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Q I am the nurse manager for surgical support services at a small rural hospital where we recently formed an occupational safety committee. We are developing a policy and procedure manual and I volunteered to write the section on the safe handling and disposal of contaminated sharps, needles and related objects. Are there any specific standards or guidelines that address this issue? Could you suggest any key topics that should be included in the manual?
A Occupational Safety Health Administration (OSHA) is a federal agency which issues and governs regulations relative to worker safety. OSHA does have strict regulations which include those relative to the proper handling of sharps such as needles and other devices used in a clinical environment. The Environmental Protection Agency (EPA) is another federal agency which is focused on environmental safety and preservation. There are EPA regulations that health care institutions must follow relative to the disposal of bio hazardous materials, including medical waste (e.g., disposable medical devices, supplies and the like contaminated with blood, body fluids or other organic matter). Contaminated, used needles and other sharp objects are considered bio-hazardous. OSHA and EPA regulations are governed by law and must be enforced and implemented. Violations are subject to severe penalties including fines, suspension of services and possible closures. All sharps need to be disposed of in an OSHA approved containment device clearly identifiable (labeled or color coded) as a contaminated sharps disposal container. Sharps containers can be made from a variety of materials including cardboard or plastic. (See Figure 1.) To be acceptable by OSHA, the container must be closable, puncture-resistant, and leak proof on all sides and the bottom. Sharps containers must be easily accessible to employees and located as close as feasible to the immediate area where sharps are used, such as patient care areas, surgical suite and support areas such as central sterile processing, laundry and the like. OSHA mandates that each sharps container must either be labeled with the universal biohazard symbol and the word “biohazard” (see Figure 2) or be color-coded red. Sharps containers shall be maintained upright throughout use, replaced routinely, and not be allowed to overfill. When removing sharps containers from the area of use, the containers shall be:
- Closed immediately prior to removal or replacement to prevent spillage or protrusion of contents during handling, storage, transport, and/or shipping
- Placed in a secondary container if leakage is possible. The secondary container must also be closable and constructed to contain all contents to prevent leakage during handling, storage, transport, and shipment. Secondary containers must also be labeled and or color-coded as previously noted.
- Upon closure, duct tape may be used to secure the lid of a sharps container. A solid lid must be used; the tape cannot serve as the lid itself.
If used, reusable containers shall not be opened, emptied, or cleaned manually or in any other manner which would expose employees to the risk of percutaneous injury. Bio-hazardous waste must be handled in accordance with OSHA and EPA regulations. EPA, like OSHA, requires bio-hazard materials and waste to be clearly identifiable via labeling and/or color coding. Bio-hazard waste cannot be disposed of in a landfill but must be rendered safe prior to disposal. While there are various means of rendering bio-hazardous materials safe for disposal including, decontamination, sterilization, incineration, chemical applications and other mechanical processes, the process can be quite complicated and expensive. Therefore most medical facilities utilize the services of a professional bio-hazard disposal company. It is critical that you verify that the any services you employ are EPA-compliant. It is also very important that you consult with your local and state departments of Public Health, EPA, and OSHA to ascertain if they have any additional regulations.
Q We have a new head nurse in Labor and Delivery and he has been making many changes to instrument set contents. He has now requested that a baby blanket be included in both the Vaginal and C-section delivery trays. While we have been doing this for him, I am very concerned that this might not be an acceptable practice as I do not have an IFU for sterilizing the receiving blankets. Do you feel this is something we should be doing? If not could you suggest a more acceptable alternative I could present to him.
A If it is clinically essential that a sterile blanket or other textile is required on the sterile field for use in an aseptic procedure then you are correct, you must have an IFU or other documentation with validation for the sterilization protocol. Aside from sterilization there are other concerns with placing linens within instrument sets. Lint and fibers from the linens may be deposited onto the surgical instruments ending up in and remaining within the surgical site. These foreign bodies left within the surgical site could present a risk to the patient welfare, causing infection or granuloma. If the blanket is to be used for passing the baby to the circulating nurse it is not necessarily an aseptic procedure and a clean receiving blanket held by the circulator or bassinet liner may suffice. I would suggest meeting with the head nurse and ICP to assess the need for a sterile blanket or linen. If it is determined that it necessary there are linens such as drapes, bedding and packaging materials that are validated for sterilization and you may also explore some prepackage sterile options.
Ray Taurasi
Ray Taurasi is Principal, Healthcare CS Solutions. His healthcare career spans over five decades as an Administrator, Educator, Technologist and Consultant. He is a member of AORN, SGNA, AAMI and a past president of IAHCSMM. Taurasi has been a faculty member of numerous colleges teaching in the divisions of business administration, nursing, and health sciences. He is the author of numerous articles and textbook chapters; he is a frequent speaker at national and international healthcare conferences.
Note to readers from Ray Taurasi - In 2021, my life’s career path will transition to one of new opportunities and adventures. As a result, after nearly 19 years and 225 CS Solution columns, this edition will be my last.
“All changes, even the most longed for, have their melancholy; for what we leave behind us is a part of ourselves; we must die to one life before we can enter another.”– Anatole France
I wish you and your loved ones a healthy and joyful holiday season and a beautiful New Year! God Speed, Ray
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