Eight Steps To Ensuring OSHA Compliance

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A Guide To Conducting An Office Safety Audit

Are you feeling overwhelmed when it comes to OSHA compliance? If so, this helpful checklist can help you organize a compliance audit of your practice. Meet with your office manager or designated OSHA supervisor and discuss the following items.

• Check the existing OSHA manual for hepatitis B vaccination records. Only personnel who are involved with patient care need to be vaccinated.

• Check your infection control practices. Is personal protective equipment available for your staff? Are staffers complying with proper hand washing practices and trained to recognize infectious diseases?

• Monitor for sterilization. Is there a designated area for processing of dirty equipment? Is there an area for designated clean processing? Is the expiration of sterilized equipment clearly defined? Check for spore testing and documentation of loads. Have the staff demonstrate the proper process for sterilization.

What About Hazardous Waste And Chemical Spills?
• Monitor your practice’s hazardous waste management (if applicable). Make sure red sharps disposal containers are available where appropriate and ensure they are out of the reach of children.

• Confirm the availability of a spill kit and ensure staffers know how to use it. Check for the correct eye wash kit. Staffers should be able to use this with one hand. The kit also needs to be flushed daily.

• Ask about lab coats. Any person dealing with hazardous materials must have long sleeve coveralls. These uniforms must be laundered professionally and paid for by the office.

Other Essential Safety Items
• Ask to see the MSD sheets. If none are available, make sure your OSHA supervisor acquires them from the suppliers of the chemicals or from the general supplies representative.

• Check the first aid kit. Although we have medical supplies, the first aid kit should be easily accessible to all staff in case of an emergency.

• Ask to see the written disaster plan. There should also be a posted evacuation plan. Make sure exit signs and stairs are properly marked. Also ensure that the exit signs are properly illuminated.

• Ask about the safety training program, how often it is given and if it is documented.

• Make sure the emergency phone list is posted. Check to make sure other posters are also posted.

Check Fire Safety And Housekeeping Issues
• Check for fire extinguishers. Note when they were last checked. Check for the presence of smoke detectors and/or a sprinkler system. Make sure there are no fire hazards in storage areas. Determine when the practice had its last fire drill.

• Ensure all chairs and office furniture are sound and the carpet has no worn areas, holes or loose seams. Check to see if all electrical cables are taped down and out of the way. Clutter and boxes should not be under desks or in the walkways.

• Discuss any immediate concerns with your in-house OSHA supervisor. If you have more specific questions, you may want to check with a local OSHA consultant.

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Author(s): 
By Steven D. Chinn, DPM, CHE

Is your practice as safe as it needs to be? When Congress created the Occupational Safety and Health Administration (OSHA) in 1971, the intent was to decrease the number of workplace injuries, illnesses and deaths. In 1999, there were over 5.7 million occupational injuries and illnesses in the United States. Approximately 6.3 employees out of every 100 experienced a job-related injury or illness.
All medical practices are expected to comply with the regulations regardless of the number of employees. Some of the critical areas emphasized over the years include injury and illness prevention, employees’ right to know about hazardous material, bloodborne pathogen protection and repetitive stress injuries. The current OSHA focus includes emergency preparedness and preventing workplace violence.
Although there are a number of ways of making sure you are complaint, I have distilled them into eight key steps for compliance.

Review The Regulations
1. Know the regulations. The laws are written with the expectation that business owners know the requirements for compliance. Keep in mind that some states have recognized OSHA programs that might be more stringent than the federal requirements. The rule that applies is the more stringent law, regardless if it is from the state or the federal government.
The U.S. Department of Labor is the parent agency that administers the OSHA program. The Web site www.osha.gov has a wealth of information, including numerous publications that you can either download or purchase from the agency. Some of the more relevant publications for healthcare include:
• Blood Borne Pathogens and Acute Care Facilities (Publication 3128)
• Guidelines for Preventing Workplace Violence for Health Care and Social Service Workers (Publication 3148)
• How to Prevent Needle Stick Injuries (Publication 3161)
OSHA also has produced a number of online web-based education programs. The most relevant would be the OSHA eTool program for hospital staff. You can find the list of these programs at www.osha.gov/dts/osta/oshasoft/index.html.

Make Sure All Staff Have Appropriate Safety Training
2. Perform workplace orientation for each new employee. The law requires that all employees are properly oriented to their work environment. This orientation will vary with the job description. Obviously, a receptionist would have a slightly different orientation (and different work place injury or illness risks) than a back office person. One problem that commonly occurs is when a longtime employee moves from the front office into the back office, but never receives the back office orientation.
3. Perform annual OSHA training for all staff. There is wide flexibility in how this can be accomplished. You can opt for an in-service format, videotape training, a CD-ROM or Internet-based education. There are numerous companies that produce these types of educational material. As previously mentioned, the federal OSHA program has developed Web-based training courses that could assist small businesses.
There should also be some sort of post-training quiz and evidence to prove that education was provided to the staff. One can store the evidence of education document in individual employee files or in an education binder that can be pulled out for review in the case of an OSHA audit.

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