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hazard communication standards
OSHA regulation that deals with identifying/limiting exposure to occupational hazards
Two areas of OSHA standards that apply in the prep room as occupational exposure as
An upper limit on the acceptable concentration of a hazard substance in workplace air for a particular material or class of materials
Reasonably anticipated skin,eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee’s duties
Requires employers to
Obtain and maintain MSDS (SDS)
Material safety data sheets
A form that must accompany a hazard product
Also required by department of labor
Label hazard material
Any agent/material exposing one to risk
Provide employee info and training on hazards in the workplace
At the time of their initial assignment
Whenever a new hazard or type of exposure is introduced
Provide docs proving the above are in compliance
The procedure for completing must be put down in a written plan called the written hazard com program
formaldehyde rule
OSHA regulation limiting the amount of occupational exposure to formaldehyde gas
In May of 1998, OSHA revised the hazard communication standard specifically concerning exposure of formaldehyde
This revision providing the following areas to the standard
PEL
permissible exposure limit (PEL)
The max legal limits established by OSHA for regulated substances
0.75 ppm over an 8 hour time weighted average
Ppm
A method of expressing low concentrations of a chemical in the air
Defined as the number of parts of chemical per million parts
TWA
An evaluation of exposure that is time-weighed over an established period
It allows exposure levels to be averaged generally over an 8 hour time period
If this limit is exceeded, employers must take proper steps to reduce employee exposure
STEL
Legal limits established by OSHA to which workers can be exposed continuously for a short period time
2 ppm over a 15 minute exposure
Shouldn’t be done more than 4 times per day
AL
This level is established to ensure adequate protection of employees at exposures below the osha limits, but to minimize the compliance burdens for employers whose employees have exposures below the 8 hour limits
0.5 ppm over the 8 hour TWA
This is the level at which monitoring is required
Monitoring at AL
Initial monitoring
Required to identify all employees who are exposed above the action level or the STEL
To accurately determine exposure of each employee
Continued monitoring
Required
If levels are above AL (every 6 months)
If levels are above STEL (every year)
If there are reports of formaldehyde exposure related signs and symptoms
May be discontinued if levels fall below the AL and STEL after 2 consecutive samples taken a week apart
Employees must be notified of the results of monitoring within 15 days of receipt
Medical surveillance
Employee reporting
These procedures are to be followed if exposure levels are at or above the STEL and/or action level
Employee must be annually offered a medical disease quiz for doctor’s review
Employee must report to employer with any signs/symptoms of potential exposure
Potential health hazards of formaldehyde
Acute effects
Ingestion (swallowing) - causes throat irritation, highly poisonous and causes death
Inhalation - irritates upper respiratory tract with inflammation of the nose, throat lungs
Skin - causes drying, cracking and scaling dermatitis and skin desensitization
Chronic effects
Carcinogenicity - potential cancer in human lungs, nasopharynx, and nasal passages
Toxicity - may result in respiratory impairment such as asthma/bronchitis
Mutagenicity - genotoxic in several in vitro tests showing properties of mutation
Signs and symptoms
Irritation of the mucosa of the eyes, nose throat
Happens at anything above 0.1 ppm
Above 100 ppm is an immediate danger to health/life
Swelling of the eyelids
Respiratory disorders, coughing, shortness of breath
Allergic reactions
Frequent headaches, dizzy, drowsy
Jaundice
Easy bruising
medical removal protection
Employees who suffer big adverse effects from formaldehyde must be removed to jobs with less exposure until their conditions improve
Employee benefits must continue for up to 6 months or until a doctor determines that the employee will never be able to return
forms of formaldehyde that are relevant
Formaldehyde gas solutions
Paraformaldehyde
Solids and mixtures containing HCHO
PPE
Purpose of PPE
For protection against a specific hazard
For the embalmer it is to avoid contact with formaldehyde, blood and other body fluids
Employees exposed to solutions of 1% or greater are required to wear goggles/face shield for protection
Items to be worn
Face mask -goggles -face shield -gown
Shoe covers -head covers -gloves
Housekeeping
Established procedures must be in place for
Spill cleanup
Decontamination of the work area
Proper disposal of contaminated waste
Emergency response procedures
Concerning overexposure to formaldehyde
safety and warning procedures
In areas where the concentration of formaldehyde exceeds any of the exposure limits
1) signs must be posted stating dangers
2) the areas must be restricted to authorized and properly trained personnel
Record keeping
Records that must be kept by the employer
Monitoring results - 30 years
Medical surveillance records - 30 years following termination
Training records, etc - 3 years
Respirator fit testings - until updated (yearly)
BBP
re pathogenic microorganisms that are present in human blood and can infect/cause disease
Examples: HBV, HIV
OSHA has determined that certain employees face a significant health risk as a result of occupational exposure to blood and other potentially infectious materials
To minimize this risk, OSHA issued the occupational exposure to BBP standard
Scope and applications
Employers must identify in writing
Tasks and procedures as well as job classifications where occupational exposure to blood occurs
Without regard to PPE
This plan must be accessible to employees and OSHA people
The plan must be reviewed/updated yearly or when new exposures occur
Applies to employees with exposure to blood and OPIM
This document is called the exposure control plan
categories of risk by exposure for BBP
category 1 (high risk)
Tasks that include exposure to blood, body fluids, or tissue
embalmers/apprentice embalmers
removal/first call personnel
Category 2 (moderate risk)
Tasks that involve no exposure to blood, body fluids/tissue, but employment may require performing unplanned category 1 tasks
FD/apprentice FDs
Funeral assistants
Housekeeping personnel
hairstylist/cosmetologist
Category 3 (minimum risk)
Tasks that involve no exposure to blood, fluids, or tissue and category 1 tasks that are not a condition of employment
Admin staff and clerical support
bodily fluids under OPIM
Semen -blood products -vaginal secretions -cerebrospinal fluid
Synovial (joint) fluid -pleural fluid -peritoneal fluid -pericardial fluid
Amniotic fluid -urine
activities requiring ppe
embalming
Prep room cleaning
Cleaning chemical, blood, body fluid spills
Placing remains in/out of refrigeration
All first call procedures
Employers must
Provide all PPE necessary to perform the task at no cost
Clean, repair, replace all safety items when necessary
Keep work site clean/sanitary
Arrange for cleaning and treatment of contaminated laundry
Laundry that has been soiled with blood or OPIM or that may contain sharps
Arrange for disposal of biohazard waste
Biohazard - any biological agent or condition that means a hazard to people
hep b vaccination
Employers must provide
Must be offered within 10 working days of initial assignment
Exceptions are
People who already have completed vaccination series
When immunity is confirmed through antibody testing
When vaccination is contraindicated for medical reasons
Employees must sign a declination form if they choose not to be vaccinated
They may request and obtain vaccination at any time at no cost
post exposure medical evaluation
A confidential medical evaluation/follow up must be made available to employees following an exposure inciting
Exposure through any of the following is considered an exposure incident
Eye
Mouth
Non-intact skin
Other mucous membrane
Parenteral contact with blood or OPIM that results from performance of duties
Introduced into the body by piercing the mucous membranes, or skin barriers through such events as needlesticks, human bites, buts, abrasions
Evaluation includes
Documenting the circumstances of exposure
identifying/testing the source
Testing the employee’s blood
Counseling
Evaluation of reported illness
communication of hazards to employees
What is required?
Labels must be attached to
Containers of regulated waste
refrigeration/freezers containing blood
Any other containers used to store, transport, or ship blood or OPIM
Labels must include the universal biohazard symbol and the term biohazard
Must be fluorescent orange/orange-red color with contrasting color lettering
Labeling is not required on
Red bags used for regulated waste
Waste that has been decontaminated
If specimen is placed in labeled outer container
training
All exposed employees must be trained before exposure begins
Training must be provided by a person who is knowledgeable in the subject
There must be no cost to the employee
It must be conducted during regular business hours
methods of compliance
Always use universal precautions - assume all bodies are infectious
Specific requirements that are most often cited
Eyewash station
Quick drench shower
Record keeping
Exposure determination
engineering controls
Mechanical systems/devices engineered as part of equipment or the architecture of a building that isolates/removes hazards from the workplace
Use drain tubes
Use embalming sink covers to avoid aerosolization
Minute particles of blood/water become atomized and suspended in air when water under pressure meets the blood drainage or when flushing an uncovered flush sink
Puncture proof sharp containers
Biosafety cabinets
Adequate air exchange
Keep lid on embalming machine reservoir
Keep lid on hazardous waste material
Check hoses on injection machines to avoid leakage/spray
work practice controls
These controls reduce the likelihood of exposure by altering the manner in which a task is performed
Not bending/breaking sharps
Washing hands as soon as gloves are removed
Clean up spills immediately
Cap all bottles
Rinse emptied fluid bottles
Continuous aspiration of cavity during injection of autopsies
Clamp all arteries/vein severed during an autopsy to minimize volume
Clamp drainage veins as soon as blood has cleared to minimize volumes
Allows less HCHO to become airborne
Higher intravascular pressure
Minimizes chemicals in the waste system
DO NOT allow drainage to run over the body/table
Continuous water flow on table to dilute and wash away drainage
Use a closed drainage system from vein to disposal system
A drainage procedure that limits the exposure of the embalmer to drainage in which tubing is attached to a drain tube allowing drainage to flow directly from the vein into a sanitary disposal system
A heart tap works as well for this