Copyright 2000 Federal News Service, Inc.
Federal News Service
June 22, 2000, Thursday
SECTION: PREPARED TESTIMONY
LENGTH: 2372 words
HEADLINE:
PREPARED TESTIMONY OF DR. TAMMY LUNDSTROM MEDICAL DIRECTOR FOR EPIDEMIOLOGY
DETROIT MEDICAL CENTER AND ASSISTANT PROFESSOR, WAYNE UNIVERSITY ON BEHALF OF
THE AMERICAN HOSPITAL ASSOCIATION
BEFORE THE
HOUSE EDUCATION AND THE WORKFORCE COMMITTEE SUBCOMMITTEE ON
WORKFORCE PROTECTIONS
SUBJECT - THE BLOODBORNE PATHOGENS STANDARD
BODY:
Mr. Chairman, I am Dr. Tammy Lundstrom,
medical director for epidemiology at the Detroit Medical Center and assistant
professor of medicine in the Division of Infectious Diseases at Wayne State
University in Detroit.
I am here today on behalf of the American
Hospital Association's (AHA) nearly 5,000 hospital, health system, network and
other health care provider members. We are pleased to have the opportunity to
testify on the effectiveness of the Bloodborne Pathogens Standard, issued by the
Occupational Safety and Health Administration (OSHA).
BACKGROUND The
Detroit Medical Center and its hospitals have been caring for the people of
southeast Michigan since 1868. Today, the Detroit Medical Center operates seven
hospitals, twonursing centers and more than 100 outpatient facilities throughout
southeast Michigan. Our health system employs more than 13,000 people and serves
as the teaching and clinical research site for Wayne State University, the
nation's fourth largest medical school. Last year, we discharged more than
100,000 patients from our hospitals; our outpatient facilities cared for more
than 1.5 million patients; and our emergency rooms saw an additional 260,000
patients. As director of epidemiology for our health system, I actively manage
the clinical aspects of our sharps injury prevention program, and I am
responsible for investigating and analyzing sharps injuries that occur in our
health institutions. This involves meeting the injured health care worker,
documenting the occurrence and providing on-the-spot counseling. It also
involves a thorough analysis of how, when and why the injury occurred as well as
recommending changes in the process to prevent it from happening again. In
addition to my work at the Detroit Medical Center, I am a practicing HIVAIDS
physician in inner-city Detroit, working as an infectious disease specialist. In
my clinical practice, I see and care almost exclusively for HIV-infected and
AIDS patients, and understand first-hand how critical the Bloodborne Pathogens
Standard and sharps injury prevention programs are for patients and health care
workers.
AHA-OSHA COLLABORATION
The AHA and its member
institutions, including the Detroit Medical Center, have a longstanding
commitment to ensuring the safety of patients and health care workers. Our work
on this particular issue dates back to the early 80s, when the AHA
developedrecommendations on managing HIV infection, including adherence to blood
and body fluid precautions. We continued our work in this critical area in 1987
when we produced the teleconference, "AIDS: Protecting Hospital Employees." In
1989, we worked with OSHA to create and distribute a video and educational
material titled "Working Together: Needlestick Prevention."
We are especially proud of our collaboration with OSHA when the agency
developed the 1991 Bloodborne Pathogens Standard. This standard revolutionized
safety for the approximately 5.6 million health care workers at risk of exposure
to bloodborne pathogens, such as HIV, Hepatitis B and Hepatitis C.
Throughout this period, we have continually communicated with hospitals
and health systems, advocating sharps safety and injury prevention through
various publications, videos and educational seminars.
Based on the
Bloodborne Pathogens Standard and its guidelines, hospitals and health systems
across the country developed and implemented sharps injury prevention programs,
including voluntarily adopting needleless systems and engineered devices.
Specifically, the 1991 OSHA standard mandates that hospitals and health systems:
Develop and implement an exposure control plan. This requires health systems to
identify and document activities where exposure to bloodborne pathogens occur,
design a plan to eliminate or minimize health care workers'exposure to
bloodborne pathogens, set up a schedule for implementing the plan and annually
review and update the plan, Determine methods of compliance using universal
precautions and personal protective equipment, emphasizing engineering and work
practice controls. Follow standard microbiological practices in HIV and
Hepatitis B virus labs, and provide additional training for. health care workers
in these facilities. Provide the Hepatitis B vaccine to any health care worker
who has the potential to an occupational exposure to blood. Provide
post-exposure evaluation and follow-up, including a confidential medical
evaluation, to employees involved in an exposure incident. Prominently display
warning labels on containers used to store or transport blood or other
potentially infectious materials. Provide employee training in minimizing
exposure to bloodborne pathogens. Training includes information on bloodborne
diseases and their transmission, engineering and work practice controls,
universal precautions and personal equipment, how to handle exposure incidents,
post-exposure activities and follow-up, and a copy of the hospital's exposure
control plan. Maintain records for each employee with occupational exposure
during their tenure at the hospital and for an additional 30 years.
EFFECTIVE PREVENTION MEASURES
The Bloodborne Pathogens Standard
has made huge strides in protecting health care workers. For example, the
standard, hospital education efforts and an effective vaccinehave made our
health care workers less at risk for infection from Hepatitis B than the general
public.
Hospitals and health systems continually strive to eliminate
sharps injuries. Recent analysis estimates that US health care workers sustain
approximately 380,000 percutaneous injuries per year, based on data from EPINet
at the University of Virginia and the National Surveillance System for Hospital
and Health Care Workers at the Centers for Disease Control and Prevention (CDC).
Hospitals and health systems are committed to decreasing these injuries
through education, training, evaluation and implementation of sharps injury
prevention programs, including the adoption of engineered devices. Manufacturers
continue to develop newer devices that have the potential to further decrease
sharps injuries.
Six years after the initial standard took effect, OSHA
reviewed its compliance directive.
In 1998, OSHA issued a request for
information about sharps injuries prevention programs and engineered devices.
The AHA supported and assisted this effort by alerting our members and
encouraging them to share information about their programs with OSHA.
In
response to this request, hospitals and health care systems provided detailed
information about their sharps injury prevention programs, including the
education and training components, and how engineered devices are evaluated and
implemented.The resulting responses prompted OSHA to update its compliance
directive for the Bloodborne Pathogens Standard. Consistent with the wider array
of devices available in the marketplace, the directive now explicitly includes
safety needles and other engineered -- devices in its definition of engineering
controls and requires their use. The AHA issued a membership advisory outlining
these changes and included OSHA's definition of engineering controls and its
mandate to use safety devices.
We believe this revised compliance
directive provides enforcement guidelines that are clear-cut and decisive, but
flexible enough to allow evaluation of existing and new devices. Many devices
that are less traumatic to patients, more accurate, and safer for workers are in
use today while others are being developed and tested. For example, blunted
suture needles may be used to close a wound. In some cases, though, the tissue
is so fragile and delicate, such as with membranes or vessels, that the use of
these needles would lead to additional trauma and possibly a greater risk of
infection.
The key questions we must always ask are: "Will this be safer
for my patient?" and "Will this be safer for our health care worker?" We are
always seeking new and better ways to ensure the safety of both.
THE AHA
GUIDE
The AHA and its members are continually assessing safety
procedures for patients and health care workers. In March 1999, the AHA
published Sharps Injury PreventionProgram - A Step-by-Step Guide, and provided
it free to our members. The guide assists hospitals and health systems in
developing a needlestick and sharps injury prevention program.
It includes regulatory guidance and expertise, and offers case studies to help
health care organizations learn from the experience of others.
According
to the guide, the 12 steps to setting up a successful program revolve around
communication, education, training and collaboration:
1. Communicate
commitment to a safe environment for patients and workers. 2. Assign a point
person to be in charge of sharps injury prevention efforts. 3. Assemble a
multidisciplinary team that includes representatives from: Infection control
Risk management Quality improvement Nursing Medical staff Laboratory
Employee/occupational health Safety
Materials management
Frontline workers and departments using devices
4. Gather
information on current use and availability of engineered devices in the
facility.
5. Collect data and identify devices/areas/uses/staff with
greatest risk of exposure to bloodborne pathogens.
6. Select targeted
devices for evaluation.
7. Meet with vendors to identify and choose
devices to test.
8. Pilot-test devices for impact on patients and health
care workers.
9. Select device to replace targeted device.
10.
Educate and train all staff who will be using the new engineered device.
11. Replace existing device with new device following training.
12. Collect data after engineered device is in use, at periodic
intervals, to evaluate its impact on worker injury and patient safety.
TAILORED PROGRAMS
The revised OSHA directive mandates that
hospitals and health systems develop a comprehensive sharps injury prevention
program, but allows each facility to tailor a plan for their particular patient
and employee populations. We believe this flexibility is essential.
The
National Institute for Occupational Safety and Health (NIOSH) at the CDC agrees
with this approach. Each health care facility has a unique physical layout and
employee population as well as a unique patient population that might require a
higher frequency of invasive procedures and a variable level of care. The
engineered devices that are effective for patients and employees in one hospital
may not be for those in another.Within the seven hospitals operated by Detroit
Medical Center, we use a variety of lancets with engineered protections. But the
model that works on our trauma floor is not suitable for patients in our
pediatric unit - the lancet used in adults gives a puncture that is too deep for
a child or infant. We believe it is important for every hospital to determine
what works best for their patients and their caregivers.
Hospitals
continually reassess their sharps injury prevention programs. We look at all of
our engineering controls, including new devices. We ask ourselves whether the
newest device on the market is good for our patients and good for health care
workers. We continually examine the safety and applicability of products and
procedures, as part of our commitment to protecting our patients and health care
workers.
At the Detroit Medical Center, we have had a sharps injury
prevention program in place since 1989 - more than two years before the
Bloodborne Pathogens Standard was published. Our program covers all seven of our
facilities. Each facility has a slightly different plan and may look at
different devices, depending on the patient population, employee population and
procedures performed.
Our sharps injury prevention committee is
comprised of health care professionals, at least 50 percent of whom are
frontline health care workers. We meet at least monthly. Committee members
include physicians, nurses, and representatives from infection control,
education, safety, purchasing and administration. We look at all the products
available, select two or three based on NIOSH recommendations and the needs of
ourpatients and employees, and conduct limited trials at all sites. During the
limited trials, we closely monitor and collect evaluations from health care
workers who are testing the device to determine if the device is easy to use,
what training may be necessary for its proper use, and ensure that the device is
effective for patients and health care workers.
Based upon the
evaluations, our committee will select the appropriate devices to implement
throughout a facility, and conduct intensive training sessions for employees on
the correct use, disposal and handling of the device. We have found that,
including the educational component, it takes a minimum of six months to fully
implement the use of a device. CDC has stated that it may take up to two years.
After the device is employed in the clinical setting, we continue to
monitor its effectiveness. Two to three months after implementation, we provide
additional training sessions for health care workers, since they may find the
device heavier or larger than the previous one or more difficult to manipulate.
Ongoing educational and training sessions are held as needed.
As
established in the Bloodborne Pathogens Standard, our health care workers
participate in annual competencies, which are comprehensive overviews of our
entire sharps injury prevention program, and bloodborne pathogens education. In
addition to this annual education program, we conduct continual evaluation and
monitoring every time a task, procedure or device is changed within our hospital
system. It ensures safety for our patients and safety for our health care
workers.
CONCLUSION
Detroit Medical Center and its practices are
just one example of what hospitals across the country are doing to ensure the
safety of their patients and health care workers. The current OSHA standards -
the original 1992 standard and its 1999 revised compliance directive - mandate
the critical elements which must be included in sharps injury prevention
programs while leaving the specifics of implementation to health care
professionals.
END
LOAD-DATE: June 23, 2000
