According to statistics published by the U.S. Occupational Safety and Health Administration (OSHA), for fines imposed in 2006 and 2007, failure to properly manage asbestos in healthcare facilities generated the highest fines per violation. Over $8,000 per violation or citation was issued by OSHA to general medical and surgical hospitals. By comparison, violations of the Bloodborne Pathogens standard generated only an average of $600 per citation; despite the fact that the Bloodborne Pathogen standard was the standard cited most often during an OSHA inspection of hospitals.
While there is no clear reason why asbestos management presents such a regulatory risk to hospitals, Bryan Connors, M.S., C.I.H., H.E.M., EH&E’s Healthcare Practice Leader, is not surprised by this finding. “It may be a combination of aging infrastructures, an increase in building and renovation activities in hospitals to meet the evolving demands of modern healthcare, and a lack of recognition that hospitals are a very complex, dynamic environment with both new and traditional safety and health concerns.” Mr. Connors has spent ten years working inside healthcare institutions and providing environmental health and safety (EH&S) services to a variety of healthcare clients. According to
Mr. Connors, “The big risks and exposures are generally recognized and well-managed, as is usually the case with Bloodborne Pathogens. However, some of the risks or exposures traditionally associated with more industrial environments (e.g., asbestos, fall protection, lockout/tag out, electrical safety, etc.) are not well characterized, and consequently are inadequately or improperly managed.”
Mr. Connors’s observations are supported by OSHA’s inspection data. Some of the other high-fine generating citations included the following OSHA categories; formaldehyde, lead, flammable and combustible liquids, hazardous waste and emergency response, and electrical wiring.
Asbestos is a highly regulated material, making it a natural target for any regulatory inspection or audit. It was also the “material of choice” for many building components prior to the 1970s, making it a ubiquitous hazardous material in many healthcare institutions. The OSHA standard for asbestos clearly establishes a number of requirements that a building owner/operator must comply with, including:
• Hazard Communications
• Working training
• Exposure monitoring and determinations
• Exposure control program
• Asbestos inventory program
• Respiratory protection
• Hygiene and personal protective equipment
• Labeling and signage
• Medical monitoring and surveillance
• Documentation and recordkeeping
Each of these areas contains very specific responsibilities that must be met, the level of effort required to comply varies significantly, and depends upon a number of factors. The U.S. Environmental Protection Agency and many individual states also regulate asbestos and asbestos-containing materials, that in combination with the OSHA requirements, can create a significant EH&S challenge for most healthcare institutions. In EH&E’s experience, well–managed asbestos management programs clearly define roles and responsibilities, and establish processes for routine (e.g., annual) audits to ensure regulatory compliance and program effectiveness. The fundamental goals of an asbestos management program are to:
• Ensure the health and safety of patients, staff, visitors, contractors, and vendors
• Minimize disruption to operations and renovation/construction activities
• Maintain compliance with occupational and environmental regulations
EH&E specializes in helping healthcare institutions efficiently manage their EH&S risks and exposures. EH&E’s asbestos management self-assessment form is available for download on our website at: http://www.eheinc.com/mark_health_hazard_asbestoscklist.htm. If you would like further information on how to ensure that your asbestos program complies with the strict EH&S requirements of the federal government, please contact Bryan Connors at Bconnors@eheinc.com or visit our website at: http://www.eheinc.com/mark_health_hazard_asbestos.htm.