Medical Environment Update: Eyewashes, bleach protocols, and proper footwear

Hospital Safety Insider, October 20, 2016

Want to receive articles like this one in your inbox? Subscribe to Hospital Safety Insider!

Editor's note: We get a lot of comments from safety professionals just like you looking for answers to everyday questions, and every so often we print some of our favorite questions for your reference. We will do the best we can to get you the right answers as soon as possible from our OSHA experts. To submit a question, feel free to email Managing Editor John Palmer at, or check out the OSHA Healthcare Advisor blog at
Q: Are we required to have a contract with a medical waste disposal provider for our physician practice? We have virtually no waste, and I want to either be on a "will call" basis or place our practice waste in with our surgery center waste for disposal. The surgery center has a contract and waste is picked up every week. Both entities share common ownership. It just makes sense to save money and not have a service that we do not use enough to justify the annual expense.

 Dan Scungio: While there is no requirement to have a contract to remove medical waste, the site is responsible for that waste in the eyes of the EPA from generation to final disposal. It might work to send the waste to the surgery center, but it will be important to know the volume of waste generated by the office itself (if it's at a separate address). Keeping waste manifests is the best way to keep track of this.

 Q: I work at an endoscopy ambulatory care center and work as the infection control professional. I am having a difficult time finding answers about the exposure time for 10% bleach solutions to clean items such as eyewash caps at our eyewash station. The ­OSHA book says to follow local state guidelines through the EPA for exposure time. The EPA for our state had no idea and referred me back to the local health department, and they were not sure. No one seems to be able to direct me, and I have looked at multiple sites with no answers. Could you help direct me, please? Also, at the eyewash station, how do we measure the gallons per minute ratio?

 Marge McFarlane: Ten percent bleach is just one way to disinfect the eyewash station covers. It is not a requirement, just a suggestion. Since one would not expect the covers to be contaminated with blood and body fluids, a few minutes may be adequate. This was a statement from the original edition of the manual. The industry trend is to clean everything according to the manufacturer's recommendations. They may want to review the literature of their brand" for directions.

Read more here.

Healthcare Life Safety Compliance: Combustible decorations, stairwell treads, and temporary construction barriers

Teaser: Each month, Brad Keyes, CHSP, owner of Keyes Life Safety Compliance, answers your questions about life safety compliance. Our editorial advisory board also reviews the Q&A column. Follow Keyes' blog on life safety at for up-to-date information.

Q: In regards to the new CMS requirements regarding corridor projections, will alcohol-based hand-rub (ABHR) dispensers have to comply? Currently, our ABHR dispensers exceed the 4-inch limit for items projecting into the corridor. Will there be any equivalency permitted for this requirement?

A: CMS said in its final rule to adopt the 2012 Life Safety Code(r) (LSC) (issued May 4, 2016) that it will enforce the 4-inch projection rule rather than the 6-inch rule that NFPA permits. CMS takes this more restrictive requirement from the ADA requirements but the problem is, ADA applies to new construction and is not retroactive to existing conditions. CMS did not clarify that its 4-inch corridor projection rule is only for new construction, so it appears to me that CMS intends to enforce it in all situations... new and existing. It remains unclear whether the accreditation organizations will enforce this. They should, because if they don't and the hospital has a validation survey and is cited by the state agency for violating the 4-inch projection rule, then that will eventually reflect poorly on the accreditation organization. But with surveyors being the humans that they are, it is unclear if they will enforce this or not. While I do not recommend it, you can take a "wait-and-see" approach to determine whether you get cited for it. You will eventually, because CMS will enforce it. So I suggest you take action to eliminate those dispensers and look for new ones that do not extend more than 4 inches. There is no equivalency for this issue. I would think a waiver would not be approved for such a minor issue either.

Read more here.

Want to receive articles like this one in your inbox? Subscribe to Hospital Safety Insider!

    Hospital Safety Center
  • Hospital Safety Center

    Improve compliance with hospital safety standards from The Joint Commission, OSHA, and other regulators with this...

  • Healthcare Life Safety Compliance

    Created exclusively for healthcare facility managers, plant operations professionals, and directors of engineering, this...

  • Hospital Safety Insider

    Stay on top of hospital safety requirements and best practices with our free, fast-paced weekly update.

  • Basic OSHA Compliance Manual Kit

    Total compliance has never been easier. This one convenient package contains everything you need to ensure your outpatient...

  • Basic Dental OSHA Compliance Manual Kit

    Total compliance has never been easier. This one convenient package contains everything you need to ensure your dental...

Most Popular