Innovative pharmacists have taken immunizations, including the influenza vaccine, to off-site clinics located at employer sites, churches, malls, and various other community locations, with the intent to keep people healthy during the annual flu season rather than having them experience extended illnesses and loss of productivity.
The CDC published the startling fact that “flu in the workplace costs US businesses approximately $10.4 billion each season.”1 Employers consistently look for programs to mitigate the impact influenza has on productivity in the workplace. Innovative pharmacists have taken immunizations, including the influenza vaccine, to off-site clinics located at employer sites, churches, malls, and various other community locations, with the intent to keep people healthy during the annual flu season, rather than having them experience extended illnesses and loss of productivity.
Not only is it important to follow state and federal regulations regarding vaccine administration, once a pharmacist has completed an off-site clinic, there are often questions regarding regulations surrounding the transport of full sharps containers. These regulations are as important as other considerations, such as insurance and billing, and include those from the Occupational Safety and Health Administration (OSHA), individual states, and the Department of Transportation (DOT).
COMPLYING WITH OSHA AND STATE REGULATIONS
Immunizers must comply with OSHA’s Bloodborne Pathogens Standard, as well as individual state rules on medical waste management,2,3 whether inside the pharmacy or at an off-site clinic. Pharmacists should be clear on sharps safety, the use of safety syringes, and disposal of syringes immediately after injection. In addition, there are a few disposal considerations that are important for immunizing pharmacists to remember:
COMPLYING WITH THE DOT
Pharmacists transporting full, or partially full, sharps containers between the pharmacy and the site of the vaccination clinic must comply with the DOT Materials of Trade (MOT) Exception4, which applies to all states. The MOT Exception allows pharmacists to transport sharps in a sharps container, as a part of doing business, without having to register with the state as a medical waste transporter. There are requirements that must be followed:
COMPLYING WITH TRAINING REQUIREMENTS
Prior to participating in an off-site clinic, the pharmacist should have documentation of his/her annual bloodborne pathogens and sharps safety training1; medical waste management plan training, if required by the state2; DOT hazmat training as prescribed in 49 CFR Part 172, Subpart H6; and training on any applicable organization policies and procedures. For more information on the federal and state trainings needed for specific waste disposal programs, pharmacies can contact their medical waste disposal companies.
In addition to pharmacists providing immunizations inside of pharmacies, their participation in off-site clinics provides a valuable and convenient service to communities and employers. Complying with state and federal regulations that govern the transportation of full sharps containers generated at these clinics is a public safety and risk management responsibility.
1. Make it your business to fight the flu. CDC website. cdc.gov/flu/pdf/business/ toolkit_seasonal_flu_for_businesses_and_employers.pdf. Accessed June 20, 2017.
2. Bloodborne pathogens and needlestick prevention. Federal Occupational Safety and Health Administration website. osha.gov/SLTC/bloodbornepathogens/index. html. Accessed June 20, 2017.
3. State regulatory map—medical waste. Sharps Compliance website. sharpsinc. com/regulatory-compliance. Accessed June 20, 2017.
4. Materials of trade exceptions, 49 CFR § 173.6 (2016). Government Printing Office website. gpo.gov/fdsys/pkg/CFR-2016-title49-vol2/xml/CFR-2016-title49- vol2-sec173-6.xml. Accessed June 20, 2017.
5. Medical Waste Management Act. California Department of Public Health website. archive.cdph.ca.gov/certlic/medicalwaste/Documents/MedicalWaste/2013/ MedicalWasteManagementAct.pdf. Accessed June 20, 2017.
6. Hazardous materials transportation training requirements. U.S. Department of Transportation website. phmsa.dot.gov/staticfiles/PHMSA/Hazmat/digipak/pdfs/ presentation/Training_Requirements(04_07).pdf. Accessed July 18, 2017.
Jan Harris, MPH, BSDH, is the director of environmental health and safety at Sharps Compliance, Inc.Robin Watson, MPH, MS, is the director of client services at Sharps Compliance, Inc.Wanda Lingner, RN, BSN, is a clinical specialist of strategic regulatory customer compliance at Sharps Compliance, Inc.