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What’s with the ascendance of EC.02.02.01, the management of hazardous materials and wastes?

Hospital Safety Insider, April 12, 2018

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Editor's note: This was originally published on Steve MacArthur's blog, Mac's Safety Space.

And you may ask yourself, well, how did I get here?

As is sometimes the case, I like to respond to questions from the “studio” audience and last week I received a question from the field that I think is worth a few inches of verbiage here. The question, as luck would have it, relates to the ascendancy of EC.02.02.01 (with 63% of the hospitals being surveyed taking hits), the management of hazardous materials and wastes.

While it may seem a little incongruous, with a side order of daunting, I think that the primary reason for the ascendance of EC.02.02.01 is that there are any number of things that can generate findings, particularly from the clinical surveyors (not that the LS surveyor couldn’t find stuff, but from what I’ve seen in recent survey reports, a lot of the HazMat findings are being generated during “regular” tracers). So, in no particular order:

• emergency eyewash equipment (availability/accessibility/documentation of testing & maintenance)
• availability and use of personal protective equipment (PPE) in accordance with product Safety Data Sheets (SDS)
• management of hazardous energy sources, particularly as it relates to managing lead PPE
• labeling of secondary containers
• management of hazardous gases and vapors (particularly as a function of ventilation, but also monitoring if you happen to have folks still using glutaraldehyde and/or cadmium-based products)
• ensuring appropriate staff education is in place, particularly Department of Transportation education for staff signing manifests
• with the odd issue relating to staff being able to competently access SDS

We’ve certainly spent our fair share of time talking about eyewash equipment (surveyors are as prone to over-interpretation as anyone, so you better have a clearly articulated risk assessment in your back pocket), and, interestingly enough, on May 31 (my birthday!), the folks at HCPro are hosting a webinar on the evergreen topic of eyewash stations, so you may want to give that look-see (listen-hear?).

I think the stuff surveyors are kicking folks on is pretty straightforward. I mean, just think about unlabeled or inappropriately labeled secondary containers — what’s the likelihood that you’ve got one out there somewhere in your organization? An unlabeled spray bottle; a biohazard container for which the label was washed off — lots of opportunities for the process to come up short.

At any rate, the list above is representative of what I’ve seen (in consulting practice and in actual survey reports). Anybody have any other potential findings that they’ve seen?

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