MATTHEW L. BERKHEISER, DrPH, CIH, CSP, CHPCP, is associate vice president for environmental health and safety, sustainability, and emergency management at MD Anderson.
LINETTE LEADON, MS, CIH, CSP, SM (NRCM), is director of environmental health and safety, sustainability, and emergency management at MD Anderson.
CHAVAUN LEBLANC, MS, CSP, CHSP, is manager of laboratory safety at MD Anderson.
MARIVONNE RODRIGUEZ, MS, CBSP, is a laboratory safety specialist at MD Anderson.
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An Eye on Risk
Install more eyewashes. This was one request stemming from a practice inspection in preparation for a future accreditation survey of our workplace, The University of Texas MD Anderson Cancer Center in Houston. Eyewashes are a common feature of facilities such as ours, where our teams conduct innovative cancer research and care for patients with cancer, often using chemotherapy.
Instinctively, we questioned the need for more eyewashes. For a workplace of our size, with more than 23,000 employees, we have relatively few eye incidents related to chemical exposures—just 5.8 per year over the last five years. We provide our employees personal protective equipment, and we use enclosed systems to contain chemotherapy agents during preparation, delivery, and administration to reduce the risk of exposure. However, there are occasional leaks, and a few drops can escape during the process.
THE REAL FAILURE We recognize that eyewashes are important. Our resistance to installing more eyewashes was informed by the fact that they help mitigate accidents but cannot prevent them. They also can contribute to a false sense of security. For example, one may adopt the attitude that if you get something in your eye, you’ll just use the eyewash to rinse it out. Relying on eyewashes obscures the real failure of not using eye protection to avoid exposure to the eye in the first place.
Eye protection is much better than it used to be and, when worn properly, there is less need for eyewashes. But employees’ resistance to wearing eye protection, or their inability to remember to wear it, is a challenge for managers and OEHS professionals. It is easier to install eyewashes than to change the culture.
It is easier to install eyewashes than to change the culture.
EVALUATING THE NEED We can’t deny that the absence of an eyewash is a compliance or employee exposure risk, especially if hazardous agents are used in the area. But we wanted to be good stewards of resources and verify the need for additional eyewashes. To address the request, we had a few options:
1. Install an eyewash in every unit.
2. Evaluate every location where caustic or corrosive materials might be used and determine whether an eyewash is located within the required distance.
3. Respond that our assessment indicates we have enough eyewashes.
4. Evaluate our inventory to verify the materials are caustic.
We chose the fourth option. First, we set out to determine if we had chemotherapy agents that met the regulatory definitions of corrosive or caustic (chemicals with a pH less than 2.0 or greater than 11.5, respectively). Our team reviewed our inventory of 761 therapeutic and injectable agents.
We discovered that most of the chemotherapy agents—which are mixed in a pharmacy, transported to a clinical area, and delivered through a closed system to the patient—are diluted at their point of origin in our facilities, rendering them neither corrosive nor caustic. Of the agents that are not diluted, only seven—one percent of our inventory—had literature sources indicating a pH of 2.0 or less, or 11 or greater. In addition, use of these seven agents is rare and requires approval, increasing our layers of protection by adding an administrative safety process ahead of use that eliminates the need for more eyewashes in our facilities.
The takeaway from this scenario is to spend time evaluating the need for your OEHS interventions. Ask yourself what you can do now to safeguard resources for new programs that are right around the corner. You may find ways to improve existing programs, enhance implementation of future programs, or conserve resources for other needs.