It’s Your Call November 2016

OSHA: Labels, Red Bags & Warnings

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Have you ever wondered if you were labeling appropriately? It can be confusing but here are some pointers from OSHA.

On one of OSHA’s fact sheets says labels and signs are used to communicate hazards. Warning labels must be affixed to containers of regulated waste; containers of contaminated reusable sharps; refrigerators and freezers containing blood or other potentially infectious materials (OPIM); other containers used to store, transport, or ship blood or OPIM; contaminated equipment that is being shipped or serviced; and bags or containers of contaminated laundry, except as provided in the standard. Facilities may use red bags or red containers instead of labels. In HIV and HBV research laboratories and production facilities, signs must be posted at all access doors when OPIM or infected animals are present in the work area or containment module.

https://www.osha.gov/OshDoc/data_BloodborneFacts/bbfact01.html

HIPAA: Contingency Planning

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Natural disasters, cyberattacks, and power failures are the last things anyone would ever want to experience. Are you a planner?  How does your facility plan for potential threats?

HIPAA officers get familiar with the term Contingency Plan because having one is a requirement of the Security Rule. Regulation 45 CFR 164.308 offers the following standard for a contingency plan: (7) (i) Establish (and implement as needed) policies and procedures for responding to an emergency or other occurrence (for example, fire, vandalism, system failure, and natural disaster) that damages systems that contain electronic protected health information (PHI). In order to deliver care safely a facility must ensure the confidentiality, integrity and availability of protected health information. Having a completed Contingency Plan in place provides the directions you will need if ever faced with responding to an emergency which in some way impacts PHI. More specific information can be found on HHS webpage, and it is best to start planning sooner rather than later.