1996 OPEN FORUM Abstracts
FYI: FDA, DOT, EPA, OSHA, ETC.
Allan B., Saposnick, MS, RRT Tuesday, November 5, 1996
A full assortment of federal, state and local agencies have a serious impact on how a respiratory home care service operates. Federal agencies have regulatory authority which cuts across all aspect of respiratory home care.
The Food and Drug Administration (FDA) has very specific requirements which must be followed by home medical equipment (HME) suppliers who transfill gaseous or liquid oxygen containers. The FDA requirements that must be followed relate to quality control, product testing, container inspection, record keeping, labeling, traceability and recall, and customer/user complaints.
The U.S. Department of Transportation (DOT) requires that vehicles carrying 1000 pounds of oxygen cylinders or 110 gallons of liquid oxygen must be properly placarded and marked. Drivers of such vehicles must have a commercial drivers license with a hazardous materials endorsement. The vehicle must carry specific safety equipment and follow DOT rules for driving, parking, loading and unloading. Records must be kept on accidents, inspections, maintenance and repairs. Drivers must submit to pre-employment and periodic drug testing.
The Occupational Safety and Health Administration (OSHA) requires a written exposure control plan for all employees with potential occupational exposure to bloodborne pathogens - HIV and hepatitis B and for tuberculosis. Personal protective equipment to provide universal precautions barriers must be provided. A log must be kept of certain injuries and illnesses. OSHA also has guidelines for deterring and preventing workplace violence. These pertain to home care employees who provide services in the patient's home, perhaps in unsafe or unfamiliar areas at odd hours.