By Meagan Collins & Matthew Teeter, as published in Executive Insight
The Occupational Safety and Health Administration (OSHA) has recognized that more than 200 deaths and 9,200 infections related to blood-borne pathogens occur each year. Of those infections, the hepatitis B virus (HBV), hepatitis C virus (HCV), and the human immunodeficiency virus (HIV) are the most common resulting from accidental exposure to blood-borne pathogens (United States Department of Labor, 1991).
More than 5.6 million workers in the United States are exposed to blood-borne pathogens - from doctors to lifeguards and rescue workers - and therefore are at risk of infection. Almost 75 percent of those people work in the healthcare industry. The consequences of poor prevention planning and follow-through are seen not only in individual's health, but in the respective organization's balance sheets.
For example, fines for OSHA violations can run thousands of dollars, yet they are easily avoidable. One of the most common mistakes is seen when a designated safety officer is responsible for meeting OSHA regulations across their facility and other employees shrug individual compliance responsibilities. This is, without question, one of the biggest influencers permitting a facility to slide into noncompliance.
Beyond that, inadequate training protocol, improper handling and disposal of bio hazardous waste, and a lack of an emergency plan all carry heavy risk and fines. The most frequent OSHA violation fined between July of 2009 and June of 2010 was a direct result of engineering and work practice controls not being used to eliminate or minimize employee exposure, according to an HCPro report released in 2010. The average initial cost for this fine was $1,371.
With that said, here are three ways you can lower your risk of noncompliance, keep your workers safe and eliminate fines.
1. Adequate training for all levels of personnel
Failure to train employees in occupational exposure carries an average fine of $750. Being proactive and training employees in clean-up and decontamination procedure is mandatory, not only for the well being of employees' and patients' health, but also to your hospital's finances. According to an International Sharps Injury Prevention Safety (ISIPS) report, when training fails to occur at one or more of the following times - during initial assignment, annually or within one year of previous training - a $7,500 is a likely consequence. Fines issued for training violations do not end there, either.
- Provide an explanation of the use and limitations of methods to prevent or reduce exposure; violating this typically bears an $800 fine.
- Include interactive questions and answers during a training session; overlooking this small detail costs $1,125.
Don't forget: training must be held at no cost to the employee and must be conducted during their working hours. In addition to this, further training must be provided if an individual's exposure to blood-borne pathogens is modified. For example, if an employee is given a new task that poses additional exposure risks, then it is mandatory that you train him or her on these risks.
2. Proper disposal of bio hazardous waste
The average financial consequence for inaccessible, overflowing or unstable sharps containers is $416. Failing to identify type and brand of device on a sharps injury log typically carries a fine of $117 fine.
- Wear equipment that prevents one's skin, eyes, mouth, and work clothes from receiving exposure when handling biohazardous waste.
- Contain any regulated medical waste (RMW) in closable, appropriately-labeled containers that are leak-proof through handling, storing, transporting and shipping.
- Properly label bio hazardous waste with an orange or orange-red label. These labels are also required for contaminated equipment.
3. Written emergency plan that is followed
The average financial consequence for a plan that fails to address procedures for exposure incidents and their investigation is $2,277. Failing to keep an up-to-date exposure control program that reflects new tasks, procedures and practices carries an average fine of $1,297.
Make certain to have a written exposure control program that:
- Evaluates routine tasks and procedures.
- Reviews methods to reduce the risk of accidental procedure.
- Clearly articulates the practices used to meet OSHA standards and accounts for every case of HBV, HCV and HIV.
Standards may seem particular or tricky at times, but they are easy to follow and in place to prevent infection and, ultimately, save lives. Health and safety are the clear, palpable reasons to uphold OSHA regulations. If hospitals are not compliant, then they are at risk to add to the statistic of infections and deaths that occur yearly as a result of blood-borne pathogen exposure. When it comes to OSHA regulations, don't wait until you receive a fine - or worse, an accident happens - to audit and improve your program.
Sanitary wastewater treatment, of course!
Maybe you never once thought about wastewater systems or perhaps you said, “Just dump that; it’ll go to the wastewater treatment facility anyway.” In terms of wastewater treatment, an educated and conscientious public helps keep recreational and drinking water supplies free of contamination. Let’s find out what happens in the sanitary system we use and take for granted every day, and why we should think twice before sending something down the drain.
Wastewater from homes and businesses travels through pipes to larger sewers below ground. The sewers are accessible for inspections and maintenance through manholes, and lead to a publicly-owned treatment works (POTW) facility, which is designed to treat primarily one thing: human waste.
Of course, many other wastes enter the system including “untreatables” such as dental floss, chewing gum, hygiene products, and children’s toys, to name a few. Accidents happen but placing as much untreatable waste as possible into household garbage ultimately saves resources and sewer bill costs because those items must be screened at the POTW entrance (called the headworks) then hauled away.
As repulsive as human waste is to humans, it is nothing less than the most delectable feast to many bacteria. These bacteria, known collectively as activated sludge (are you getting hungry?), are the heart stomach of the POTW.
Under tightly-controlled conditions, sludge digests wastewater organic matter. When the smorgasbord is complete, liquid and sludge solids are separated. Liquid continues through a final disinfection (reaching near drinking water quality) before discharge to a nearby river, lake, or ocean. The dewatered solids are often sold as fertilizer. Other byproducts such as methane gas are produced and can be reclaimed as renewable resources to power the POTW.
Despite my simplification of POTWs, their true complexities are proven by regulations that require designs licensed by professional engineers, permits approved by government agencies, and systems operated by experienced and certified personnel.
Ask if your local POTW offers tours and you can see how much happens “behind the scenes” to keep our waters safe.
Now that you have a basic understanding of sanitary wastewater treatment, will you think twice about what you dump, flush, or rinse down the drain? What do you think happens to other potentially harmful “stuff” that gets into the system? Check back here for more insight.
What’s the difference, and when you should do one or the other
by Sandra J. Perry, Environmental Health & Safety Consultant
The primary difference between a Compliance Program Review and a Compliance Audit is that a compliance audit identifies potential non-compliance specific to onsite activities and programs, related to hazardous waste management, air emissions, wastewater treatment, hazardous materials management, safety practices etc. The program review is a bird’s eye view of the EH&S programs that are currently in place in order to assess the strengths or weaknesses of the current programs.
It is prudent to conduct a comprehensive third-party compliance audit at least every one to two years. A fresh look at day-to-day activities and compliance management systems can take care of that “can’t see the forest for the trees” situation that happens to us all after awhile.
A program review on the other hand is more of a higher level look at the systems and programs that are in place, designed to keep you in compliance. Conducted similar to a compliance audit, each EH&S program area by media – Clean Air Act, Clean Water Act, RCRA, DOT, Radiation Control, NIH, etc. is compared to current applicable regulatory requirements. This is also an excellent means of assessing staffing and organizational structure. It may tell you that you need to go to the President for additional staffing or consider outsourcing specific program areas.
By Amanda Mendonza, Technical Services Representative
So you finally got your RCRA and DOT training and you’re ready to start shipping waste. You learned about appropriate container labeling and how to properly fill out your uniform hazardous waste manifest. One important part of your training should have been making sure your chemical waste is contained in a “specification” packaging for the material you are shipping. If you are shipping a DOT-regulated hazardous material, then your drum will have to be “UN-specification” (that’s UN as in United Nations). This means that the drum has been tested to international standards of integrity, such as drop and pressure testing. You can check whether your drum is UN-specification by the UN test marking located on the side or top of the drum. It will have a series of codes in the following configuration:
1H1/Y1.8/150/05/USA/M824 /1.1 mm
Here is how you decode the series:
1H1: Is a packaging identification code designating the container type, material of construction, and in some cases, a characteristic. In this case the notation is saying this is a closed top plastic drum.
Y: Indicates which of the three performance standards has been met which tells the filler which packing group materials (PG I, II, or III) are allowed. X = OK for PG I, II, or III, Y= OK for PG II or III, Z = PG III only
1.8: Designates the maximum specific gravity of the liquid chemical suitable for this drum. In this case, the notation is saying this drum is able to withstand the weight of a liquid with a density up to 1.8 g/cm3. Non- leak proof containers will have a maximum gross mass in kilograms at this spot in the marking.
150: Is the hydrostatic pressure test in kPa. Non-leak proof containers will have an “S” at this spot in the marking. Shippers must select materials with vapor pressures that are not too high- the pressure test marking is used as part of that calculation (see 49 CFR 173.24a(b)(4) for how to calculate).
05: 2005 Production year
USA: Manufactured in the U.S.
M824: This spot is used to indicate, either by name and address, or by the use of a symbol, what party performed the UN- protocol testing.
1.1 mm: On many drums, the minimum thickness of the material of construction is indicated in millimeters (this is required in some cases for the container to be eligible for reuse).
On reconditioned drums, you may also see an abbreviated version of the full series, such as: 1H2/Y25/S
And remember, all UN-specification drums come with a set of closure instructions by the manufacturer to which you much precisely follow and retain a copy of for a period of 1 year after a package is offered for transport.
By Matthew Teeter, Environmental Compliance Consultant
The use of respirators is wide spread throughout higher education, healthcare, life science and industrial facilities. However, OSHA regulations state that respirators should be the last line of defense.
The use of respirators is only allowed if you have tried to employ some type of engineering control first. If this does not work then administrative controls is the next step. This could be items such as using a less toxic material, use of fans and/or automated equipment. The last line of defense is then the use of respirators.
In the event engineering and administrative controls prove ineffective in controlling the hazards, the employer may issue a respirator to an employee if the employee has passed a medical evaluation, been fit tested and the employer has a written respiratory protection plan. All employer issued respirators except for under certain circumstances filtering face pieces (dust masks), fall under the respiratory protection standard. Prior to issuing a respirator, the employer must have a written respiratory protection plan. The plan is required to include mention of some key information including respirator selection, medical clearance/questionnaire, training, fit testing and proper use/storage of the respirator.
Before donning a respirator, employees must be medically cleared to wear a respirator by a physician or other licensed health care professional. As part of the medical clearance process, a medical questionnaire is required to be answered by the employee. The questionnaire is confidential and has questions related to the employee’s health history and focuses on the task in which the employee is required to wear the respirator. The physician or other licensed health care professional will make the determination if the employee is physically fit to wear a respirator.
Those employees that have been cleared to wear a respirator shall be trained on the following:
- Why the respirator is necessary and how improper fit, usage or maintenance can compromise the protective effect of the respirator;
- What the limitations and capabilities of the respirator are;
- How to use the respirator effectively in emergency situations, including situations in which the respirator malfunctions;
- How to inspect, put on and remove, use and check the seals of the respirator;
- What the procedures are for maintenance and storage of the respirator; and
- How to recognize medical signs and symptoms that may limit or prevent the effective use of respirators.
After an employee has been medically cleared to wear a respirator, each employee must be initially fit tested and annually thereafter to assure the respirator provides a tight fitting seal. Fit testing can be done using either qualitative or quantitative methods. Qualitative fit testing procedures rely on sensation (taste, irritation, smell) to the respirator wearer while quantitative fit testing relies on specialized equipment to measure the fit of the respirator. Additionally, workplace exposure level determines what constitutes an acceptable fit and which fit test procedure is required. Per the Occupational Safety and Health Administration (OSHA), “negative pressure air purifying respirators, users may rely on either a qualitative or a quantitative fit test procedure for exposure levels less than 10 times the occupational exposure limit. Exposure levels greater than 10 times the occupational exposure limit must utilize a quantitative fit test procedure for these respirators. Fit testing of tight-fitting atmosphere-supplying respirators and tight-fitting powered air-purifying respirators shall be accomplished by performing quantitative or qualitative fit testing in the negative pressure mode.”
The employer is required per OSHA regulations to perform a program evaluation to determine if the written respiratory protection program is being properly implemented and to consult employees to ensure they are using the respirators properly. The evaluation should be completed as necessary with any noted deficiencies being corrected as soon as possible.
by Steve Todisco, Healthcare Account Manager
For those of you who routinely ship waste off-site for hazardous waste disposal you should be familiar with what the term lab pack means. In order to understand what a lab pack is we should quickly outline the different types of ways that most people typically ship waste off of their site for hazardous or non- hazardous waste disposal. There are typically 3 major types of overall ways to ship waste off-site: Bulk, Non-Bulk, and Lab Pack.
Bulk waste shipping is shipping waste in larger containers that exceed 119 gallons of waste and is usually utilized for shipping in tanks, tanker trucks, and totes.
Non – Bulk waste shipping can include the shipment of a 55 gallon drum of liquid such as oil, or solvents. These containers might look and feel like a bulk container and they are often referred to that way but because they fall under the 119 gallon requirement we can call these non-bulks.
This brings us to the term lab pack. Lab packing is a method of shipping smaller inner containers inside a larger outer container. This allows companies like ours to be more efficient when shipping “like” materials. If you had several smaller containers that all were intact and contained within their own primary container than these items could be placed into a drum that is equal or lesser than 55 gallons and “lab packed”. Other things like packing material would also fall under the requirements of being added to this lab pack drum. Don’t forget that there are specific requirements for the amount of packing material required in each specific size drum per D.O.T regulations.
By shipping “like” things together you will be utilizing shipping names in the regulations like Waste flammable liquids n.o.s or (Not otherwise specified). This means that the shipping name that best fits all of the materials involved isn’t a specific single item like Waste Acetone, or Waste Methanol. Instead it could include “like” items such as methanol, acetone, and Isopropanol all in the same outer container.
Remember that “lab packing” falls under specific rules and exceptions so only highly trained individuals should undertake these tasks. Combining bottles of chemicals in the same outer container can be dangerous if not done correctly.
By Doug Graham, Senior Compliance Advisor & Training Manager
What makes an EHS specialist qualified and competent? Most employees would agree that training is an essential part of becoming a skilled EHS specialist. In the EH&S world, there are many disciplines that require training, such as the shipping of hazardous materials and the management of hazardous waste. The training is required so that employees tasked with those functions are presented with, and provided an explanation of, specific regulatory requirements which they must meet. But the question becomes, is training enough?
When it comes time to put the knowledge acquired during training to use, can the employee perform the task compliantly? Even further, does the employee continue to be competent if considerable time elapses between tasks or is given new and more challenging tasks? If I'm an employer, I need to know- if I don't, I risk penalties, financial, civil or criminal liability, the reputation of my company or institution, even peoples' lives could be at stake.
It's no secret that employers do not always make an effort to determine if employees are qualified and competent to perform EH&S tasks, usually because they don't see the consequences. . . .right away, that is. (We've heard it- "he's got the certificate, he's good to go"). Concern about competency commonly arises only after a shipment is rejected, a regulatory inspection occurs, a citation is issued, an incident occurs, the environment is contaminated, or a person is injured or killed. It may take considerable time and practice to establish proficiency at mastering the minutiae of a set of regulations to be confident that what he/she is doing is accurate and compliant.
Nowhere in the EH&S world is it more crucial for an employer to determine competency after training, than when offering hazardous materials for transport by aircraft. ValuJet Flight 592 which crashed in the Everglades in 1996- an avoidable tragedy caused by the improper loading of hazardous material, is a stark example. The Federal Aviation Administration (FAA), responsible for enforcement, knows this all too well. In the last 6-7 years enforcement has been vigorous. Enforcement actions against employers have resulted from discovery of non-compliant shipments at air terminals, incidents, and what's becoming ever more frequent, from unannounced inspections of employers triggered merely by offering hazardous materials by air. FAA is very concerned with the qualifications and competence of employees tasked with preparing shipments. One FAA inspector recently, during an onsite inspection, required the employer to assess the competency of each hazmat employee and certify that those previously-trained individuals were qualified, even suggesting an additional employer's signature be added to the original training certificate already signed by the instructor.
So, the lesson to be learned here is, employers should look at EH&S tasks carefully, assess the risks associated with non-compliance, and not only train those employees, but follow-up and have another person with the training, knowledge and experience assess their competency through evaluation of actual job duties. . . only then should they be qualified.
By Sandy Perry, Director of Water Management and Wastewater Services
If you have a wastewater treatment system then you probably (hopefully) have a discharge permit, for which you must have submitted an application to one regulatory agency or another. I’ve found that the section of the application that seems to be the most difficult and takes the most time is where you must list the quantities of wastewater generated from each potential source. This is primarily because few facilities have flow meters on all water use sources.
Ideally, you want to be able to account for the entire volume of water used in a twelve month period. Identifying and quantifying all water uses and the outputs of this water to match the incoming water is typically a challenge. Why? Because it is difficult at best to estimate the amounts evaporated, the boiler blow down quantity, lab sink contributions, or discharges from scrubbers, production operations where some of the water may be consumed in the product or wastes collected for offsite disposal, non-contact cooling (which is clean water and should not go to sewer discharge), RODI reject water, etc.
The best plan is to gather together key people from Facilities, Production, Research, and EH&S to assist in identifying all of the inputs. Piping diagrams are great, but I’ve found that few are kept up to date with piping changes made over the years. Use a white board to begin creating a water mass balance flow diagram and label each box with each water use activity and all of the outputs from each water use source. So for instance, if you have incoming water to your steam boilers, there should be at least two arrows from that box labeled as outputs – evaporation and boiler blow down.
Comparing the total water consumed to the either estimated or metered outputs, you may find that it doesn’t add up. Then you need to review your estimates – what are you missing? What have you double counted? Are your flow meters calibrated? How reliable are they? You may determine the need for additional meters and daily or weekly water use logs. Most regulatory agencies think this is a pretty important aspect of your permit so it’s a good idea to work towards a no more than 1-5% differential between incoming and outgoing water sources. Good luck!
By, Ashley Cole, Chemist II
Looking for a simple rubric to assist you in determining your status as a generator of hazardous waste?
Just remember this number.
If you generate less than 220 pounds of D, U, F or K listed Hazardous Waste in a one month period and NO P-listed materials, then you are a Very Small Quantity (VSQG). If this is the case, the legal requirements you must adhere to are the easiest to comply with.
VSQG's do not have a time limit for storage of waste materials, do not need an EPA ID#, and do not need to keep manifest records. VSQG's must still identify and dispose of Hazardous waste in a State Permitted Hazardous Waste or solid waste disposal facility.
If you generate more than 220 but less than 2200 pounds of D, U, F or K listed Hazardous Waste and no more than 2.2 pounds of P-listed materials in a one month period, then you are a Small Quantity Generator (SQG). Remember, no more than 2.2 pounds or acutely hazardous waste can be generated and stored in both the SAA's and the MAA. Requirements for SQG's are more stringent than VSQG's but significantly less than for LQG's.
SQG's must identify and properly label Hazardous Waste, store it in the MAA for no more than 180 days, obtain an EPA ID#, utilize manifests for shipping hazardous waste and maintain records for at least three years.
If you generate greater than 2200 pounds of D, U, F or K listed Hazardous Waste and more than 2.2 pounds of P-listed materials in a one month period, then you are a Large Quantity Generator (LQG). If this is the case, you must comply with the most stringent code of conduct.
LQG's may store materials in the MAA for no more than 90 days, have an established employee training program, have a formalized written contingency plan for emergencies and spills, submit biennial reports to EPA as well as comply with SQG requirements above.
It is up to each generator to properly assess and track their status. Practicing waste minimization in the laboratory and including your EH + S team in the purchasing process, are both great ways to reduce the potential of accidentally knocking yourself up the 2.2 ladder.
*Please remember that this is a partial list of requirements and that each State Department of Environmental Protection has a greater than or equal to clause when it comes to complying with 40 CFR 261. Check with your local government for further regulatory information.
By Courtney Drayer, Technical Services Representative
Keeping track of manifest return copies can be a hassle especially if you ship waste frequently. If you have not received a signed return copy of your manifest by 35 days from the time of shipment (per 40 CFR part 262.42), it is time to call your friendly TSR to request it. You can track when it is time to call your TSR by using the following four column spreadsheet:
The magic happens in the status column. Logically, what we want to know is "IF the manifest is older than 35 days AND I have not received a return copy THEN I should call my Technical Services Representative to ask for it." You also want to know that "IF the manifest is older than 35 days AND I have received a return copy THEN I am in compliance." And finally you'll want to know "IF the manifest is younger than 35 days AND I have received my return copy or I have not received my return copy THEN I am in compliance". We can say all that in excel using the following formula in column D;
=IF(AND((TODAY()-B2>35), C2="N"), "Call your TSR", "Compliant")
Now all you have to do is enter your manifest #, the shipment date, and whether or not you have your return copy and the spreadsheet will tell you the rest! Since we have used the "TODAY()" function in the formula, the spreadsheet will automatically update every time you open the file so you don't need to keep track of the dates anymore!
If all this still sounds like more data entry than you have time for, you can use Triumvirate's ADVISE software to track manifest compliance.
Your manifests will automatically appear in ADVISE
with red, yellow and green dots showing you the compliance status of each one. You can also scan in and upload your manifest copies (generator’s copy and returned copy) and save them in the program. ADVISE
can be accessed from anywhere you have an internet connection.
So, if an inspector shows up for a paperwork review at one of your sites, you can show them all of your manifests from all of your sites from the comfort of your desk!
Now that’s easy.