Compliance Perspectives

How to Create an Enhanced Cleaning and Disinfection Policy

In the age of COVID-19, complying with the rigorous hygiene requirements CLIA, accreditation criteria, OSHA and other standards may not be enough. That’s because the U.S. Centers for Disease Control and Prevention (CDC) and public health guidelines mandate that work facilities still in operation undertake special enhanced cleaning and disinfection measures. This is particularly true of lab and other healthcare diagnostic and treatment sites. Here are the rules and how to comply. There’s also a Model Policy on this website that you can adapt for use at your own lab.

What’s at Stake

SARS-CoV-2, the virus that causes coronavirus, spreads by human-to-human contact and can live on a surface or object for up to seven days. The virus can be killed but it takes the right products and procedures. That’s why public health agencies are requiring employers to implement special cleaning and disinfection procedures as part of their workplace COVID-19 exposure control plan. In addition to putting workers and others present at your facility at greater risk of infection, failure to comply exposes your lab to the risk of OSHA penalties, loss of CLIA accreditation and even partial or full shut down.

Of course, the duty to maintain a clean and sanitary workplace is nothing new. But the COVID-19 public health guidelines go well beyond the normal standards. They require not just regular but frequent and special cleaning and disinfection measures to ensure the virus isn’t allowed to linger on workplace surfaces, door knobs and other frequently touched objects. More precisely, they require employers to create and implement specific cleaning and disinfection procedures for all parts of the workplace, including lab-owned vehicles. The best way to comply is to create a policy that provides for at least the following six things:

  1. Workplace Cleaning and Disinfection Assessment

First, designate a competent person to carry out an assessment of all the areas in your workplace that may contain COVID transmission points. While not expressly required, if your lab has a workplace joint health and safety committee (JHSC) or health and safety representative, it’s best practice to enlist it/him/her to participate in the assessment. In the policy, identify the tasks of the assessment, including:

  • Identifying all surfaces and objects requiring just routine cleaning;
  • Identifying surfaces and objects also requiring disinfection;
  • Determining how often the particular surface or object needs to be cleaned and disinfected;
  • Determining which materials to use for cleaning and disinfection;
  • Listing the health and safety measures needed for each particular cleaning and disinfection operation; and
  • Listing personal protective equipment (PPE) necessary for each particular cleaning and disinfection operation.

2. Transformation of Assessment into Cleaning and Disinfection Schedule

The next step is to use the data from the assessment to create a schedule for cleaning and disinfection, which can be either: i. a central plan created by your OHS or safety director for the entire facility, or ii. a set of separate plans for each department created by each department head. In either case, have the person creating the plan systematically listing for each space or area:

  • The specific objects and surfaces it contains;
  • How frequently those objects and surfaces will be cleaned and, if necessary, disinfected; and
  • Who’ll be responsible for carrying out those cleaning and disinfection operations.

3. General Cleaning Procedures Guidelines

The person who creates the schedule should also establish a cleaning and disinfecting procedure for each item on the schedule. While specifics will vary, in general, cleaning should be performed before disinfection in a well-ventilated area by a properly trained person following manufacturers’ instructions with regard to concentration/dilution, required PPE and application methods.

4. General Ground Rules for Materials Used

Most routine cleaning operations can be carried out with soap and water. Disinfectants should be used only if they’re approved for use against coronavirus (SARS-CoV-2) infection. However, safe alternative disinfectants are okay to use if such products aren’t available, such as a mixture of one-third cup of 5.25 percent to 8.25 percent bleach added to one gallon of water, or 70 percent alcohol solutions. But ban mixing bleach together with other cleaning and disinfection products because the mix may emit hazardous fumes.

5. Separate Guidelines for Cleaning of Soft (Porous) Surfaces

Procedures for soft (porous) surfaces such as carpeted floor, rugs, and fabric chairs, should provide for removal of any visible contamination present and then cleaning with appropriate cleaners indicated as being safe for use on those surfaces. Those items should be laundered after cleaning using the warmest appropriate water setting in accordance with the manufacturer’s instructions and then completely dried. If laundering isn’t possible, be sure to use a disinfectant approved for use against SARS-CoV-2.

6. Required PPE

Cleaning and disinfection procedures should specify the PPE required to perform the operation safely. In general, that should include:

  • Disposable gloves—once the procedure is over, users must immediately discard their gloves and wash their hands;
  • Eye protection where there’s a risk of splash or splatter to the face; and
  • Gowns or aprons for larger scale or frequent cleaning.
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