OSHA Compliance

The Occupational Safety and Health Administration (OSHA) was created to assure safe and healthful working conditions for working men and women by setting and enforcing standards and by providing training, outreach, education, and assistance.

While generally associated with industrial facilities or construction sites, OSHA rules apply in healthcare practices as well. If you have one employee, then you must have an OSHA plan in place. Some have tried to skirt the law by saying that independent contractors are not employees. As far as OSHA is concerned, if they work in your office, they are considered an employee, no matter what title they are given.

Like HIPAA rules, OSHA federal requirements are the minimum standard. When this article was written, there were 26 states (and 2 territories) with their own OSHA plans which may be different than federal rules. Be aware of your individual state requirements.

Quite often, an OSHA inspection begins with a complaint from either an employee or a patient. Your office will then be given an on-site visit. To help you avoid being blindsided by these on-site visits, it is important to understand these requirements.

How to Begin

Be aware that there are entire books on the subject of OSHA and how to fully and properly meet OSHA requirements.

The information presented here is only a beginning point. OSHA recommends taking the following steps in your compliance program:

1. Learn which OSHA standards/requirements apply to health care.
2. Identify hazards at your facility and learn how to minimize the risks for those hazards.
3. Develop a comprehensive safety and health program.
4. Train your employees on safety.
5. Establish procedures for recordkeeping, reporting, and posting.

Tip: If an illness or injury happens to a temporary employee – including those from a staffing agency, in most cases, the reporting entity is NOT the staffing agency - it is the office where the event occurred.

Start by creating your own “OSHA Compliance Manual” in order to document your compliance steps. At a minimum, include sections on:

• General Safety which can include areas such as fire safety, ergonomic hazards, radiation safety (if you have an x-ray machine) and an emergency action plan.
• Pathogen Standards which include procedures for disinfection and sterilization.
• Hazard Standards which include Material Safety Data Sheets (MSDS) for hazardous materials and how to properly handle those hazards.
• Recordkeeping which includes reports of training as well as incidents with their associated incident response. As part of a new rule in 2015, OSHA made it easier to do this reporting online.

OSHA offers many free resources on their website including a “Compliance Assistant Quick Start” for the healthcare industry. These resources can assist providers who are setting up a compliance program on their own. On-site consultations to identify hazards and provide advice for small businesses may also be available in your area.

For those who desire professional assistance, there are compliance specialists who can come to your office and set up your program. There are also commercial products available to assist in the creation of a personalized OSHA Compliance Manual.

Quick Tips

Practices are responsible for learning and implementing all pertinent OSHA requirements. Although NOT a comprehensive checklist, here are some quick steps you can take to get started with an OSHA compliance plan. At a minimum, be sure to document these steps in your OSHA Compliance Manual.

• Obtain a poster that lists employee protections and applicable laws and hang it in a prominent staff area such as a lunchroom. These “Job Safety and Health Posters” can be found in many office supply stores. Click here to download a free “It’s the Law” poster.
• Hang fire extinguisher(s) of the appropriate type in an accessible location. Assign a staff member to record the status of the gauge on a monthly basis in your OSHA Compliance Manual where it can be seen by an inspector. Check with your local fire department, as many of them offer an inspection service which, upon completion, often includes an inspection certificate or proof of inspection which, may be included in your Compliance Manual.
• Provide an eyewash station (a gallon of clean water and an eye cup may do for starters) in areas where chemicals (e.g., x-ray developer or cleaning supplies) are stored. Have a staff member record the condition and readiness of these facilities on a monthly basis. Keep this record in your Compliance Manual where it can be seen by an inspector.
• Obtain an OSHA spill kit. Cleaning up spills of OSHA covered items requires an official policy and procedure which should be included in your OSHA Compliance Manual. Train staff on how to safely clean spills and record that training in your manual.
  
  Tip: Kits may be purchased from supply companies, but they can also be easily created on your own. To create your own spill kit, simply include the following items in a dated plastic baggie: kitty litter, scoop, gloves, goggles, brush and if mercury is used in your office, your kit also needs a thermometer. Place the kit close enough to places that might have spills so that it can be easily accessed by all staff.
  
  
• Provide emergency exit charts at each work area that illustrate the appropriate path out of the office.
• Post emergency numbers by telephones. Have policies regarding who should be called for what event. Keep a book labeled “Emergency Phone Numbers” in plain site in the office.
• Obtain Safety Data Sheets (SDS) (formerly called Material Safety Data Sheets (MSDS)) for any toxins in your office and keep them in a clearly labeled binder (your Compliance Manual is a good place). This includes printer ink, toner and cleaning supplies. Warning posters can typically be obtained free of charge from your suppliers. This includes chemical vendors, such as an x-ray supply company.
• Provide a secure lockbox in a public area for the submission of suggestions, and log the submissions in your OSHA Compliance Manual on a regular basis.
• Provide scrubs on site for employees for emergencies. They must change out of contaminated clothing BEFORE they leave the office! This is for all biological spills, including someone vomiting in your office.
• Understand and evaluate rules for proper ergonomics in each department and for each employee.
• Be sure that employees are properly trained in all areas of OSHA compliance as well as the reporting procedures for injuries and other safety related occurrences.

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