FW: Medtronic letter to customers

[Nauss,Karen A (Mount Auburn)]

Hi Everyone,
Here are some of the information I have received back. Very interesting.
Have a wonderful Labor Day and be safe.
Karen



Hi Karen,

This is the OSHA “Bloodborne Pathogens (BBP)” Health & Safety topic from their Central Supply site:

Bloodborne Pathogens (BBP)
________________________________________
As mandated by the Needlestick Safety and Prevention Act, OSHA revised the Bloodborne Pathogens Standard [29 CFR 1910.1030], effective April 18, 2001.

Potential Hazard

Employee exposure to BBP and other potentially infectious materials as bloody, contaminated surgical instruments and sharps (e.g., needles, scalpels) are sorted. Employee must discard any disposable sharps and recycle reusable instruments/equipment that need to be washed and sterilized before their next use.

Possible Solutions
Wear appropriate PPE as required by the Bloodborne Pathogens Standard 29 CFR 1910.1030(d)(3)(i) if blood or Other Potentially Infectious Materials (OPIM) exposure is anticipated. The type and amount of PPE depends on the anticipated exposure including:
Gloves must be worn when hand contact with blood, mucous membranes, OPIM, or non-intact skin is anticipated, or when handling contaminated items or surfaces [29 CFR 1910.1030(d)(3)(ix)].
Wearing thick utility gloves and gowns can offer additional protection to the employee sorting contaminated items.
Utility gloves may be decontaminated for re-use if the integrity of the glove is not compromised. However, they must be discarded if they are cracked, peeling, torn, punctured, or exhibit other signs of deterioration or when their ability to function as a barrier is compromised. [29 CFR 1910.1030(d)(3)(ix)(C)].
Promote using engineering controls such as safer needle devices to help remove or isolate exposures to blood and bloodborne pathogens (e.g., self-sheathing needles, needle less connectors, retractable needles) [29 CFR 1910.1030(c)(1)(iv), 29 CFR 1910.1030(d)(2)(i)and OSHA Directive, CPL 2-2.69 (2001, November 27).
The Bloodborne Pathogens Standard also requires:

Discarding contaminated needles and other sharp instruments immediately or as soon as feasible after use into appropriate containers [29 CFR 1910.1030(d)(4)(iii)(A)(1)].
Sharps containers need to be available, and in close proximity to areas where sharps may be used [29 CFR 1910.1030(d)(4)(iii)(A)(2)].
Contaminated needles and other contaminated sharps shall not be bent, recapped, or removed except as noted in paragraphs 29 CFR 1910.1030(d)(2)(vii)(A) and 29 CFR 1910.1030(d)(2)(vii)(B).
Employers must provide readily accessible hand washing facilities, [29 CFR 1910.1030(d)(2)(iii)] and ensure that employees wash their hands immediately or as soon as feasible after removing gloves [29 CFR 1910.1030(d)(2)(v)].

For additional information see Healthcare Wide Hazards - Bloodborne Pathogens.

https://www.osha.gov/SLTC/etools/hospital/central/central.html

The only thing close to what Medtronic is stating is “Employee must discard any disposable sharps and recycle reusable instruments/equipment that need to be washed and sterilized before their next USE”. Loaner instrumentation being brought from outside of a hospital will be washed and sterilized before their next actual use anyway, so are they establishing the action of the rep picking instruments up as the next “use”?

Additionally, in the Bloodborne Pathogens Standard, under “(e)(2)(iii) Containment Equipment.”, line (e)(4)(v) states “An autoclave for decontamination of regulated waste shall be available within or as near as possible to the work area”. Does this mean they are classifying decontaminated loaners as “regulated waste”?

Regulated waste is defined as the following according to the Bloodborne Pathogens Standard:
Regulated Waste means liquid or semi-liquid blood or other potentially infectious materials; contaminated items that would release blood or other potentially infectious materials in a liquid or semi-liquid state if compressed; items that are caked with dried blood or other potentially infectious materials and are capable of releasing these materials during handling; contaminated sharps; and pathological and microbiological wastes containing blood or other potentially infectious materials.

If loaners are classified as regulated waste, then if you look at section “(d)(4)(iii) Regulated Waste”, Medtronic should be providing us with regulated waste containers for disposal of said waste. I think Medtronic should look over the standard and establish the definition the instruments correspond to.

This is the link to the Bloodborne Pathogen Standard:
https://www.osha.gov/needlesticks/needlesticks-regtxtrev.html

Regards,
Eli

-----Original Message-----
From: Rooney, Dawn [mailto:Dawn....@ministryhealth.org]
Sent: Friday, September 02, 2016 8:51 AM
To: Nauss,Karen A (Mount Auburn)
Cc: Duro,Mark (Director, CSPD)
Subject: Medtronic letter to customers

Happy Friday Karen,

Here's the letter from Medtronic. :)

Have a great Labor Day weekend.
Dawn

-----Original Message-----
From: Arndt, Gina
Sent: Friday, September 02, 2016 7:49 AM
To: Rooney, Dawn
Subject: FW:



Gina

-----Original Message-----
From: C...@ministryhealth.org [mailto:C...@ministryhealth.org]
Sent: Friday, September 02, 2016 6:12 AM
To: Arndt, Gina
Subject:

This E-mail was sent from "CS1" (LD015).

Scan Date: 09.02.2016 07:11:35 (-0400)
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