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OSHA Compliance: How CNT Falls Short

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I presume that many on this forum practice acupuncture in addition to

herbal medicine, and thus might have interest in the following item.

 

My article in the latest issue of the California Journal of Oriental

Medicine (CJOM 18.1:23-4) provides a sampling of deficiencies and

inaccuracies in the acupuncture profession's official manual of

standards for safe practice. I compared the contents of Clean Needle

Technique Manual for Acupuncturists (5th Ed., 2005, National

Acupuncture Foundation) with then-current federal standards from the

Occupational Safety and Health Administration (OSHA). To view full

text of the article on the Internet, go to:

http://www.convergentmedical.com/newsdesk.html.

 

I found that the Clean Needle Technique Manual for Acupuncturists

(CNT) did not correctly or fully convey the requirements of the

Needlestick Safety and Prevention Act of 2000. Nor did it provide

current guidance on the use of alcohol-based hand rubs, as approved by

OSHA in 2003. There were additional deficiencies with respect to

expressing key provisions of OSHA's Bloodborne Pathogens Standard and

Respiratory Protection Standard.

 

I consider acupuncturists and their employees (and not patients) to

be the parties most at risk due to these shortcomings. Acupuncturists

who rely on the CNT manual for OSHA compliance guidance could be

surprised to discover that they are not in OSHA compliance. I suggest

that acupuncturists review federal OSHA regulations at

http://www.osha.gov. I also recommend my recent book, Quality In

Complementary & Alternative Medicine (2006, CMS Press), as a resource

for comprehensive guidance on relevant federal regulations.

 

Fulfillment of OSHA safety standards rests on an accurate

understanding of those standards. The national acupuncture

organizations involved in the preparation of the CNT manual are

accountable to the profession for the manual's shortcomings. I expect

those organizations will heed my critique, recognizing that it

indicates opportunities for improvement in the establishment and

expression of safety standards. A continuous process of improvement

is the result we're all hoping to achieve.

 

Best Regards,

 

David Kailin, Ph.D., M.P.H., L.Ac.

Author, Quality In Complementary & Alternative Medicine

http://www.convergentmedical.com

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