November, 2011

Copyright 2011 Center for Phlebotomy Education, Inc.
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OSHA Announces New Educational Materials

Clinical laboratories in search of comprehensive and user-friendly information on OSHA compliance now have new resources available. Last month, the Occupational Safety and Health Administration (OSHA) announced in an OSHA Trade News Release, the publication of new educational materials aimed at assisting laboratory managers in protecting workers from exposure to chemical, biological and physical hazards. One of the documents, Laboratory Safety Guidance, contains recommendations and well as descriptions of mandatory safety and health standards, including the Bloodborne Pathogens Standard (29 CFR 1910.1030), and the Personal Protective Equipment Standard (29 CFR 1910.132) applicable to clinical laboratories subject to Federal OSHA. Select passages from the document are highlighted below:

OSHA estimates that 5.6 million workers in healthcare and related fields are at risk for occupational exposure to bloodborne pathogens.(1) The Centers for Disease Control and Prevention notes that over 200 diseases can be transmitted via blood exposure, with the most serious infections being hepatitis B virus (HBV), hepatitis C virus (HCV), and human immunodeficiency virus (HIV).(1)

In providing a safe work environment, the “hierarchy of controls” is defined as a systematic method of addressing workplace hazards, rather than relying on employees to reduce their exposure. Measures that may be used to protect laboratory workers are ranked from most effective to least effective below:

  1. Engineering controls – involve making changes in the work environment to reduce hazards, and are not dependent on worker behavior.
  2. Administrative controls – modify worker schedules and tasks in ways that minimize exposure.
  3. Work practices – procedures that reduce the duration, frequency or intensity of exposure to a hazard.
  4. Personal protective equipment (PPE) – protective gear needed to keep employees safe while performing their jobs.

In terms of personal protective equipment, it’s important that PPE be:(1)

  • Selected based upon the hazard to the employee;
  • Properly fitted;
  • Conscientiously and properly worn;
  • Regularly maintained and replaced according to manufacturer’s specifications;
  • Properly removed to avoid contamination of self, others or the environment;
  • If reusable, properly removed, cleaned, disinfected and stored.

The symptoms of latex allergy and the employer’s responsibility to provide appropriate PPE alternatives to affected individuals are also addressed.

In addition to the Bloodborne Pathogens Standard and PPE Standard, OSHA’s Laboratory Safety Guidance document covers chemical hazards, physical hazards related to ergonomics, noise and radiation, safety hazards associated with centrifuges and autoclaves, trips, slips and falls, fire and electrical safety, and much more. The detailed Appendices provide supplemental information, listing numerous links and resources on a variety of laboratory safety topics.


  1. U.S. Department of Labor. Occupational Safety & Health Administration. Laboratory Safety Guidance. OSHA 3404-9N, 2011.  Link (pdf).  Accessed 11/2/11.

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Featured Product
Two for One To the Point™ CE Booklets

For individuals or facilities that prefer to receive their continuing education (CE) exercises by mail, the Center for Phlebotomy Education is offering two of its popular To the Point™ CE exercises in soft-cover booklets for one low price. Buy Volume 1, get Volume 2 for free. That's 6.0 CEs for $34.99 plus shipping, making To the Point™ Volumes 1 & 2 Booklets the most affordable CE available.

Volume 1, subtitled “Collection Protection,” includes a series of articles on lab coats, glove use, face and foot protection, handwashing, safe practices, exposure management, safety needles, and sharps containers. Volume 2 includes three detailed articles on preventing patient injury, blood culture collection, and specimen processing/transportation errors.

To the Point™ booklets can be used three ways: 1) as a comprehensive resource in specimen collection; 2) implemented into a facility’s in-house continuing education program; and 3) for individual use.

The To the Point™ series is the Center’s response to the specimen collection community’s demand for highly accurate and authoritative phlebotomy continuing education at a reasonable price. For more information, click here.

The Center is an approved continuing education provider for the ASCLS P.A.C.E.® program in all states including California. *To obtain P.A.C.E. ® credit, a minimum passing score of 70% is required.


Center Offers Facility-Wide P.A.C.E.® CE Credits

The Center for Phlebotomy Education, a leading provider of continuing education (CE) exercises for blood collection personnel, is making facility-wide continuing education credits available to employers looking for a turn-key solution to maintaining their staff's certification and competency.

"We know facilities struggle with keeping their staff credentialed and exposed to quality educational materials," says the Center's P.A.C.E.® coordinator Catherine Ernst, RN, PBT(ASCP). "That's why we're launching a program that streamlines continuing education for every manager. They simply distribute our material via email or intranet, instruct the staff to complete the exercise, and return their exams and evaluations to us for scoring. We send P.A.C.E.® certificates for every individual who achieves a score of 70% or better, and they're done."

For a flat fee of $10 per person per contact hour, the lowest in the industry for phlebotomy-related CE exercises, managers can put highly researched and impeccably accurate educational materials in the hands and heads of their staff without expending a lot of their valuable time. "We make it our job to take the burden off of managers when it comes to implementing continuing education," says Ernst. "And we make it affordable. A staff of 200 can get three P.A.C.E.® credits per person for $600. Best of all, they can do so with minimal effort on the part of their manager or supervisor."

The exercises are part of the Center's To the Point® CE program, and are delivered as downloads in a pdf format with instructions. Managers simply distribute the document to their staff, collect the Test Answer/Evaluation document, and ship or fax them to the Center. All forms must be submitted to the Center at the same time in order to qualify for the reduced rate.

The Center currently has three To the Point® exercises for immediate implementation, each worth from 3.0 to 6.0 continuing education credits. For more information on the content of each available exercise, visit http://www.phlebotomy.com/category/TTPDownload-PACE.cpe. To set up facility-wide CE credit, contact the Center toll free at 866-657-9857 or send an email to support@phlebotomy.com.


This Month in Phlebotomy Today

Here’s what subscribers to Phlebotomy Today, the Center for Phlebotomy Education’s paid-subscription newsletter currently in its 12th year of publication, are reading about this month:

  • Feature Article: Literature Review of Newly Published Studies and Articles: Part I
  • Phlebotomy in the News: a round-up of articles on phlebotomy and phlebotomists who made Internet headlines in October including these stories:
    • Phlebotomist Charged with Theft at DUI Center
    • Hospitals Hit with More and Higher BBP-Related Fines

    • Home Laundering of Uniforms May Not Kill Pathogens

    • Doctor Cleared of Sexual Assault During Blood Draw

    • GED, Phlebotomy Certificate Provide New Opportunities

    • Phlebotomist Indicted for Stealing from Elderly Patients

    • Delivery of Phlebotomy Services Sparks Irish Controversy

  • Safety Essentials: “But I don’t work in the lab!”
  • Tip of the Month: Defend Your “Ear-Space”
  • CE questions (institutional version only).

Buy this issue for only $9.95.

For subscription rates and to subscribe to Phlebotomy Today, click here. The current month’s issue will be emailed to you immediately upon subscribing.

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Ernst to Speak at Dark Intelligence Conference

Dennis J. Ernst MT(ASCP), Executive Director of the Center for Phlebotomy Education, will be presenting at this year's Lab Quality Confab and Process Improvement Institute in San Antonio, Texas. The event is part of The Dark Intelligence Group, Inc. and is dedicated to bringing business and management intelligence to managers and administrators of clinical diagnostic services, pathologists, radiologists, and industry executives.

Ernst will co-present "Attacking Pre-analytical's Three Biggest Sources of Error" with Patrick Maul, a Lean Six Sigma Black Belt and BD consultant. The two will discuss industry benchmarks and Lean strategies to reduce patient/sample identification errors, hemolysis rates, and blood culture contamination.

Scheduled for November 15–16, the objective of the Lab Quality Confab is to advance the knowledge, skills, and effectiveness of process improvement and quality management practitioners in diagnostic medicine. Each of the 50+ presentations at this year's event are designed to provide information, and training on process improvement and quality management methods and systems designed to advance the knowledge and skills for senior executives and administrators, managers, and quality team members.

The Dark Intelligence Group, publisher of the DARK Daily and THE DARK REPORT, also conducts the annual Executive War College on Laboratory and Pathology Management and the Molecular Summit. To register for the Lab Quality Confab and Process Improvement or for more information, visit http://www.labqualityconfab.com.


Last Month on Facebook

During the month of October, fans and visitors to our Facebook page shared their thoughts on the following topics:

  • Procedural errors committed per draw;
  • Finding difficult veins in the elderly;
  • Appropriate use of butterfly needles.

Looking for an online community to post questions or to simply satisfy your hunger for phlebotomy talk between newsletter issues? Visit and “Like” our Facebook page and you’ll never miss out on another discussion. Your peers need your input, and you need theirs. www.facebook.com/CPEInc


Featured FAQ
Draws from VADs

Q: What is the common practice for drawing coagulation specimens from venous access devices? I know CLSI has issued guidelines for this procedure that recommend flushing with 5 mL of saline and discarding the first 5 mL of blood or 6 times the dead space of the catheter. Is it appropriate to follow these standards routinely, or only when no other venipuncture site can be found? Phlebotomists are put in a challenging position when patients request their line be used, but nurses insist specimens be drawn by venipuncture.

A: The standards promoted by the Clinical and Laboratory Standards Institute (CLSI, formerly NCCLS) discusses how to draw from a vascular access device (VAD), not when. It’s best to avoid VAD draws because of the increased potential for preanalytical error from contamination, hemolysis, etc., and to draw from them only when no veins are accessible. When doctors tell patients that their VAD will prevent them from having to endure venipunctures, it becomes a problem for those with blood collection responsibilities who know the risk line draws pose to accurate results. There’s no easy answer for this dilemma except to explain to the physician the problem that such a comment to the patient presents.

Each month, PT-STAT! will publish one of the hundreds of phlebotomy FAQs in the growing database of questions and answers available in Phlebotomy Central, the members-only section of the Center for Phlebotomy Education's website. For information on joining Phlebotomy Central, click here.


Website Answers Blood-Collection Questions

"The next best thing to knowing something is knowing where to find it," so says 18th century English author Samuel Johnson. When it comes to answers to questions on blood sample collection, finding them at www.phlebotomy.com is often the first and last place healthcare professionals need to look.

"First and foremost, our website must be a place where visitors find answers to their questions," says Dennis J. Ernst MT(ASCP), Executive Director of the Center for Phlebotomy Education. "Type "MRSA" into the search window in the upper left corner of our home page and no fewer than ten search results appear with links to articles we've written on MRSA as it pertains to phlebotomy. Type in "hematoma" and you get eight returns. 'Hemolysis,' over sixty."

Perhaps the most comprehensive source of answers to preanalytical questions resides in Phlebotomy Central, the members-only area of phlebotomy.com. There, subscribers have access to hundreds of back Phlebotomy Today back issues, hundreds of FAQs, and dozens of lengthy articles, all searchable by keyword.

If visitors still can't find an answer to what they're looking for, Ernst offers the personal touch. "My staff and I spend many hours each week taking calls and answering technical questions submitted by email through our 'contact us' page," says Ernst." There aren't many questions we haven't been asked over the last 13 years, but every now and then we get stumped." When that happens, Ernst says they are not ashamed to say they don't know, and then resolve to go out and find the answer. "After all, the next best thing to knowing something is knowing where to find it."  


On a Personal Note...

Throughout my working life, I've held a grand total of 15 jobs before this one, which I can't really count as a job since it's too much fun. Eight were in healthcare, three in the food-service industry, one in education, one with a utility contractor, one at a tractors store, and one at a laundromat. How would I rate them in terms of job satisfaction?.If you have a moment, follow me.


Survey Says
When to Don Gloves

Last month, we asked visitors to our website and our Facebook page about what their facility’s written procedure says about when to glove in relation to drawing blood, and at what point they actually put on their gloves.

  1. For non-isolation patients, when in the sequence of blood specimen collection does your facility's written procedure instruct you to don gloves?

Chart 1 illustrates the responses received, with the majority of survey participants indicating that their facility policy requires gloving to occur after identifying the patient (42%). Ten percent of respondents reported that no written instruction is provided by their facility. Of this group, only 20 percent represent facilities outside the U.S. Facilities outside the U.S. also comprise the two percent that indicated gloves are not required during phlebotomy procedures.

Chart 1

Sample Comments:

  • “Our phlebotomy procedure says we should don gloves after palpating and cleaning the venipuncture site.”
  • “After greeting patient before identifying the patient.”
  • “We are allowed to remove our glove to palpate for difficult/hard to find veins, prior to cleansing the site. Then we put the glove back on, cleanse site and perform venipuncture.”
  • “Two gloves are required for all collections and are donned after washing hands and before touching the patient.”
  • “The phlebotomist may feel for the vein with cleaned, ungloved hands if need be. Then we glove before cleansing the site and proceed with the draw.”

We also asked survey participants to share their actual gloving practices with us, with the results shown in Chart 2.

  • What is your actual practice?

Overall, the actual gloving habits reported by survey participants mirror facility policy. Interestingly, approximately 6 percent of respondents whose policies call for gloving before the cleansing step reported they choose to glove earlier in the procedure, after identifying the patient. Of the 4 percent who responded that they do not wear gloves, 3 percent represent facilities outside the U.S.

Chart 2

Sample Comments:

  • “I put on gloves after identifying the patient. Even though facility policy says we should put gloves on after cleansing the site, I put mine on before patient contact. As a phlebotomist, I don't know what kind of germs could be lurking on each patient!”
  • “In a patient with good veins, I put a glove on my right hand after seating the patient, then I locate the vein, clean the area and put the other glove on while the site is drying. In a patient with hard-to-find veins, it is impossible for me to keep sight on the vein location with a gloved hand and I must keep my locating hand glove-free. I cannot feel anything through a glove, and I hate not wearing a glove.”
  • “Always wash in front of the patient (or use sanitizer) and before handling any supplies.” “I do poke a hole in the fingertip, just in case I need to relocate.”
  • “I teach my new phlebs, my students on rotation, and the general nurses to never touch anything without gloves on.”
  • “After greeting the patient which is before identifying the patient.”
  • “After washing hands and before touching the patient.”

The Clinical and Laboratory Standards Institute (CLSI) in its venipuncture standard states that the phlebotomist must put new gloves on before the venipuncture is performed. It also defers to institutional policy for isolation patients or other situations that may require donning of gloves earlier in the procedure.(1)

In the sequence of routine blood sample collection, CLSI instructs the collector to put on gloves after the vein has been selected, and before cleansing the site.(1) This placement allows the collector the option to palpate for a suitable vein before gloving, and remain in compliance with the standard.

Employees in the U.S. who choose to draw blood without gloves or compromise their integrity by tearing off the fingertips are in violation of OSHA’s Bloodborne Pathogens Standard and place their employers at risk for fines and citations.(2) They also place themselves at risk for contracting any of the 200-plus diseases that may be transmitted via blood exposure.


  1. CLSI. Procedures for the Collection of Diagnostic Blood Specimens by Venipuncture; Approved Standard—Sixth Edition. CLSI document H3-A6. Wayne, PA: Clinical and Laboratory Standards Institute; 2007.
  2. U.S. Department of Labor. Occupational Safety & Health Administration (OSHA). Bloodborne Pathogens (29 CFR 1910.1030). Link. Accessed 11/13/11.

This month’s survey question:
Do you ask every outpatient if he/she has a history of fainting? Are your outpatient draw stations stocked with ammonia inhalants? In your outpatient drawing area, do you have a reclining phlebotomy chair, cot or gurney for patients who feel faint?

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What Should We Do?

[Editor’s Note: "What Should We Do?" gives you the opportunity to ask our team of technical experts for advice on your most pressing phlebotomy challenges. Whether technical or management in nature, we'll carefully consider solutions and suggestions based on the industry's best practices so that you and those in other facilities with the same problem can benefit, all the while maintaining your facility's anonymity. What Should We Do? is your opportunity to ask us for suggestions on the best way to handle your real-life dilemmas.]


This Month’s Case Study:
Confirming the ID of an unconscious patient

One reader writes: Last year, I updated our phlebotomy procedure using the CLSI standards. Our old procedure stated to document certain things but it didn't say how or where. I polled surrounding areas and found one site that had a phlebotomy form with circumstances listed and a coded specimen comment to be entered when the specimen was received in the lab. A few situations such as when a patient is identified by the nurse or physician, drawing above an IV, or doing a foot draw require the signature of a nurse or physician for our documentation before we complete the collection.

We have been doing this for a year and the nurses grumble because it adds to their busy day. They also don't want a permanent record of them confirming the patient’s ID. Out of the blue, the ER nurses have banded together and said they are refusing to sign our form and their manager is backing them up. 

Before I make this a hill to die on, I want to make sure I am interpreting the guideline correctly. If a patient has an armband on but is unconscious, we still need someone (either a family member or a caregiver) to confirm the identification of the patient before we draw their blood, and we should document this step. The nurses say this step of them confirming the ID is unnecessary, and the armband should be all that we need



Our response: You are doing exactly what we would recommend: defending the patients' right to be properly identified. Many would buckle under the pressure, but we commend you for taking a stand as the patients' last line of defense against medical mistakes. The standards and guidelines are on your side.

According to the CLSI venipuncture standard (H3), for patients who cannot identify themselves:

  1. Ask the nurse, a relative, or a friend to identify the patient by name, address, identification number, and/or birth date. Document the name of the verifier.
  2. Compare these data with the information on the request form. For inpatients, compare these data
    with those on the patient’s identification bracelet, which must be attached to the patient.
  3. Report any discrepancy, however minor, to the responsible person in the area (as determined by
    institutional policy) and have the patient identified by name and/or identification number before
    drawing any specimen.

According to a new CLSI guideline on patient identification titled "Accuracy in Patient and Sample Identification” (GP33), the language is nearly identical. It goes on to state:

In the case of a semiconscious or comatose patient, contact a nurse or physician and record the name of the person who verifies that the ID band is on the correct patient.

So your stance is not only supported by a guideline, but a long-standing industry standard. What this means is that if a patient is ever misidentified because the ID bracelet was incorrect or on the wrong patient, the evidence is overwhelming that the facility is operating beneath the standard of care. Perhaps your facility's risk manager should be brought into the conversation.
Note that the standard does not suggest the caregiver or family member who identifies a patient must provide their signature, only that their name should be documented. Your facility is perfectly entitled to make the signature mandatory, but it is not required by the standards.
So, the hill you are climbing in this fight is noble and supported by the CLSI standards. You have solid ground upon which to enforce your policy.



Your most challenging phlebotomy situations and work-related questions.

Send your submission to WSWD@phlebotomy.com and you just might see it as a future case study.



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PT STAT! is a free, monthly educational service provided by the Center for Phlebotomy Education, Inc., the most respected authority in phlebotomy. For a complete company profile and product list for all healthcare professionals who perform, teach or manage specimen collection procedures, visit us on the Internet at: http://www.phlebotomy.com.
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Copyright 2011, Center for Phlebotomy Education, Inc. All rights reserved. Newsletters may contain links to sites on the Internet owned and operated by third parties. The Center for Phlebotomy Education, Inc. is not responsible for the availability of, or the content located on or through, any such third-party site. Information in this document is provided "as is," without warranty of any kind, either expressed or implied, including but not limited to the implied warranties of merchantability, fitness for a particular purpose and freedom from infringement. The user assumes the entire risk as to the accuracy and the use of this document. We will not be liable for any damages of any kind arising from the use of this information, including, but not limited to direct, indirect, incidental, punitive, and consequential damages.