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Two Ways to Correct Safety Regulation Violators

Evan Sweeney, for HealthLeaders Media, December 4, 2009

Unless they work in a medical facility with perfectly compliant employees, safety directors and infection preventionists (IP) are usually forced into the unenviable, but inevitable job of confronting a healthcare worker who is not adhering to safety and infection control regulations.

On most occasions, managers encounter an innocent mistake or a one-time offense that is easily correctable. On other occasions, persistent or especially hard-headed employees will demonstrate consistent non-compliance because of inconvenience or simply out of sheer stubbornness.

In either case, finding the right approach can often be challenging both in smaller private medical practices and in larger hospital systems. With Joint Commission standards focusing on topics, such as hand-hygiene improvement, it's imperative that managers have a documented disciplinary policy along with an effective approach for fixing non-compliance.

Two of the most common IC and safety violations are phlebotomists biting the tip of the index finger off gloves to feel for a vein, and physicians not wearing required personal protective equipment (PPE) during procedures, says Kathy Rooker, safety officer and owner of Columbus Healthcare & Safety Consultants in Canal Winchester, OH. Incision and draining procedures are the most common vehicles for ignoring PPE because physicians don't think they need the required gloves, mask, goggles, and impervious gown for such a simple procedure. However, Rooker has seen instances where pus has sprayed into the mouth or eyes of a doctor.

"I just try to tell them the consequences are if they don't wear it and is it really worth them taking the risk?" Rooker says. "I hear, 'Oh, I'm going to look ridiculous,' and I say, 'Yeah but you'll be alive.'"

Although all OSHA regulations are important from a general safety perspective, IPs should consider the risks involved with non-compliance, rather than how flagrant the foul is, says Steve MacArthur, a safety consultant at the Greely Company in Marblehead, MA.

"For instance, at the moment handwashing and wearing appropriate PPE have shifted as a function of their risk 'potential' into the realm of probability," MacArthur says. "Now there is a very real threat as opposed to what might nominally be described as theoretical threat, so the tolerance levels for non-compliance, either accidental or purposeful, are much less because inappropriate protection can impact any number of people."

Taking a tactical approach
It's rarely effective to yell and scream at a healthcare worker, or call out a physician in front of his or her peers or in front of a patient, says Rooker. Instead, it is more beneficial to either take the physician aside and explain the error, or meet with him or her individually to explain the requirement.

"I would sit down with them one-on-one, and I will usually bring with me statistics on hepatitis B, hepatitis C, and HIV and say, 'Look at the statistics. Look what could happen to you by not using a safety needle if this person were infected,'" Rooker says. "And that's a real eye-opener sometimes."

However, the conversation should not be one-sided. IPs should address the issue from the employee's perspective because there may be legitimate reasons for non-compliance, says MacArthur.

"Most people know what they are supposed to do, but if convenience gets in the way, compliance can take a window seat pretty quickly," MacArthur says. "But maybe, just maybe, there's a kernel, grain, atom of useful information there. Maybe the PPE is really not accessible enough or maybe you need to look at a different product or a different technique."

Initiating disciplinary action
There is always the possibility that a one-on-one consultation is not enough to elicit consistent compliance, or that a blatant offender will continue to ignore safety protocols. In these cases, employers will turn to their established disciplinary matrix.

Most facilities already have this in place, but with any luck, managers rarely have to initiate the process. Most corrective action procedures begin with one or two verbal warnings, then a written warning, suspension, and finally termination.

In most facilities, disciplinary action should be handled by the employee's supervisor, not necessarily the IP or safety officer. The IP may be involved with consultation, but he or she should not be the "police officer" for the entire staff.

"Safety should be a baseline competency for anyone working in the organization," MacArthur says. "It should be evaluated just like any other competency, clinical or otherwise."


Evan Sweeney is an editorial assistant at HCPro. He manages and writes for Briefings on Infection Control, a monthly newsletter directed at IC compliance. He also blogs for OSHA Healthcare Advisor, a resource center for infection control and safety professionals, and regularly contributes to Medical Environment Update and OSHA Watch, which focus on healthcare employee safety and health.

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