Food and drink in the clinic: Where can staff have lunch?


May 1, 2019

There are many rules and regulations that the average safety officer must adhere to on a daily basis. If you work in a medical clinic, you’re used to the OSHA regulations that govern the way you do business, treat patients, deal with hazardous chemicals, and protect your employees from bloodborne pathogens. If your facility is connected to a healthcare system with hospitals, The Joint Commission (TJC) also has a say in how you do things.

It’s time to add a new requirement to your list. Apparently, there have been lots of questions from the field about spaces where clinicians and staff can consume or store food and drink, leading to a clarification from TJC about where it’s appropriate for healthcare workers to eat their lunch.

The safety of consuming food and drink in the medical clinic and laboratory is governed by OSHA’s Bloodborne Pathogens and Sanitation standards, and TJC wants hospitals and clinics to know it’s ready to enforce those standards.

“Joint Commission standards do not specifically address where staff can have food or drink in work areas, including nursing and physician stations,” according to a TJC written statement. “Instead, Joint Commission Leadership (LD) Standard LD.04.01.01 requires that health care organizations follow licensure requirements, laws, and regulations, including OSHA’s Bloodborne Pathogens Standard.”

Specifically, TJC said, OSHA’s regulation prohibits the consumption of food and drink in areas where work involving exposure or potential exposure to blood or other potentially infectious or toxic material exists, or where the potential for contamination of work surfaces exists.

It probably seems like a no-brainer: no food in areas where it could come in contact with blood or other biologically hazardous material. But for extra clarity, TJC stressed that OSHA’s regulation also prohibits consuming or storing food in areas where blood or other potentially infectious or toxic materials are located or stored, including the following areas:

  • Refrigerators
  • Cabinets
  • Shelves
  • Counters

Of course, OSHA and TJC like to keep the compliance onus on employers, so as part of the clarification, TJC pointed out that healthcare organizations can define and establish safe eating areas for staff members.

“OSHA does require that health care organizations evaluate the workplace to determine locations where potential contamination may occur and prohibit employees from eating or drinking in those areas,” the statement said. “An employer’s evaluation will determine what areas represent the risks for contamination from food and drinks. Based on this assessment, organizations can designate a safe space for staff to eat or drink.”

TJC asked healthcare organizations to use common sense when choosing places appropriate for employee meals and storage of food. For example, a clinic may determine that a particular nurse’s station is separated from work areas that are subject to contamination, making occupational exposure at that station unlikely; therefore, it would be reasonable to allow nurses to eat there, even if eating is prohibited at other nurse’s stations.

Conversely, some areas will be strictly off limits to food and drink containers. For example, it should be common sense that staff may not eat in any area where specimens are collected, processed, or stored.
“Keep in mind that while OSHA regulations apply to all health care facilities, states and local health departments may have additional requirements that health care organizations must comply with,” the statement said.

Commonsense advice

If TJC has felt a need to clarify where staff can eat their lunch, there’s obviously a need for training—both for safety officers and those who work under them. Note the following:

The standards don’t just apply to food. If an area presents any possibility of contaminated blood or other substances coming into contact with living human tissue, all consumable items, not just food, need to be kept away from that area; however, some employees still haven’t gotten that message. Even though the standard may not make mention of specific exceptions, people working in these environments need to use common sense.

“The Bloodborne Pathogens Standard clearly states that no food or drink should be inside the lab, but it makes no mention of gum chewing,” says Dan Scungio, MT(ASCP), SLS, laboratory safety officer for Sentara Healthcare, a multihospital system in Virginia and otherwise known as “Dan, the Lab Safety Man.” Scungio, as a lab professional, has seen employees try to skirt the OSHA rules in every imaginable way. Likewise, the standard “specifically states not to use lip balm or manipulate contact lenses in the lab, but there is nothing stating not to use a cell phone.”

That doesn’t mean employees can blow bubbles or text with impunity, Scungio stresses; it’s not just about the cases the rules spell out. “Remember, one of the purposes of this standard is to minimize or prevent hand-to-face contact in a contaminated setting. It is clearly a best practice for many reasons not to chew gum or use a cell phone in a lab, but OSHA would view these practices as a violation of regulations even though it is not written directly. You can tell an OSHA inspector you put that gum in your mouth in the break room, but you couldn’t prove it, and it does not make chewing it in the lab acceptable.”

Don’t store food next to blood specimens. This seems like common sense, but OSHA and TJC inspectors/surveyors still find refrigerators that contain staff members’ lunches stored right next to potentially hazardous blood samples. This is a huge no-no, and even if your staff member doesn’t get sick, your facility will likely get written up and fined.

 “In addition to contamination of the food itself, one must consider that food and beverage containers may also become contaminated, resulting in unsuspected contamination of the hands,” OSHA said in a written statement. “Food and drink may be contaminated by such processes as the leakage or spillage of specimen containers, or the performance of activities that could generate splashes, sprays, or droplets of blood or other potentially infectious materials.”

You make the food rules. OSHA makes it clear that the onus is on the employer to determine where workers can and can’t eat. In other words, don’t wait for an OSHA inspector to find a violation and correct it for you—you’ll still get dinged.

Like most situations with OSHA, it’s better to make a good-intentioned attempt to learn and follow the rules than to not try at all. If you haven’t already, it’s time to set aside a designated room or area in your facility, free of any possibility of contamination, where employees can eat safely.

Remember that OSHA allows for individual locations to be deemed safe for food, even if other locations of the same type are deemed unsafe (as in the previous example of the nurse’s station). It also allows employers to enact requirements that are more stringent than OSHA’s standards.

Teach workers a lesson. Sometimes people have to have things waved in their face to get the message across—especially if they already think they’re doing the best job they can. This logic can apply to healthcare and lab workers who think they are complying with guidelines for hand washing, disinfecting surfaces, and wearing gloves.

Pamela Dembski Hart, BS, MT(ASCP), CHSP, principal of Healthcare Accreditation Resources, LLC, and a lab safety consultant in Plymouth, Massachusetts, likes to teach medical clinic staff lessons by using Glo Germ™ powder, which glows in the dark under ultraviolet light, to show them how dirty surfaces can get and how germs can travel. Not only is this a cool trick, it might keep your clinical staff from ever eating their lunch in a “dirty” place again.

Put the powder down on surfaces without your staff’s knowledge and let them go about their daily activities, including breaking for lunch and making phone calls. Later, ask them if they used proper PPE, wore their gloves, and washed their hands often. They’ll probably say yes, and that’s when you can light up their hands and various surfaces with a blue light (readily available for purchase online) to show them where they’ve been and how they’ve picked up the powder from touching different surfaces. The intent is not to catch staff in a lie, but to show them how important it is to practice proper sanitation—and how easy it is to inadvertently fall short.

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