The Accreditation Association for Ambulatory Health Care (AAAHC) places significant emphasis on organizations meeting OSHA regulations and performing proper waste management. However, these are areas where facilities, including ambulatory surgery centers, frequently struggle, says Scott J. Trimas, MD, FACS, a facial plastic surgeon and otolaryngologist in Florida who serves as a surveyor for AAAHC and consultant for its subsidiary, Healthcare Consultants International.
Dr. Trimas identifies seven OSHA and waste management rules and regulations that organizations may find surprising, although failure to meet them could put a facility in violation of OSHA requirements, and thus subject to thousands of dollars in penalties, out of compliance with AAAHC standards and even simply hurt the bottom line.
1. OSHA requirements can vary by state. While OSHA may be a federal agency with requirements that organizations must meet, states develop and operate their own job safety and health programs, and have the authority to establish their own requirements. AAAHC standards require organizations to have knowledge of and meet federal and state guidelines, Dr. Trimas says.
“As a surveyor, I frequently go to an organization and they don’t know their state OSHA requirements,” he says. “I’d say about one-third of all surgery centers I survey are not familiar with their state OSHA requirements.”
2. Copies of hazardous waste manifests must be kept on file. Facilities need to keep copies of the signed manifest provided by the hazardous waste removal vendor following waste removal usually for a period of 5-7 years, depending on the state, according to Dr. Trimas.
3. Organizations need to conduct annual safety device evaluation. A national OSHA requirement, and one Dr. Trimas says many organizations do not meet, is annual testing and evaluation of new safety devices.
“Every year you’re supposed to try safer alternatives to your syringes, needles, IV catheters, blades for surgery, etc., and evaluate whether they’re useful for your organization,” he says. “Probably a third of the organizations don’t do that, or they don’t document they do it. You have to document it.”
4. Biohazardous waste must be kept separate. Biohazardous waste must be kept separate from other waste, and there are often other requirements about where biohazardous waste can be placed and what it can be kept near, which varies by state, Dr. Trimas says.
5. Proper labeling required for biohazardous waste. Biohazardous waste must be labeled as such. “The type of label and what the label needs to indicate vary by state,” he says.
6. Surgical fluid waste can often go down the drain. In many states, organizations can dispose of fluid suctioned away during a procedure, such as blood or saline, down their sanitation system. “However, there are some states that don’t allow you to do that,” says Dr. Trimas. “In these ‘green’ states, they are afraid it will contaminate their water and they will require you to solidify it.”
If your state does not require solidification, it may be cost effective to dump this waste down the sanitation system as opposed to producing more, and expensive, red bag waste.
7. State may allow products with blood on them to go into regular garbage. “If you have gauze that has blood or other patient waste product in it, a lot of times you can throw this in the regular garbage, as long as it’s not saturated,” Dr. Trimas says. “That varies from state to state as well. In Florida, if we have gauze that has some blood on it from dabbing, if it can’t be rung out, then it can be thrown into the regular garbage. If you don’t do that and instead fill a whole red bag with things that could go into the regular garbage, that just wastes money.”
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