OSHA adds GHS to Hazard Communication Standard Expected revisions align with United Nations global chemical labeling system to improve worker safety It was only a matter of time, but OSHA has officially revised its Hazard Communication Standard to include the Globally Harmonized System (GHS) of Classification and Labelling of Chemicals. The change was expected to be announced this year after OSHA submitted the change to the Office of Management and Budget in October 2011. GHS adoption has been on OSHA’s agenda for more than six years. “Exposure to hazardous chemicals is one of the most serious dangers facing American workers today,” Secretary of Labor Hilda L. Solis said in a press release. “Revising OSHA’s Hazard Communication Standard will improve the quality, consistency and clarity of hazard information that workers receive, making it safer for workers to do their jobs and easier for employers to stay competitive in the global marketplace.” OSHA expects the revised standard to prevent rough- ly 585 injuries and illnesses each year, and improve productivity for businesses that regularly handle, store, and use hazardous chemicals, with a cost savings of $32.2 million for businesses that periodically update safety data sheets (SDS) and labels. Complete imple- mentation of the changes is expected by 2016; however, employers have until December 2013 to train employees on the system’s new requirements. Hospitals are one of the primary businesses affected by the revision of the Hazard Communication Standard, which has been troublesome for healthcare facilities even before this change. OSHA lists it as the third most frequently cited standard from October 2010 to September 2011. Switching to the new GHS system should ultimately make it easier for hospitals to protect employees who regularly work with hazardous chemicals, says Bruce Cunha, RN, MS, COHN-S, employee health and safety manager at Marshfield (Wis.) Clinic. “I’m usually moderately critical of OSHA and their new rules, but I think this is a good, positive rule,” he says. “I think it will help employees—it makes it easier for them to understand the hazards of a chemical, and [the change] makes for a much better rule.” Training employees Employee training, on both the laboratory and clinical side, is the most immediate compliance need that safety officers should focus on, says Kenneth Weinberg, BA, MSc, PhD, an environmental health, safety, and toxicol- ogy consultant with Safdoc Systems, LLC, in Stoughton, Mass. Weinberg, who was previously the director of “Revising OSHA’s Hazard Communication Standard will ... [make] it safer for workers to do their jobs and easier for employers to stay competitive in the global marketplace.” —Hilda L. Solis IN THIS ISSUE p. 7 CMS adopts sections of 2012 Life Safety Code A memo declares CMS is accepting waivers on four sections of the Life Safety Code ® , providing leeway for corridor clutter. p. 9 Double-gloving can be both safe and effective AORN shows that double-gloving, particularly with an indicator glove, offers more protection during surgery. p. 11 Learn from the past to aid the recovery process Past disasters give clues about what you need to consider for the long-term recovery process. June 2012 Vol. 20, No. 6
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June 2012 Vol. 20, No. 6 - · GHS adoption has been on OSHA’s agenda ... back issues are available at $25 each. ... ent from the existing MSDS forms, Cunha says.
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OSHA adds GHS to Hazard Communication StandardExpected revisions align with United Nations global chemical labeling system to improve worker safety
It was only a matter of time, but OSHA has officially
revised its Hazard Communication Standard to include
the Globally Harmonized System (GHS) of Classification
and Labelling of Chemicals. The change was expected
to be announced this year after OSHA submitted the
change to the Office of Management and Budget in
October 2011. GHS adoption has been on OSHA’s agenda
for more than six years.
“Exposure to hazardous chemicals is one of the
most serious dangers facing American workers today,”
Secretary of Labor Hilda L. Solis said in a press release.
“Revising OSHA’s Hazard Communication Standard will
improve the quality, consistency and clarity of hazard
information that workers receive, making it safer for
workers to do their jobs and easier for employers to stay
competitive in the global marketplace.”
OSHA expects the revised standard to prevent rough-
ly 585 injuries and illnesses each year, and improve
productivity for businesses that regularly handle, store,
and use hazardous chemicals, with a cost savings of
$32.2 million for businesses that periodically update
safety data sheets (SDS) and labels. Complete imple-
mentation of the changes is expected by 2016; however,
employers have until December 2013 to train employees
on the system’s new requirements.
Hospitals are one of the primary businesses affected
by the revision of the Hazard Communication Standard,
which has been troublesome for healthcare facilities
even before this
change. OSHA
lists it as the third
most frequently
cited standard from
October 2010 to
September 2011.
Switching to the
new GHS system
should ultimately
make it easier for hospitals to protect employees who
regularly work with hazardous chemicals, says Bruce
Cunha, RN, MS, COHN-S, employee health and safety
manager at Marshfield (Wis.) Clinic.
“I’m usually moderately critical of OSHA and their
new rules, but I think this is a good, positive rule,” he
says. “I think it will help employees—it makes it easier
for them to understand the hazards of a chemical, and
[the change] makes for a much better rule.”
Training employees
Employee training, on both the laboratory and clinical
side, is the most immediate compliance need that safety
officers should focus on, says Kenneth Weinberg, BA,
MSc, PhD, an environmental health, safety, and toxicol-
ogy consultant with Safdoc Systems, LLC, in Stoughton,
Mass. Weinberg, who was previously the director of
“ Revising OSHA’s Hazard
Communication Standard
will ... [make] it safer for
workers to do their jobs
and easier for employers
to stay competitive in the
global marketplace.”
—Hilda L. Solis
IN THIS ISSUE
p. 7 CMS adopts sections of 2012 Life Safety CodeA memo declares CMS is accepting waivers on four sections of the Life Safety Code®, providing leeway for corridor clutter.
p. 9 Double-gloving can be both safe and effectiveAORN shows that double-gloving, particularly with an indicator glove, offers more protection during surgery.
p. 11 Learn from the past to aid the recovery processPast disasters give clues about what you need to consider for the long-term recovery process.
Leo J. DeBobes, MA (OS&H), CSP, CHCM, CPEA, CHEP, CSC, EMTAssistant Administrator, Emergency Management/Regulatory ComplianceStony Brook University Medical Center Stony Brook, N.Y.
Elizabeth Di Giacomo-Geffers, RN, MPH, CSHAHealthcare ConsultantDi Giacomo-Geffers and Associates Orange County, Calif.
Zachary Goldfarb, EMT-P, CHSP, CEM, CHEPPresidentIncident Management Solutions, Inc. East Meadow, N.Y.
Ray W. Moughalian, BS, CHFRMPrincipalSaf-T-Man Methuen, Mass.
John L. Murray Jr., CHMM, CSP, CIHSafety DirectorBaystate Health Springfield, Mass.
Paul Penn, MS, CHEM, CHSPEnMagine/HAZMAT for Healthcare Diamond Springs, Calif.
Dalton Sawyer, MS, CHEPDirector, Emergency Preparedness and Continuity PlanningUNC Health CareChapel Hill, N.C.
Steve SchultzCorp. E&O Safety DirectorCape Fear Valley Health System Fayetteville, N.C.
Barry D. Watkins, MBA, MHA, CHSPSenior EC SpecialistCorporate Safety Carolinas HealthCare System Charlotte, N.C.
Kenneth S. Weinberg, PhD, MScPresidentSafdoc Systems, LLC Stoughton, Mass.
Earl Williams, HSPSafety SpecialistBroMenn Healthcare Bloomington, Ill.
Pier-George Zanoni, PE, CSP, CIHZLH Consulting St. Johns, Mich.
CMS adopts sections of 2012 Life Safety CodeMemo: CMS accepting waivers on four sections of the Life Safety Code, providing leeway for corridor clutter
A Centers for Medicare & Medicaid Services (CMS)
memo released in March offers some flexibility for
healthcare facilities in terms of Life Safety Code® (LSC)
compliance, particularly when it comes to corridor
clutter and combustible decorations.
The memo states that CMS will immediately allow
hospitals to adopt four sections of the 2012 LSC, also
known as National Fire Protection Association 101.
CMS is looking at eventually adopting the entire 2012
edition of the code, but is allowing hospitals to adopt
these sections now through a waiver process. The sec-
tions address the following issues:
➤ Previously restricted items that can now be placed in
exit corridors
➤ The recognition that a kitchen is not a hazardous area
and can be open to an exit corridor under certain
circumstances
➤ The installation of direct-vent gas fireplaces and solid
fuel burning fireplaces
➤ The installation of combustible decorations
CMS decided to adopt these 2012 LSC changes early
in order to appease strong lobbying groups representing
nursing homes, says Brad Keyes, CHSP, a consultant
with Keyes Life Safety Compliance.
“Apparently, owners of nursing homes want to design
new structures with some amenities that you may find
in a retirement home, or perhaps even in a nice home,”
Keyes says.
While most of the changes benefit nursing homes,
the changes were made under the general category
of “healthcare occupancy,” meaning that they will
also apply to hospitals. This will offer some leeway in
comparison to the 2000 LSC that was fully adopted by
CMS, says Steven MacArthur, safety consultant for
The Greeley Company, a division of HCPro, Inc., in
Danvers, Mass.
“CMS is cherry-picking some of the more useful
and influential standards, and allowing hospitals
and nursing homes to take advantage of the more
flexible 2012 requirements for things such as corridor
storage and the presence of combustible decorations
in the care environment, both which had very limited
application based on the 2000 edition of the Life Safety
Code, which is the current enforcement document,”
MacArthur says.
More flexibility with corridor space and
decorations
Of the four changes, corridor clutter and combustible
decorations are the most applicable to the hospital en-
vironment. Fireplaces and kitchens open to the corridor
are issues more commonly found in nursing home envi-
ronments rather than the traditional healthcare setting.
Historically, corridor clutter has been a notorious com-
pliance problem for hospitals, but the new requirements
allow for slightly more leeway, particularly with wheeled
equipment, Keyes says. Wheeled equipment is permitted
to be left unattended in the corridor for more than 30
minutes, provided:
➤ The equipment does not reduce the clear unobstructed
corridor width to less than 5 feet.
➤ The fire safety plan addresses the relocation of
wheeled equipment during a fire emergency. The
plan must identify where the wheeled equipment
will be relocated.
➤ The wheeled equipment is limited to equipment that
is in use, medical emergency equipment not in use,
and patient lift and transport equipment. Beds are not
considered transport equipment or emergency medical
equipment, so they will not be allowed in corridors.
Fixed seating may be installed in corridors that are at
least 8 feet wide, but it cannot project more than 2 feet
Double-gloving can be both safe and effectiveAORN shows that double-gloving, particularly with an indicator glove, offers more protection during surgery
A study published by the Association of periOpera-
tive Registered Nurses (AORN) in March focused on
the benefits of double-gloving during surgery, a practice
that has been endorsed by many associations as a means
to significantly reduce healthcare worker exposure to
bloodborne pathogens.
The results were published after a 24-month investi-
gation by researchers examining the effect of using inner
indicator gloves and the detection of tears or perforations
during surgery.
Although many organizations already support
double- gloving during surgery, this study lends addi-
tional support to the practice’s safety and efficacy, says
Denise Korniewicz, PhD, RN, FAAN, dean and
professor at the College of Nursing at the University of
North Dakota in Grand Forks.
“I think when you have the data that we presented
where you can actually demonstrate that you have more
safety resulting from use of double-gloving, I think it does
give more credence to standards and a set policy,” she says.
Professional recommendations for double-gloving
The Association of Surgical Technologists published Rec-
ommended Standards of Practice for Gowning and Gloving,
which recommends double-gloving for all surgical proce-
dures based on a review of five major studies that revealed
the following:
➤ There is no difference in the number of perforations be-
tween a single pair of gloves and the outer glove when a
healthcare worker double-gloves; however, the number
of perforations in the innermost glove is significantly re-
duced during double-gloving
➤ There is no difference in the number of perforations to
the innermost glove when double-gloving as compared
to wearing a single pair of orthopedic gloves
➤ When the innermost glove is colored when double-glov-
ing, it is considerably easier to detect perforations to the
outer glove, but the detection of perforations of the in-
nermost glove does not increase
➤ Wearing glove liners between the two gloves when
double-gloving significantly reduces the number of
perforations to the inner glove
➤ Wearing an outer cloth glove over the inner glove signifi-
cantly reduces perforations to the inner glove
➤ There was no difference in the number of perforations
to the innermost glove when wearing steel-weave gloves
compared to standard double-gloving
If a sharps injury does occur, double-gloving reduces the
amount of exposure to blood or body fluid since it is being
wiped or stripped off of the instrument as it passes through
the first glove.
In 2004, the American College of Surgeons addressed
the use of double-gloving in an article published in the
Journal of the American College of Surgeons. The authors in-
dicated that perforation rates were as high as 61% among
thoracic surgeons and 40% among scrub nurses. Subse-
quently, double-gloving reduced the risk of exposure to
patient blood as much as 87% when the outer glove was
punctured, and the volume of blood on a suture needle
was reduced as much as 95% when passing through two
glove layers. However, the authors noted that there is still
widespread perception among surgeons that double-gloving
reduces hand sensitivity and dexterity.
Overall, a large body of literature and data suggests
double-gloving is safe and effective, thus supporting the
practice.
A number of other organizations, including the Centers
for Disease Control and Prevention, the Association of peri-
Operative Registered Nurses, and the American Academy
of Orthopedic Surgeons, also support the use of double-
gloving and offer recommendations and support for the
facilities have created more awareness through their
annual bloodborne pathogens training, and more pro-
fessional organizations include double-gloving in their
recommendations. (For a summary of recommendations,
see “Professional recommendations for double-gloving”
sidebar on p. 9.)
“I think when the professional organizations move
forward and say it’s safer, that’s when behavior changes,”
says Korniewicz. “I don’t think it’s because of one or two
research studies that change automatically happens; I
think it takes a while in practice.” n
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Past disasters give clues into the recovery processManaging a large-scale disaster can be difficult enough, but without long-term recovery plans, your hospital is doomed from the start
When you look back at the major disasters of the last
decade, a few come to mind right away. The 10-year
anniversary of 9/11 was last September; Hurricane
Katrina struck in 2005; and most recently Joplin, Mo.,
was destroyed by a category EF5 tornado that virtu-
ally wiped out the local hospital. Overseas, Japan is still
feeling the impact of a deadly tsunami that struck early
in 2011.
Major disasters like these can ravage a community for
months or even years, but once healthcare facilities have
returned to normal operations, their experience provides
a learning opportunity for other hospitals, particularly
when it comes to disaster recovery.
Hospitals need to strike a balance between mitigat-
ing the immediate effects of a disaster in order to treat
the surge of patients and moving forward to return to
normal operations. These are decisions that are typically
made by facility managers along with hospital leader-
ship, says Mary Comerio, a professor of architecture
at UC Berkley College of Environmental Design and an
internationally recognized expert on disaster recovery.
“You are coping and you have a plan on how you’re
going to get back into operation,” she says. “It’s a two-
pronged approach. If you just cope with the emergency
and you’re not dealing with the long term, you’re shoot-
ing yourself in the foot.”
Recovery begins on day one
The immediate aftermath of a disaster will throw
every process off balance, and the following 24 hours
will focus mostly on minimizing the damage, setting up
triage units, and safely caring for existing patients.
But during that time, facility managers and emer-
gency managers should start to think about how their
decisions will affect operations in the future.
“I think the sacred saying of most people in any local
government or emergency management is that ‘recovery
begins on day one;’ this is when you have to start plan-
ning your long-term recovery even while you’re coping
with the immediate impact,” Comerio says.
Initially, the main priority is ensuring safety for all
patients. This often involves a review of basic facility
issues such as:
➤ Power
➤ Emergency generators
➤ Lights
➤ Water
➤ Evacuation or closure of units
➤ Communication
Long-term repairs, particularly architectural or design
repairs, should also be evaluated at this time, with the
understanding that major damage could take years to
fix due to all of the needed permits, engineering evalua-
tions, and—of course—financing. For example, Charity
Hospital in New Orleans took nearly five years to get
back to normal operations after being devastated by Hur-
ricane Katrina.
“All of those things take time, and I think people are
often unfortunately a bit naïve about understanding
why you can’t just snap your fingers and make it better,”
Comerio says.
Recovery planning
Planning for immediate disaster management is often
the primary focus for hospitals, but those plans should