Time to Review OSHA Standards

Early in the year is a good time to get out your Occupational Safety and Health Administration logs, walk through your office, and confirm that you remain in compliance with all the applicable OSHA regulations. Even if you hold regular safety meetings (which all too often is not the case), the occasional comprehensive review is always a good idea, and could save you a bundle in fines.

Your review should include each of the six OSHA standards (seven if you have an x-ray machine) that apply to all physician offices, whatever their size.

Start with the official OSHA poster—enumerating employee rights and explaining how to file complaints—which must be displayed in a conspicuous place in your office. It's the first thing an OSHA inspector will look for. You can download it from OSHA's Web site (www.osha.gov/Publications/poster.html

Next, check out your building's exits. Everyone must be able to evacuate your office quickly in case of fire or other emergencies. At minimum, you (or the building's owner) are expected to establish exit routes to accommodate all employees and to post easily visible evacuation diagrams.

Examine all electrical devices and their power sources. All electrically powered equipment—medical, clerical, or anything else in the office—must operate safely. Pay particular attention to the way wall outlets are set up. Make sure each outlet has sufficient power to run the equipment plugged into it, and that circuit breakers are functioning. And beware the common situation of too many gadgets running off a single circuit.

Now, review your list of hazardous chemicals, which all employees have a right to know about. Keep in mind that OSHA's list contains many substances—alcohol, disinfectants, even hydrogen peroxide—that you might not consider to be particularly dangerous, but must nevertheless be on your written list of hazardous chemicals. For each of these substances, your employees must also have access to the manufacturer-supplied material safety data sheet, which outlines the proper procedures for working with a specific substance and for handling and containing it in a spill or other emergency.

The blood-borne pathogen rules are aimed at reducing occupational exposure to blood-borne diseases such as HIV, hepatitis B, and hepatitis C. In 2000, Congress added the Needlestick Safety and Prevention Act in an attempt to reduce the risk of needlestick and other sharps injuries.

The basic requirements include a written exposure control plan, updated annually to reflect changes in technology. You need not evaluate or purchase every new device on the market, but you should document which safety devices you are using, and why. Also, be sure to document the input of all employees involved in the selection process.

For example, you and your employees may decide not to purchase a newly available safety needle because you don't think it will improve safety, or because you think that it will be more trouble than it's worth, but you should document how you arrived at your decision and what you plan to use instead.

Your plan should document your use of such protective equipment as gloves, face and eye protection, and gowns, and your implementation of universal precautions.

You must provide all at-risk employees with hepatitis B vaccine at no cost to them. You also must provide and pay for appropriate medical treatment and follow-up after any exposure to a dangerous pathogen.

Other components of the rule include proper containment of regulated medical waste, identification of regulated-waste containers, sharps disposal boxes, and periodic employee training regarding all of those things.

Federal OSHA regulations do not require medical and dental offices to keep an injury and illness log, as other businesses must. However, your state may have such a regulation which supersedes the federal law. Check with your state or with your local OSHA office regarding any such requirements.

For x-ray therapy, there are separate rules regulating such equipment, including area restriction to minimize employee exposure, the use of film badges, and appropriate caution signs.

It is a mistake to take OSHA regulations lightly; failure to comply with them can result in stiff penalties that could total many thousands of dollars.

How can you be certain you are complying with all the rules? The easiest and cheapest way is to call your local OSHA office and request an inspection. Why would you want to do that? Because in return for agreeing to have your office inspected, OSHA will agree not to cite you for any violations—providing you correct them, of course.

Early in the year is a good time to get out your Occupational Safety and Health Administration logs, walk through your office, and confirm that you remain in compliance with all the applicable OSHA regulations. Even if you hold regular safety meetings (which all too often is not the case), the occasional comprehensive review is always a good idea, and could save you a bundle in fines.

Your review should include each of the six OSHA standards (seven if you have an x-ray machine) that apply to all physician offices, whatever their size.

Start with the official OSHA poster—enumerating employee rights and explaining how to file complaints—which must be displayed in a conspicuous place in your office. It's the first thing an OSHA inspector will look for. You can download it from OSHA's Web site (www.osha.gov/Publications/poster.html

Next, check out your building's exits. Everyone must be able to evacuate your office quickly in case of fire or other emergencies. At minimum, you (or the building's owner) are expected to establish exit routes to accommodate all employees and to post easily visible evacuation diagrams.

Examine all electrical devices and their power sources. All electrically powered equipment—medical, clerical, or anything else in the office—must operate safely. Pay particular attention to the way wall outlets are set up. Make sure each outlet has sufficient power to run the equipment plugged into it, and that circuit breakers are functioning. And beware the common situation of too many gadgets running off a single circuit.

Now, review your list of hazardous chemicals, which all employees have a right to know about. Keep in mind that OSHA's list contains many substances—alcohol, disinfectants, even hydrogen peroxide—that you might not consider to be particularly dangerous, but must nevertheless be on your written list of hazardous chemicals. For each of these substances, your employees must also have access to the manufacturer-supplied material safety data sheet, which outlines the proper procedures for working with a specific substance and for handling and containing it in a spill or other emergency.

The blood-borne pathogen rules are aimed at reducing occupational exposure to blood-borne diseases such as HIV, hepatitis B, and hepatitis C. In 2000, Congress added the Needlestick Safety and Prevention Act in an attempt to reduce the risk of needlestick and other sharps injuries.

The basic requirements include a written exposure control plan, updated annually to reflect changes in technology. You need not evaluate or purchase every new device on the market, but you should document which safety devices you are using, and why. Also, be sure to document the input of all employees involved in the selection process.

For example, you and your employees may decide not to purchase a newly available safety needle because you don't think it will improve safety, or because you think that it will be more trouble than it's worth, but you should document how you arrived at your decision and what you plan to use instead.

Your plan should document your use of such protective equipment as gloves, face and eye protection, and gowns, and your implementation of universal precautions.

You must provide all at-risk employees with hepatitis B vaccine at no cost to them. You also must provide and pay for appropriate medical treatment and follow-up after any exposure to a dangerous pathogen.

Other components of the rule include proper containment of regulated medical waste, identification of regulated-waste containers, sharps disposal boxes, and periodic employee training regarding all of those things.

Federal OSHA regulations do not require medical and dental offices to keep an injury and illness log, as other businesses must. However, your state may have such a regulation which supersedes the federal law. Check with your state or with your local OSHA office regarding any such requirements.

For x-ray therapy, there are separate rules regulating such equipment, including area restriction to minimize employee exposure, the use of film badges, and appropriate caution signs.

It is a mistake to take OSHA regulations lightly; failure to comply with them can result in stiff penalties that could total many thousands of dollars.

How can you be certain you are complying with all the rules? The easiest and cheapest way is to call your local OSHA office and request an inspection. Why would you want to do that? Because in return for agreeing to have your office inspected, OSHA will agree not to cite you for any violations—providing you correct them, of course.

Early in the year is a good time to get out your Occupational Safety and Health Administration logs, walk through your office, and confirm that you remain in compliance with all the applicable OSHA regulations. Even if you hold regular safety meetings (which all too often is not the case), the occasional comprehensive review is always a good idea, and could save you a bundle in fines.

Your review should include each of the six OSHA standards (seven if you have an x-ray machine) that apply to all physician offices, whatever their size.

Start with the official OSHA poster—enumerating employee rights and explaining how to file complaints—which must be displayed in a conspicuous place in your office. It's the first thing an OSHA inspector will look for. You can download it from OSHA's Web site (www.osha.gov/Publications/poster.html

Next, check out your building's exits. Everyone must be able to evacuate your office quickly in case of fire or other emergencies. At minimum, you (or the building's owner) are expected to establish exit routes to accommodate all employees and to post easily visible evacuation diagrams.

Examine all electrical devices and their power sources. All electrically powered equipment—medical, clerical, or anything else in the office—must operate safely. Pay particular attention to the way wall outlets are set up. Make sure each outlet has sufficient power to run the equipment plugged into it, and that circuit breakers are functioning. And beware the common situation of too many gadgets running off a single circuit.

Now, review your list of hazardous chemicals, which all employees have a right to know about. Keep in mind that OSHA's list contains many substances—alcohol, disinfectants, even hydrogen peroxide—that you might not consider to be particularly dangerous, but must nevertheless be on your written list of hazardous chemicals. For each of these substances, your employees must also have access to the manufacturer-supplied material safety data sheet, which outlines the proper procedures for working with a specific substance and for handling and containing it in a spill or other emergency.

The blood-borne pathogen rules are aimed at reducing occupational exposure to blood-borne diseases such as HIV, hepatitis B, and hepatitis C. In 2000, Congress added the Needlestick Safety and Prevention Act in an attempt to reduce the risk of needlestick and other sharps injuries.

The basic requirements include a written exposure control plan, updated annually to reflect changes in technology. You need not evaluate or purchase every new device on the market, but you should document which safety devices you are using, and why. Also, be sure to document the input of all employees involved in the selection process.

For example, you and your employees may decide not to purchase a newly available safety needle because you don't think it will improve safety, or because you think that it will be more trouble than it's worth, but you should document how you arrived at your decision and what you plan to use instead.

Your plan should document your use of such protective equipment as gloves, face and eye protection, and gowns, and your implementation of universal precautions.

You must provide all at-risk employees with hepatitis B vaccine at no cost to them. You also must provide and pay for appropriate medical treatment and follow-up after any exposure to a dangerous pathogen.

Other components of the rule include proper containment of regulated medical waste, identification of regulated-waste containers, sharps disposal boxes, and periodic employee training regarding all of those things.

Federal OSHA regulations do not require medical and dental offices to keep an injury and illness log, as other businesses must. However, your state may have such a regulation which supersedes the federal law. Check with your state or with your local OSHA office regarding any such requirements.

For x-ray therapy, there are separate rules regulating such equipment, including area restriction to minimize employee exposure, the use of film badges, and appropriate caution signs.

It is a mistake to take OSHA regulations lightly; failure to comply with them can result in stiff penalties that could total many thousands of dollars.

How can you be certain you are complying with all the rules? The easiest and cheapest way is to call your local OSHA office and request an inspection. Why would you want to do that? Because in return for agreeing to have your office inspected, OSHA will agree not to cite you for any violations—providing you correct them, of course.