Regulatory Compliance

Regulatory Compliance / en Tue, 22 Oct 2024 21:28:44 -0500 Tue, 18 Jun 24 13:17:15 -0500 The Joint Commission: New and Revised Requirements for the Infection Prevention and Control (IC) Chapter – Analysis and Next Steps /joint-commission-new-requirements-infection-prevention-and-control-chapter-2024 <h1>ANALYSIS AND NEXT STEPS The Joint Commission: New and Revised Requirements for the Infection Prevention and Control (IC) Chapter</h1><h3>The Joint Commission approved new and revised requirements for infection prevention and control (IC) standards, effective July 1, 2024.</h3><h3>Your current program is valid, but it needs expanding.</h3> Tue, 18 Jun 2024 13:17:15 -0500 Regulatory Compliance Pulling Back the Sheets on the Bed Bug Controversy /pulling-back-sheets-bed-bug-controversy <h4>By Ron Harrison, Ph.D., B.C.E. and Bill Lawrence, Ph.D., B.C.E.</h4>May 22, 2017&nbsp;|&nbsp;Formats:&nbsp;White Paper&nbsp;|&nbsp;Content Areas:&nbsp;Administration, Environmental Sanitation Operations, Regulatory Compliance&nbsp;|&nbsp;Tags:&nbsp;Beds, Chemicals , Contracting, Cost Management, Disaster/Outbreak Preparedness, Environmental hygiene and sanitation, Infection Prevention and Epidemiology, Laundry and Textiles, Linen , Pest Control, Process Improvement<hr>Bed bugs exhibit a number of unique characteristics that make them problematic pests: parasites that are almost exclusive to humans; bites that frequently produce no reaction; nocturnal feeders that stay out of sight during the day, making them difficult to detect. The severity of the risk presented to humans is inconclusive. Clearly, further research is needed to define the degree of the the threat that bed bugs pose. Until then, prevention and early detection are the best practices.Health care providers will need to rely on their staff for an effective monitoring and prevention strategy. Working hand in hand with your pest management professional, staff education and cooperation is essential to identifying and reporting potential bed bug infestations. Your pest management professional can educate employees about the pests, harborage points and signs of their presence. They can also train staff on sanitation practices and monitoring activities that will reduce the risk of a bed bug infestation and ensure that if bed bugs do enter your facility, they don't take up residence.As the debate around bed bug continues to evolve and further research brings to light new information about these pests, the prevention and management practices will also evolve. In the meantime, rest easy with a proactive approach and the advice of a trained pest management professional.&nbsp; &nbsp; Mon, 22 May 2017 09:27:20 -0500 Regulatory Compliance Sustainability and Compliance /sustainability-and-compliance <h4>By Debra Gillmeister, MBA</h4> September 23, 2013 | Formats: Article | Content Areas: Environmental Sanitation Operations, Regulatory Compliance | Tags: Chemicals , Policies, Regulatory Compliance, Sustainability, Waste Management and Sustainable Operations <hr> Healthcare facilities can generate up to 25 pounds of waste per day per patient. (1) Hospital leaders recognize the large amount of waste is a consequence of operating around the clock. Priorities are shifting to achieve a balance of sustainability and compliance that pushes environmental boundaries with commitments to improving air and water quality. Many regulatory standards for properly managing waste were set in motion beginning in 1976 followed by RCRA, and then the Clean Water Act, the Safe Drug Disposal Act, and the Hospital Medical Infectious Waste Incinerator Rule, to name a few. Yet the average number of regulatory compliance issues (The Joint Commission, OSHA, EPA, and/or Department of Transportation) uncovered during a typical hospital compliance review is 23. (2)&nbsp; To 91��members at the EXCHANGE 2012 conference, Laurie Leon, director of materials management at Boca Raton&nbsp;Regional Hospital, highlighted that 90 percent of hospitals could not readily pull together cost and weight data for their waste streams. This reality can lead to financial pressure. No Single Department is Responsible for Managing Waste “There is no single department responsible for managing waste. What is positive is that hospitals are taking a currently decentralized model for managing multiple waste streams and streamlining it into an integrated model,” she noted. “When I ask facility leaders how many soap dispensers or surgical kits they ordered last year and the total spent, they can answer in a few clicks. When I ask: ‘What was your total waste spend last year?’ everyone looks around the room,” said Leon. Why? Many departments are responsible for different waste streams. “Environmental services (EVS) professionals usually manage the bulk of medical waste and solid waste. EH&amp;S or the facilities department might be responsible for the hazardous waste streams. And engineering typically takes construction waste,” Leon concluded. (2)&nbsp; When the process of managing waste is segmented, a great burden is placed on EVS teams. Cross functional collaboration and communication between many departments within the hospital is critical. Education Changes Culture Identifying ways to stay compliant while becoming sustainable often means implementing a green team and educating staff to stop looking at waste as ‘waste’ when items such as desks, chairs, water pitchers, cups, laptops, and iPads are recyclable. Managing 10 to 12 waste streams, 80 percent of which are highly regulated, is not an easy task. The process involves clinical and non-clinical departments and requires a significant culture change, no matter the size or location of the hospital. Segregation and waste stream diversion standards help redirect waste to drive better economics and sustainability efforts. 91��member, Yale-New Haven Hospital Environmental Services Team Lead&nbsp;Robert Frankel noted, “There is a massive opportunity for waste reduction and sustainability within hospitals. Rounding with managers and speaking with staff helps make sure that things are being disposed of in the appropriate waste stream. Education is critical to focus on getting bandages, gloves, and other normal trash materials out of the red bags and into the clear bags or containers where they belong.” Keep Drugs Out of the Public Water System It is important for EVS teams to know what waste they are handling, whether it is hazardous or nonhazardous, and the process of signing the appropriate manifests or DOT shipping papers. The EPA has specific management requirements for hazardous waste. For instance, medications such as warfarin (Coumadin) and nicotine must be kept out of the water supply and therefore should be discarded in separate, designated containers that require responsible disposal by a properly licensed company. Either way, several guidelines help you better understand the risks. <ol> <li>Understand which state or federal regulations impact drug disposal;</li> <li>Protect your community by not allowing narcotics to be diverted; and</li> <li>Properly store waste on site and restrict accessibility to unauthorized personnel.</li> </ol> The issues of pharmaceuticals polluting the waterways were highlighted in the early 2000s with the U.S. Geological Survey (USGS) Water Survey finding substances in&nbsp;80 percent of tested streams. Roughly one third of those contaminants were pharmaceutical substances which prompted close examination of how hospitals dispose of pharmaceuticals and how they affect Americans. Regulatory and legislative bodies have begun establishing and enforcing strict hospital waste guidelines. This increase in regulatory oversight has left hospital leaders challenged to understand what their role and responsibilities are and how to avoid costly fines and citations. \ Combined with keeping drugs out of the water, hospital leaders and EVS professionals also desire to keep containers that carry pharmaceutical waste out of landfills. At Beebe Medical Center (BMC) in Lewes, Del., a 24-month case study (2) of reusable pharmaceutical containers tracked the reuse rates for 2,184 containers serviced. Ninety-seven percent of the reusable containers were eight-gallon and 17-gallon. By utilizing reusable containers, BMC diverted between 3.7–5.0 tons of plastic from disposal, therefore minimizing landfill contributions and reducing hospital disposal costs. Proactive, Reusable Sharps Container Services Don’t Always Add Labor Costs An often overlooked component of reducing waste includes the waste containers such as reusable sharps containers. Yale-New Haven Hospital switched from using disposable to eco-friendly reusable sharps containers. The solution creates a “win-win” for the facility said Frankel. “Staff&nbsp;safety is improved due to the container’s user-friendly ‘point and drop’ design. The container is a FDA-regulated medical device, which can be reused 600 times creating a greener, more sustainable solution. We use a company that manages proactive container exchange, so EVS teams and hospital staff no longer have to replace filled containers. This service decreases labor, and we have realized a 25 percent reduction in regulated medical waste,” said Frankel. The Dana Farber Cancer Institute, Boston, Mass., has a clinical program devoted to cancer care. “All of the clinical sharps containers are sent for incineration as trace chemotherapy. However, most of the sharps from our basic research program are diverted to the reusable sharps container service to improve our carbon footprint,” explained Karen Byers, biosafety officer. “We implemented the proactive container exchange service, very cautiously at first, on one research floor for three months. We then expanded the service to one building on another campus and then expanded to our research community. The statistics speak for themselves. In 2012 we diverted 6,562 pounds of plastic and 515 pounds of cardboard from the landfill, which prevented the emissions of 3,896 pounds of CO2. These numbers are the equivalent of not burning 201 gallons of gas or 74 propane cylinders for home barbeques.” (3) Byers noted that the service has resulted in considerable time savings. “Previously, researchers had to order disposable sharps containers, monitor the level of sharps in the container, replace as required, and then request pickup of the full container. Now the process is automatic—the container exchange partner comes in, removes containers, and replaces them. This is working well.” Byers noted that the service has resulted in considerable time savings. “Previously, researchers had to order disposable sharps containers, monitor the level of sharps in the container, replace as required, and then request pickup of the full container. Now the process is automatic—the container exchange partner comes in, removes containers, and replaces them. This is working well.” <img alt="Managing hospital waste streams is a complex process" data-entity-type="file" data-entity-uuid="1d561544-3c16-4461-b1e1-77014a187270" src="/sites/default/files/inline-images/SustainabilityandCompliance.png" width="686" height="453"> References <ol> <li>www.sustainabilityroadmap.org/topics/waste.shtml#.Udq-_ax2nqQ</li> <li>Stericycle, Inc.</li> <li>www.stericycle.com/carbon-footprint</li> </ol> Mon, 23 Sep 2013 10:16:26 -0500 Regulatory Compliance OSHA HAZCOM and GHS /osha-hazcom-and-ghs <h1>OSHA HAZCOM and GHS</h1> <h4>By Kathy Thompson, CIH, MT(ASCP), MPH, MS</h4> September 23, 2013 | Formats: Article | Content Areas: Administration, Regulatory Compliance | Tags: Chemicals , Employee Safety , Environmental hygiene and sanitation, Environmental Monitoring Tools, Regulatory Compliance <hr /> The Occupational Safety and Health Administration (OSHA) is tasked with protecting worker health and safety in the U.S. OSHA develops and enforces many standards that apply to workplaces everywhere, including the healthcare environment. One of those standards, the OSHA Hazard Communication (HazCom) Standard, has been significantly revised for the first time since it came about in the 1980s. Those changes in the “Right-to-Know” Standard, as HazCom is commonly called, have brought in the use of the Globally Harmonized System (GHS) to identify and communicate chemical hazards. This new OSHA final rule became effective on May 25, 2012, and is called HazCom 2012. The major change in the HazCom Standard is to use GHS, which offers a prescriptive approach rather than the previous performance-oriented approach, to determine the hazards of chemicals and communicate them via labels, signage, and safety data sheets (SDSs). This means that you will start seeing a different look to these items and that the term “MSDS” is now changing to SDS due to the newly required GHS format. But what is GHS, and where did it come from? GHS is a product of the United Nations (UN) and initially came about through committee work on the transportation&nbsp;of dangerous goods. At the 1992 UN Conference on Environment and Development, there was agreement to implement global harmonization for sectors beyond transportation to include many more hazards with the intent that all member countries would eventually be harmonized in their approach to hazardous chemical criteria. While safety was one incentive for this “global harmonization,” it was also the economic burden to multi-national companies with hazardous materials criteria and communication differences from country to country that gave rise to the GHS. While the first edition of the GHS was published by the UN in 2003, it is the third edition from 2009 that OSHA adopted in the revised HazCom 2012. Because of the ‘building block’ structure of the GHS, implementation between countries can look different in large part due to differences in their regulatory framework and rulemaking processes. The U.S. Department of Transportation has actually been using GHS for some time, but that change was not as visible as the OSHA changes will be. Chemical labels and SDSs will look quite different than before once they are converted to GHS format. So, when will that start to happen? The first OSHA HazCom 2012 compliance deadline you may have heard about is the initial training date of December 1,&nbsp;2013—that is when workers must be trained on the general elements of GHS labels and SDSs because they will start to see them and need to know how to interpret their information. This training should be considered just the beginning though; so while it needs to be done for compliance, it is also a good opportunity to help ease worker concerns about these regulatory changes and prepare your workplace for the transition to GHS. The next compliance deadline is for manufacturers and importers, who have until June 1, 2015, to change their chemical product labels and MSDSs to the OSHA GHS format. Because many end-users obtain their chemicals from distributors, there is a later compliance deadline of December 1, 2015, to allow for product sell-through. After that date, products shipped by distributors must have the new GHS labels and SDSs. It is expected that between now and then will be a transition period where you could start to see the new GHS information anytime from your chemical suppliers. Note that some products, such as disinfectants, have labels regulated by the Environmental Protection Agency (EPA) as well as OSHA, but since the EPA has not adopted GHS, these products will need a hybrid approach to labeling and SDSs. For Environmental Services (EVS) Professionals in healthcare, it is important to be aware of the upcoming OSHA&nbsp;compliance deadlines and changes because the Hazard Communication Standard intertwines with many other requirements that affect EVS operations, such as The Joint Commission (TJC) Environment of Care Standards. OSHA regulations that apply to EVS workplaces are also mirrored by TJC, mostly in EC.02.02.01 for hazardous materials and waste. In that Standard, you will see many of the same elements required by OSHA, such as a written chemical inventory and procedures, labeling, and maintaining a collection of MSDSs. Keep in mind that although HazCom is changing to use GHS, many basic elements of the OSHA Standard (such as the need for a written program, chemical list, and (M) SDS access plus labels and training) remain&nbsp;the same. Also compliance with HazCom is often targeted by inspectors, with that Standard consistently in the OSHA Top Ten for citations. So how does the move to using GHS change the look of labels and MSDSs? The previous Hazard Communication Standard was termed “performance-oriented” because it allowed chemical manufacturers considerable flexibility in how they determined and communicated hazards. While certain information was required on the label and MSDS, there was no specific format required so the same chemical from different manufacturers could have very different looking hazard communication. The move to GHS means using specific criteria to “classify” chemical hazards along&nbsp;with defined label elements and SDS format. This should increase the quality and consistency of chemical hazard information and the new term OSHA uses for HazCom 2012 is the “Right-to-Understand” rather than the previously used “Right-to-Know.” One of the new GHS label elements you will most likely notice is called a pictogram. This is a symbol that represents certain hazard classes, and OSHA will require it to have two colors—black (on white) with a red border. There are nine pictograms in GHS, but OSHA will only require eight of them because they do not have jurisdiction for Environmental Hazards and the pictogram that represents them. The new GHS SDS requires the hazards be identified in Section 2 (where you previously often found the ingredients listed), so you may also see the pictograms on the SDS there, even though the actual symbols are only required on the label and descriptive words for them can be used on the SDS. Since an individual pictogram can represent more than one type of hazard, it will be important to read the statements as well to fully understand the chemical hazards. The MSDS has come a long way since the concept was first developed for a few select chemicals by their manufacturers in the 1940s, to it becoming an OSHA regulatory requirement in the 1980s, and now aligning with a globally harmonized approach with HazCom 2012. This evolution is expected to improve worker health and safety once workplaces have successfully managed the transition to GHS. Seeking help from your chemical suppliers and safety or industrial hygiene resources&nbsp;may be a good place to start as you review your written Hazard Communication Program, plan for training, and prepare for HazCom 2012 compliance. References <ul> <li>OSHA/SCHC Alliance Webinar August 13, 2012</li> <li>National Safety Council Safety and Health Magazine, Dec 2012</li> <li>www.osha.gov/law-regs.html</li> <li>Comprehensive Accreditation Manual for Hospitals, January 2013, TJC Publication</li> <li>Kaplan, Samuel A., History of the MSDS, Presented at the 191st ACS National Meeting, April, 1986, New York, NY</li> </ul> Mon, 23 Sep 2013 09:55:25 -0500 Regulatory Compliance