge of guaranteeing that all personnel with occupational exposure hazards complete the appropriate work practices training in to lessen exposure hazards, and for making sure that these work practices are implemented and adhered to. Contact the U RI Bio-safety Officer for additional information and support concerning these requirements.

Personal Protective Equipment (PPE)

Personal protective equipment is accessible at no cost to all U RI personnel with an occupational exposure to blood or related potentially contagious substances.

Principal Investigators (PI) or supervisors ought to ensure that PPE of suitable size and type is obtainable easily to employees. Employees should be trained concerning the use of suitable PPE for their job categories and the procedures/tasks they perform. This training will be recorded through the conclusion of the site-specific instruction checklist record.

If an employee reject the use of PPE, the principal investigator/supervisor must confirm that it was the employee’s professional decision that the use of PPE may have posed a bigger hazard to his/her safety or a colleague. When an employee makes this decision, the status shall be investigated and recorded to establish if modifications can be made to avert future incidents.

Housekeeping

Employees working with probable contagious substances must:

1. Clean and disinfect all apparatus as well as surfaces after making contact with blood or related potentially contagious substances.
2. Inspect infected apparatus prior to shipping or servicing. If apparatus must be shipped, contact the U RI Bio-safety Officer prior to shipping.
3. Routinely examine and disinfect all pails, cans, bins, and other containers.
4. When disposing of infected biological waste, appropriate measures must be taken.

Bio-hazardous Waste

For information in relation to disposal of wastes infected with further biohazards such as contagious agents and recombinant DNA substances, contact the U RI Bio-safety Officer at (354) 123-4567. There are groups of waste materials that could be a BBP exposure risk and must consequently be properly isolated, labeled, disinfected and disposed of in a different manner from unregulated wastes. Bio-hazardous waste in whichever form must not be left unsecured and untreated in areas that are reachable to the public. Treated bio-hazardous waste ought to be removed from the laboratory area and transferred to waste holding locations for ultimate disposal by lab personnel only.

Pathological waste

This comprises of every unfixed human organs, body parts and tissues apart from teeth. It also comprises of unfixed animal tissues as well as carcasses that have been exposed to human- derived substances or BBP (HIV, HBV, and HCV).

Treatment and disposal

This category of waste should be double-bagged in bio-hazard bags that have a biohazard symbol. Bags should be stored in a way that will reduce the probability of release of fluids in the storage as well as handling process. These substances should be incinerated for disposal except when other provisions are appropriate (contact U RI Bio-safety Officer).

Hepatitis B inoculation, Post-Exposure assessment and follow-up

A Hepatitis B Vaccination Program as well as procedure for post-exposure assessment and follow-up has been launched through the Ultimate Research Institute Occupational Health Program.

Vaccination Program

The Ultimate Research Institute has employed a vaccination program through its Occupational Health. This program is provided free of charge to all workers at the risk of occupational exposure to BBP.  This vaccination program consists of a cycle of three inoculations spread in half year duration and a post-vaccine titer. At the point of the BBP instruction or Occupational Health Program conscription, employees will obtain information concerning the vaccination program.

Post-Exposure Assessment plus Follow-up

If an employee experiences an incident where exposure to BBP may have occurred, the employee must search for medical consultation and treatment instantly. The U RI Safety Officer or U RI Bio-safety Officer will assess all BBP exposure incidents and document the following data on the Exposure Incident

1. Investigation statement:
2. Date of event
3. Time of event
4. Department
5. Job designation
6. Supervisor
7. Path of exposure
8. Explanation of device in Utilized
9. Incident account
10. Work practice controls employed
11. Engineering controls utilized
12. PPE employed
13. Date of preceding BBP instruction
14. Comments & Recommendations Remedial Action

All documentation connected to an exposure event will be documented and maintained in absolute confidentiality.

Medical Record Keeping

The U RI Occupational Health Nurse should set up and maintain confidential employee medical documentation. Data will not be revealed without the employee’s written authority, except as required or acceptable by law. This documentation shall have to be maintained for a minimum duration of employee’s service plus thirty years.

Initial Training Topics

In accordance with the least requirements of OSHA BBP Standard, BBP training for new employees who should have occupational exposure with respect to OPIM or human blood will comprise the following compulsory topics:

• OSHA’s BBP Standard and its availability;
• Epidemiology, signs and modes of communication of BBP diseases including HBV, HIV and, HCV; existence of related blood-borne diseases;
• URI’s Exposure Control Plan and its accessibility;
• Process for recognizing tasks as well as related activities that may entail exposure to blood and related potentially contagious substances;
• Review of utilization and limits of techniques that will avert or lessen exposure, including:
• Work practice controls
• Personal protective equipment (PPE)
• Engineering controls
• Appropriate selection use in addition to disposal of PPE;
• Visual warning in biohazards as well as labels, signs and color-coded containers;
• Data on the hepatitis B vaccine, as well as its accessibility, efficiency, benefits, safety, administration, as well as HBV Vaccination Program;
• Emergency actions in relation to occurrences involving blood or related potentially contagious substances.
• Occurrence reporting and post-exposure follow-up measures;
• Post-exposure appraisal and follow-up as well as medical consultation;

In the event that a supervisor decides to perform their own training, he/she must guarantee that all these topics, including site-specific training data are included.

Update Training

Supervisors should provide concise update training as soon as a new procedure or task is approved that affects occupational exposure hazards. At a minimum, yearly update training should be completed, in spite of any procedural amendments. This training may be given by supervisors together with the U RI health & safety personnel and will center on compliance weaknesses and new data relative to exposure control.

Training Documentation

Every time BBP training is done, the following data must be recorded:

• Dates of every training session;
• Contents of the training sessions;
• Names and credentials of the instructors;
• Names as well as job titles of employees in attendance.

Although the U RI health & safety personnel will maintain documentation of the training sessions that they offer, this does not make up an absolute training record. Consequently, supervisors ought to maintain documentation for their staff  in their work statio. These records should be accessible for scrutiny upon request. Training documentation ought to be maintained for at a minimum of three years from the date of the training event.

OSHA standard 1910 subpart k (medical and first aid)

1910.151   Medical services and first aid.

(a) The URI shall ensure the availability of medical personnel for consultation and  advice on matters of health.

(b) Where the body or eyes of any employee may be exposed to deleterious corrosive materials, appropriate facilities for rapid flushing or drenching of the eyes and body shall be offered within the working area for instantaneous emergency use.

First aid supplies will always be readily available under paragraph 1910.151(b). The contents contained first aid kit as listed in the American National Standard (ANSI) standard will be adequate for all worksites. When multiple or large operations are being executed at the same work station, URI will determine the need for supplementary first aid kits at the relevant worksite, extra types of first aid equipment as well as supplies and supplementary quantities and types of supplies as well as equipment in the first aid kits. If it is convincingly projected that employees will be exposed to blood or related potentially contagious materials while using the first aid supplies, URI will provide appropriate personal protective equipment (PPE) in accordance to the provisions of the Occupational Exposure to Blood borne Pathogens standard as stipulated in the preceding URI  Blood borne Pathogens Exposure Control Plan (ECP)

References

Centers for Disease Control & Prevention, (2010). U.S. Public Health Service strategy for Management in Occupational Exposures to HBV, HCV, & HIV & Recommendations for Post-Exposure Prophylaxis. MMWR 2001; 50.