After your practice has gained an understanding of the USP <800> standard and assessed your risk, the next step to creating a safer workspace is to develop an action plan. Your action plan should include these four key components:
- Policy and procedure
- Orientation and training
- On-going monitoring
Although much emphasis is placed on the facility aspect because of the potential structural changes required and their associated costs, your action plan should involve more than just physical upgrades to the office itself. Each of these aspects is equally critical for creating a safe working environment.
Facility - Facility requirements for USP <800> compliance include negative pressure, air changes, and venting the “mixing hood” to the roof of the building. These building upgrades require collaboration between building managers, HVAC professionals, architects and your finance team. Be sure that all parties understand the requirements for both USP <800> and USP<797> standards, and that they’re vested in helping you become compliant without breaking your budget. While a well-contained mixing area is necessary, an additional clean room, ante room and buffer room may not be. Note that while USP<800> standards apply to all physician offices where hazardous materials are being mixed and administered, USP<797> only applies in certain cases.
Policy and Procedures – Are your processes for receiving, unpacking, handling, mixing, transferring, administering and managing waste resulting from hazardous materials documented? Are these processes being followed and enforced? In many cases, practices already have procedures that comply with USP <800> standards in place, such as wearing gloves when unpacking chemotherapy medications and using needleless systems to prevent exposure in the treatment room, though they may not be in writing. Be sure that your policies and procedures are documented, up-to-date and accurately reflect how current day-to-day activities are performed.
Education and training – Once written policies and procedures are in place, the next critical step is communicating them to your staff so that they are aware of them and understand them. New employee orientation sessions are an excellent opportunity to educate staff members on areas where exposure to hazardous materials may occur and the procedures that have been put in place to help minimize exposure. For those who will be mixing and administering hazardous materials, special training will be needed, including but not limited to certification, re-certification and procedural checklists. Training schedules and re-certification procedures must be clearly outlined. Opportunities for continuing education through regular in-service training in both general and specific areas should be encouraged.
On-going monitoring – Whatever is measured can be improved upon, so on-going monitoring is critical to make sure standards continue to be upheld. This may include regular observation of those mixing chemotherapy, surface testing, and baseline testing of employees that are at high risk for exposure. Encourage employees to obtain baseline physical exams with their primary care physicians, inform their healthcare providers about their work environment, and obtain follow up exams in the event of exposure, to help them stay healthy and informed.