On September 10, 2004, GE Healthcare brought together a panel of radiology administrators, imaging technologists, and catheterization laboratory nurses to address issues related to new and existing guidelines for the health care workplace and how they relate to the handling of contrast material. The participants shared their experiences in compliance with such regulations, and their presentations are summarized in this supplement to Decisions in Axis Imaging News.

This group was convened not only to share expertise concerning the use of new polymer bottles in regulatory compliance, but to help inform radiology and catheterization laboratory personnel of the safety factors related to the choice of packaging for contrast media. The group found that polymer contrast bottles are superior to glass particularly because they are unbreakable (eliminating the risk of cuts and other potential employee exposures) and lighter (reducing the chance of musculoskeletal injuries). The panel also noted additional benefits associated with the use of polymer bottles, including improvements in employee satisfaction, enhanced efficiency, increased value through savings in disposal cost, reduced contrast waste, and easier compliance with regulatory and accreditation-related requirements.

Critical occupational safety and health concerns include minimizing employee exposure to hazards, reducing Worker’s Compensation costs, and decreasing liability. Employee exposures to the risk of sharp injuries, ergonomic hazards, and where applicable probably hazardous substances, increase an institution’s costs and liability, so minimizing exposure is vital. There are, of course, many patient-safety issues involved in the use of glass packaging for contrast media, but this panel focused on the issues related to employee safety.

There are a number of governmental agencies and standards-making organizations that play a role in occupational safety and health for health care. The US Occupational Safety and Health Administration (OSHA), in operation since 1970, began to focus much more intensively on the health care industry in the early 1990s. But many older standards originally designed for heavy industry (or even construction) are still being applied to health care. Civil and criminal enforcement of OSHA standards, whether specific to health care or not, is increasingly rigorous.

There is also federal-state interplay in occupational health because OSHA, at the federal level, has 24 counterparts at the state level. This adds to the complexity of regulatory compliance for radiology providers in those 24 states.

The National Institute for Occupational Safety and Health (NIOSH), the research and educational arm of OSHA, often helps OSHA develop or explain regulation in unfamiliar areas. NIOSH has proceeded with that mission, and has a legislative mandate to engage in additional investigation and quasi-regulatory activity. NIOSH now develops guidelines that become standards and sometimes even regulations, with which health care facilities must comply.

The US Centers for Disease Control and Prevention (CDC) is not an enforcement agency, but it does issue guidelines. Because the CDC has expertise in health care, OSHA often relies upon its guidelines as a model when drafting health care regulations.

The American National Standards Institute (ANSI) develops consensus standards for equipment, some of which is used in health care, but is not a regulatory body. The need to meet ANSI standards comes to hospitals through OSHA obligations and Joint Commission on Accreditation of Healthcare Organizations (JCAHO) standards. The occupational safety and health requirements of JCAHO are now being designed to match OSHA obligations more closely, which should make compliance easier.

Taking all of the agencies and organizations into account, it is clear that particularly critical standards for the health care industry concern blood-borne pathogens, hazard communication, and ergonomics. The regulations covering blood-borne pathogens require the use of universal precautions, the use of engineering and work-practice controls that minimize employee exposures, the training of employees, and the keeping of adequate records.

For hazard communication, the applicable regulations concern material-safety data sheets (MSDS), labeling, and training. And while ergonomics regulations exist only in some states, since proposed regulations at the federal level have not yet gone into effect, a very large number of employee claims are now being made concerning ergonomic injuries. Radiologic technologists have particularly high rates of occupational musculoskeletal injury, and emergency-department, general-radiography, and mobile-radiography shifts rank as more hazardous for back and upper extremities than other assignments. Considerable physical effort may be involved in the technologist’s work, along with repetitive motions, extended-reach tasks, awkward static postures, or small-part manipulation.

OSHA is intended primarily to prevent injuries and illnesses and state Worker’s Compensation programs are designed to provide appropriate care and treatment for injured employees. The cost of Worker’s Compensation has increased so dramatically that anything that can minimize injuries is tremendously important. This is particularly significant as civil and criminal liability can be imposed as a result of occupational injuries and illnesses. And, beyond the issues of liability and cost, protecting employee safety and health is simply one of the most important responsibilities of any employer. For all of these reasons, employers must find the best possible ways to protect the safety and health of employees. Because it decreases risk in several ways and helps in regulatory compliance, the use of polymer bottle packaging for contrast media is a solid step in this direction.

Jeff Tannenbaum, JD, Nixon Peabody LLP, San Francisco, CA