oshahcmarketplace.com/media/browse/8711_browse.pdfwith osha regulations. during her tenure at baxter...

Sarah E. Alholm, MAS

for Healthcare Facilities

OSHA

OSHAPB

200 Hoods Lane | Marblehead, MA 01945www.hcmarketplace.com

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for H

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This concise primer cuts through the clutter and illustrates how to maintain compliance.

Save time trying to interpret vague OSHA standards and discover specific methods to

train staff, identify hazards, and document accurately, enabling you to become a highly

effective safety professional.

Keep employees safe and avoid costly fines

Implement a compliant safety program using proven successful case studies

and “how-to” action-oriented strategies as your guide

Navigate the complex crossover of OSHA regulations with other organizations,

such as the CDC, EPA, and FDA

Save time researching the right training methods and documentation with

customizable, downloadable sample forms and tools

Execute your OSHA plan with help from “Top 10 Action Items” lists at the end

of every chapter

OSHAfor Healthcare Facilities

Sarah E. Alholm, MAS

This is the type of reference book that I can get excited about. My position allows only a few hours

each week when I’m not with patients to devote solely to safety, and it would be nice to have this

quick reference material at hand.

— Michelle Ambrose, BA, RT(R), OSHA Safety Leader, Minnesota Orthopaedic Specialists/Twin Cities Orthopedics

Sarah Alholm, MAS

for Healthcare Facilities

OSHA

OSHA Training Handbook for Healthcare Facilities is published by HCPro, Inc.

Copyright © 2010 HCPro, Inc.

All rights reserved. Printed in the United States of America. 5 4 3 2 1

ISBN: 978-1-60146-761-4

No part of this publication may be reproduced, in any form or by any means, without prior written

consent of HCPro, Inc., or the Copyright Clearance Center (978/750-8400). Please notify us immediately

if you have received an unauthorized copy.

HCPro, Inc., provides information resources for the healthcare industry.

HCPro, Inc., is not affiliated in any way with The Joint Commission, which owns the JCAHO and Joint

Commission trademarks.

Sarah Alholm, MAS, Author Amanda Donaldson, Copyeditor

Tami Swartz, Editor Sada Preisch, Proofreader

Michael Briddon, Executive Editor Matt Sharpe, Production Supervisor

Emily Sheahan, Group Publisher Susan Darbyshire, Art Director

Janell Lukac, Graphic Artist Jean St. Pierre, Senior Director of Operations

Advice given is general. Readers should consult professional counsel for specific legal, ethical, or clinical

questions.

Arrangements can be made for quantity discounts. For more information, contact:

HCPro, Inc.

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Telephone: 800/650-6787 or 781/639-1872

Fax: 800/639-8511

E-mail: [email protected]

Visit HCPro online at:

www.hcpro.com and www.hcmarketplace.com

7/201021797

OSHA Training Handbook for Healthcare Facilities © 2010 HCPro, Inc. iii

Contents

About the Author....................................................................................................................................... v

Introduction...............................................................................................................................................vi

Chapter 1: Roles and Responsibilities...................................................................................................1

You’re the Safety Officer … Now What?.....................................................................................1

Tailoring Your Job to the Needs of Your Facility........................................................................2

Your Safety Committee.................................................................................................................3

Resources ......................................................................................................................................9

Top 10 Safety Officer Action Items............................................................................................18

Chapter 2: Creating a Compliance Program........................................................................................19

Bloodborne Pathogens ...............................................................................................................19

Hazard Communication ............................................................................................................38

Emergency Action Plans ............................................................................................................44

Electrical Requirements..............................................................................................................48

Other Standards: Respiratory Protection, Ionizing Radiation, and Chemical Hygiene........50

General Duty Clause...................................................................................................................53

MRSA and More .........................................................................................................................56

Ergonomics .................................................................................................................................58

Workplace Violence ...................................................................................................................61

Risk Assessments .......................................................................................................................62

Recordkeeping Exemption .........................................................................................................64

Top 10 Compliance Action Items...............................................................................................66

Chapter 3: Employee Training................................................................................................................69

Hazard-by-Hazard vs. Best-Practices Approach.......................................................................70

Training Basics for All OSHA Training .....................................................................................71

Unique Training Required by Specific Standards ....................................................................75

The Problem of Physician Training...........................................................................................85

Training Ideas..............................................................................................................................86

Top 10 Action Items for Training Employees............................................................................89

Chapter 4: Inspections, Violations, and Fines.....................................................................................91

The Knock on the Door..............................................................................................................91

During the Inspection.................................................................................................................93

Receiving a Violation Warning..................................................................................................99

OSHA Training Handbook for Healthcare Facilities © 2010 HCPro, Inc.iv

Responding to and Rectifying Violations................................................................................100

Challenging or Mitigating Fines...............................................................................................105

Top 10 Inspection Action Items................................................................................................107

Chapter 5: Beyond OSHA.....................................................................................................................109

Patient Safety.............................................................................................................................109

Waste: Where OSHA Ends and State and Federal Regulations Begin..................................126

Accreditation and Insurance Audits........................................................................................136

Top 10 Action Items for Additional Safety and Regulatory Concerns..................................140

Appendix A: Common and Expensive OSHA Citations ......................................................................145

Appendix B: Checklists.........................................................................................................................149

Keeping Checklists....................................................................................................................149

Appendix C: Sample Training Exams...................................................................................................157

Recordkeeping for Employee OSHA Training Exams.............................................................157

Appendix D: Frequently Asked Questions ..........................................................................................171

Postexposure Requirements.....................................................................................................171

Storage for Employee Medical Records...................................................................................173

Gloves and Injections................................................................................................................174

Eating and Drinking..................................................................................................................174

Floor vs. Carpet.........................................................................................................................175

Safety Sharps ............................................................................................................................176

Laundering Lab Coats...............................................................................................................177

Spill Kit.......................................................................................................................................177

Food and Vaccine Storage.........................................................................................................178

Master Hazardous Substance List...........................................................................................178

MSDS Requirements..................................................................................................................179

Heathcare Worker Vaccinations...............................................................................................180

DownloaD Your Materials

Materials are available for dowload upon purchase of this product.

OSHA Training Handbook for Healthcare Facilities © 2010 HCPro, Inc. v

About the Author

Sarah Alholm has applied her safety knowledge at organizations large and small for more than

10 years. Before partnering with HCPro, she was the lead OSHA technical expert at Quality

America, Inc., a healthcare consulting firm that helps medical and dental practices comply

with OSHA regulations. During her tenure at Baxter Healthcare Corporation, she implemented

procedural and engineering controls that reduced occupational risk for laboratory personnel.

She has developed successful safety training programs for both the healthcare and aviation

industries. Her experience also includes curriculum development and execution addressing

communication among members of high-performance teams, risk management, and OSHA

hazard communication.

Alholm received her master’s degree in human factors from Embry-Riddle Aeronautical Univer-

sity in 2002. Human factors is a multidisciplinary field incorporating contributions from psy-

chology, engineering, industrial design, statistics, and operations research that involves the

study of how we relate to the world around us, with the aim of improving operational perfor-

mance and safety. She earned her bachelor’s degree in biology from the United States Air Force

Academy. She also holds continuing education certificates in Human Performance Enhance-

ment, Safety Program Management, Accident Investigation and Prevention, Alertness Manage-

ment, and Crew Resource Management, among others. She currently resides in Asheville, NC,

with her family, where she provides safety-related healthcare consulting services and training.

She may be contacted through the publisher.

OSHA Training Handbook for Healthcare Facilities © 2010 HCPro, Inc.vi

Introduction

This book is designed to cut through the confusing world of OSHA regulations and tell you in a

friendly way just what you need to do to stay safe and in compliance. Lots of examples from

actual healthcare facilities (just like yours!) are interspersed throughout so you can see exactly

how to apply the information presented. New and experienced safety officers alike find this

guide invaluable—it’s a great beginning if you’re just starting out and a checkup for seasoned

pros. Anyone working as his or her practice’s safety officer will love to have this handy quick

reference. You will find this book helpful if you:

• Are or are about to become the safety officer at an outpatient healthcare facility

• Are responsible for providing safety training to the medical staff

• Want to ensure the well-being of your coworkers and patients

• Are an owner of a medical practice and want to have the best return on your

investment

I know it would be awesome to have a day set aside to sit down and read this handbook cover

to cover, but for most of us, that’s just not going to happen. Use the summary section at the

start of each chapter to quickly find the subject you’re looking for. Icons draw your attention to

key points and warnings as you skim the text. Lots of bulleted lists get to the point, and quick!

Inset boxes feature real-world questions and experiences from OSHA safety officers all over the

United States. Each chapter finishes with a “top 10” list of critical action items for successful

implementation. Finally, tables and Web addresses included throughout tell you where to go

to get more in-depth information, should you need it.

The following is an overview of what you’ll be able to find in each chapter:

• Chapter 1 covers the roles and responsibilities of the safety officer and tells you

how to get help developing a safety committee and working toward a safety cul-

ture in your facility. You’ll also find sources for information and strategies for gar-

nering support.

• Chapter 2 helps you figure out which OSHA regulations apply to your facility and

covers the basics of what the various standards require. Tables, figures, and lots of

frequently asked questions help you construct a road map for compliance.

OSHA Training Handbook for Healthcare Facilities © 2010 HCPro, Inc. vii

Introduction

• Chapter 3 tells you what to do to meet OSHA’s policies for employee training.

We also talk about what makes a training session memorable—because if staff

members don’t remember the information, it will never have the chance to make

a difference.

• Chapter 4 walks you through what to do and expect if you get the dreaded knock

on the door from an OSHA inspector. It also takes you through the dispute pro-

cess should you disagree with the inspector’s findings.

• Chapter 5 goes beyond OSHA and looks at other related areas, such as patient

safety concerns like infection control and healthcare worker drug abuse. It also

looks at where Environmental Protection Agency jurisdiction takes over concern-

ing biohazardous and hazardous pharmaceutical wastes.

• The appendixes explain common OSHA citations and answer even more frequent-

ly asked questions. There are also checklists to make sure you’re on track and

example exams to use during your training sessions.

I hope you’ll find this handbook to be a quick read and valuable compliance resource.

DownloaD your MaTErIals now

Readers of OSHA Training Handbook for Healthcare Facilities can download the figures and forms

included in this book by visiting the HCPro Web address below. We hope you will find the down-

loads useful.

Thank you for purchasing this product!

jlukac

Text Box

Materials are available for download upon purchase of this product.

OSHA Training Handbook for Healthcare Facilities © 2010 HCPro, Inc. 1

You’re the Safety Officer … Now What?

Workplace safety is important. We all know it, but most of the time it feels like just one more

additional duty—one for which there isn’t a lot of time or money. But, luckily, you’ve got help.

This guide is designed to be your quick reference helper to get a handle on occupational safety

at your medical facility.

Let’s start with the basics. Why do we need to do this? Well I, for one, don’t want to contract a

life-threatening illness or be burned by a chemical while at work. Everyone wants to leave at

the end of the day as healthy as when he or she showed up. And, well, it’s the law.

The federal government of the United States issued regulations on workplace safety about 40

years ago by passing the Occupational Safety and Health Act of 1970. That law created the

Occupational Safety and Health Administration (OSHA), which is part of the U.S. Department

of Labor. OSHA’s mission is to “assure safe and healthful working conditions for working men

and women.”1 I think we can all agree that this is a good goal. They’ve been very successful,

too. According to OSHA, “since the agency was established in 1971, workplace fatalities have

been cut by 62% and occupational injury and illness rates have declined 40%.”2 Even though

CHApTer 1

Roles and Responsibilities

In this chapter, you’ll find information about:

•Key.duties.for.the.safety.officer

•Getting.help.from.your.safety.committee

•Where.to.turn.for.information

•How.to.garner.support.from.leadership.at.your.facility

•Ten.things.to.do.to.be.an.effective.safety.officer.

OSHA Training Handbook for Healthcare Facilities © 2010 HCPro, Inc.

Chapter 1

2

we have seen a lot of improvement, workplace-related illness and injuries still occur. When

preventable accidents or disease transmissions happen, it’s a tragedy. As safety officer, prevent-

ing those tragedies now lies in your hands. Good thing you’ve got a game plan.

Tailoring Your Job to the Needs of Your Facility

One of the first things you’ll want to do is have a written job description outlining your safety

officer duties. This helps on many levels: getting senior staff members to understand what’s

required, having written authority for dealing with difficult situations, answering the question

“Why do we have to?” and having all you do recognized during performance evaluations.

The following are some key duties for the safety officer that you’ll want to include:

• Solicits upper management’s written and ongoing commitment to safety

• Maintains, reviews, and updates the OSHA manual at least annually

• Enforces policies contained within the OSHA manual

• Calls safety concerns to the attention of management and recommends remedial

action for unsafe situations

• Provides and maintains personal protective equipment (PPE) and clothing, engi-

neering controls, labels, and waste disposal containers (delegating the actual affix-

ing of labels and emptying of waste containers is appropriate)

• Secures all required medical actions in the event of an employee exposure

• Confidentially maintains employee safety records, including hepatitis B (HBV)

vaccination, postexposure follow-up, and training

• Verifies that employees are aware of hazardous chemicals in the workplace and

that employees understand how to protect themselves to prevent exposure to these

chemicals

• Trains and retrains all employees and keeps documentation of such training (tools

such as seminars, videos, and computer-based training may be used)

• Makes the OSHA manual available to all employees

• Accompanies the OSHA inspector (OSHA compliance safety and health officer)

during an inspection


roles and responsibilities

3

From the previous list, you can see that one of the recurring themes is written documentation.

Having written policies and procedures in an OSHA manual and records of employee training,

self-audits and monitoring, HBV vaccinations, fire drills, employee exposure determination lists,

sharps injuries, and other employee exposures is a lot to keep up with. Keeping it filed and

ready to pull at a moment’s notice is one of your organizational challenges.

Tip: Not organized yet? We have ideas to help. Check out Appendix B for weekly,

monthly, and annual checklists to help you stay on top of everything.

Besides keeping everything organized and meeting deadlines, your largest challenge is likely to

be promoting safety and OSHA compliance, the responsibility found in that pesky third bullet in

the previous list, “Enforces policies contained within the OSHA manual.” Yes, the term “enforces”

elicits a strong negative response for a lot of us. And even for those who do it seemingly without

effort, it still can take up hordes of time. Luckily, you don’t have to go it alone. By forming a

safety committee, you can get help with that dreaded enforcement and more.

Your Safety Committee

Forming a safety committee is a key step to creating a safer workplace and, ultimately, a safety

culture. Having a safety committee gets more employees actively involved in safety, which not

only can help eliminate accidents, but also can help overcome staff resistance to safety-mandated

changes. Things for your safety committee to do include:

• Perform self-inspections (perhaps using the monthly checklist in Appendix B).

• Assist the safety officer with the annual review of safety policies, including your

exposure control plan and written hazard communication program.

• Research the availability of new safety sharps products, and participate in

reviews to ensure the safer sharps used continue to be the best choice for the

tasks performed.

• Suggest improvements to safety policies, PPE selection, and general work prac-

tices concerning safety.

• Find out about “near misses” (i.e., potential accidents that were just barely avoid-

ed). Research data show that there are about 30 near-miss events for every one

accident that actually takes place.


Chapter 1

4

• Review workplace near misses/accidents/incidents (talk about what happened

and why but keep all blood-testing results confidential).

• Recommend corrective actions for near misses and accidents, including consider-

ation of new safety products (engineering controls) when appropriate.

• Express safety concerns.

• Make suggestions for safety training, especially for short three- to five-minute

training that relates to recent occurrences in the workplace.

When establishing your safety committee, you want to make things better, not worse, at your

organization. If the committee does things that breach employee trust, all effectiveness is lost.

This is worse than being back to square one. You absolutely don’t want your safety committee to:

• Access confidential patient or employee health information (talking about it casu-

ally in the break room after meetings is not appropriate or compliant).

• Blow off employee safety concerns (if these are obviously totally unfounded, such

as catching HIV from assisting a patient onto an exam table, the committee should

listen empathetically and explain in a caring manner why the work poses no risk to

the worried employee).

• Speak negatively or callously about safety in the workplace or the purpose/effec-

tiveness of the committee.

• Place blame or become the “safety police.” The goal is to improve the process to

make it safer, not to bludgeon the worker over the head, which effectively stops

communication.

Depending on the size of your organization, your committee could be composed of three to

eight people or more. However, stick to 12 members or fewer; otherwise, you’ll get so bogged

down, you’ll get nothing done. Use subcommittees focused on a particular problem or issue, or

for a department/work area, as a way to foster participation if you have more than 12 people

who want to be involved (which is unlikely).

When you are first forming the committee, you should try to include more high-level manage-

ment staff members to garner support. After people get in the mind-set of doing things safely,



5

having senior-level staff members on the committee isn’t as necessary as long as they keep

showing their support for safety in other ways. The following groups should be represented:

• Top management

• Supervisors

• Frontline nonsupervisory staff members (don’t forget about departments like lab

or housekeeping)

• The safety officer

Not always, but frequently, the safety officer also wears the hat of nursing supervisor.

GETTING TOP-MANAGEMENT SuPPORT

If. the.owner.or. leadership.team.is.already.on.board.and.focused.on.having.a.safe.workplace,.

that’s.great..You’ll.want.them.to.keep.up.their.support.and.let.employees.know.they.care.about.

their.health.at.work..But.what.if.the.top.management.at.your.facility.has.other.priorities?.How.can.

you.get.their.buy-in.to.create.a.safety.program?.Usually,.the.best.way.to.convince.organizational.

leaders.is.by.showing.them.the.dollars.and.cents..If.they.see.how.a.workplace.accident.or.OSHA.

inspection.will.negatively.affect.the.facility’s.pocketbook,.you’ll.have.their.attention..Unsafe.work.

practices.can. lead.to. increased.direct.costs. (like. lab. testing.after.a.needlestick. incident).and.

indirect.costs.(such.as.the.time.spent. investigating.the.incident.and.filling.out.paperwork.and.

increased.insurance.premiums)..For.more.about.how.a.needlestick.incident.affects.the.bottom.

line,. check.out. the.discussion. later. in. the.chapter.on. the.costs.associated.with.an.exposure.

incident..Also,.take.a.look.at.Appendix.A.for.common.OSHA.citations.in.medical.practices.and.

accompanying.fines.

Getting others in your organization to buy into creating a safer workplace makes your job as

safety officer a lot easier. When the members of your safety committee devote their time and

energy to brainstorming and developing safety ideas together, they are more likely to be devot-

ed to safety. The more folks you can get on board initially, the less resistance you’ll be left to

overcome when putting safety practices into place. Obviously, everyone in your facility can’t be

on the safety committee at once, but by rotating staff members via terms on the committee,

you’ll get fresh ideas and have staff members with “safety eyes,” in the form of current and

former members, working in all parts of your office.


Chapter 1

6

It’s good for core members of the safety committee, such as management representatives and

supervisors, to maintain continuity for two or three years. The safety officer may also be

designated for a term of two or three years or serve in the position indefinitely, depending on

the practice. In actuality, it’s usually the latter. Nonsupervisory employees might be on the com-

mittee for six months or one year. Ideally, they’ll be volunteers; shorter terms tend to increase

volunteerism. Otherwise, appoint employees randomly or choose those who seem conscientious

about safety. Stagger terms so that everyone doesn’t turn over at once.

ADDING ‘NEGATIVE NEllIE’ TO THE SAFETY COMMITTEE

QuesTion: Our office’s “Negative Nellie” wants to be on the safety committee. I am sure she would

see plenty of horribly dangerous issues. She seems to have problems with how everything else

works, after all. She makes working toward change impossible. I’m afraid if I say no, she’ll bad-

mouth safety to everyone. What can I do?

Answer:.First,.consider.whether.it.makes.sense.for.her.to.be.on.the.committee.based.upon.her.

job.position..If.it.totally.doesn’t.make.sense,.explain.to.her.nicely.that.you.have.a.limited.amount.

of.space.and.really.need.clinical.(or.fill-in-the-blank).people.on.the.committee..Then,.try.not.to.

worry.about.it..Everyone.who.works.with.her.already.knows.she.never.has.anything.positive.to.

say.and.will.dismiss.her.rants.about.safety.as.her.personality.shortcomings,.not.those.of.your.

excellent.safety.program..If.it.does.make.sense.for.her.role.to.join.the.committee,.work.hard.to.

make.sure.it.doesn’t.become.a.complaint.venue..Set.clear.ground.rules.that.emphasize.finding.

solutions,.not.just.listing.problems..Work.hard.to.make.her.feel.heard.and.understood..Employees.

may.get.frustrated.if.they.don’t.feel.their.concerns.are.being.taken.seriously.and.call.OSHA.just.to.

be.heard..These.types.of.calls.are.the.top.reason.an.inspector.will.come.knocking.on.your.door.

Establishing a safety culture

Many businesses, especially those in industrial settings, are working to establish a “safety

culture” in their workplaces. Establishing one is often a multiyear effort that takes a strong

commitment from leadership, but it is worth mentioning.

Tip: In a strong safety culture, everyone feels responsible for safety and considers it on a

daily basis. If any employee sees something unsafe, the natural reaction is to correct it or

bring attention to the matter if a fix can’t be made on the spot. You can imagine how this

beyond-the-call-of-duty attitude brings safety into the spotlight.



7

The Centers for Disease Control and Prevention (CDC), in its most recent version of the Work-

book for Designing, Implementing, and Evaluating a Sharps Injury Prevention Program, specifi-

cally investigated the benefits afforded by developing strong safety cultures:

One organization level factor, known as safety culture, has been found to be notably

important. Some industrial sectors are finding that a strong safety culture correlates

with: productivity, cost, product quality, and employee satisfaction (113). Organiza-

tions with strong safety cultures consistently report fewer injuries than organizations

with weak safety cultures. This happens not only because the workplace has well-

developed and effective safety programs, but also because management, through these

programs, sends cues to employees about the organization’s commitment to safety.

The concept of institutionalizing a culture of safety is relatively new for the health-

care industry and there is limited literature on the impact of such efforts. However,

a recent study in one healthcare organization linked safety climate (a measure of

overall safety culture) with both employee compliance with safe work practices and re-

duced exposure to blood and other body fluids, including reductions in sharps-related

injuries (114). A second study in one healthcare organization also noted correlations

between specific dimensions of safety culture (such as perceived management com-

mitment to safety and job hindrances) and compliance with universal precautions

and accidents and injuries (115). Additionally, a recent study examining a statewide

sample of healthcare personnel further indicated that greater levels of management

support were associated with more consistent adherence with universal precautions

(specifically, never recapping needles), while increased job demands was found to be

a predictor of inconsistent adherence (81).3

81. Vaughn TE, McCoy KD, Beekmann SE, Woolson RF, Torner JC, Doebbeling BN. Factors promoting con-

sistent adherence to safe needle precautions among hospital workers. Infect Control Hosp Epidemiol

2004; 25(7):548-55.

113. Gershon RM, Karkashian CD, Grosch JW et al. Hospital safety climate and its relationship with safe

work practices and workplace exposure incidents. Am J Infect Control 2000; 28:211-21.

114. Gershon R. Facilitator report: bloodborne pathogens exposure among healthcare workers. Am J Ind

Med 1996; 29:418-20.

115. Grosch JW, Gershon R, Murphy LR, DeJoy DM. Safety climate dimensions associated with occupational

exposure to blood-borne pathogens in nurses. Am J Ind Med 1999; Suppl(1):122-24.


Chapter 1

8

Without knowing it, you’ve probably already started toward building a safety culture. See, this

safety stuff isn’t that difficult! First up: Increase safety awareness. Post safety posters and

warning signs (especially those required by OSHA). Let everyone know your practice is dedi-

cated to a safe workplace by posting a statement signed by top leadership that declares your

facility’s commitment to the safety and well-being of all employees. Hang it near your OSHA

poster or where other important office notices are placed. Also keep a copy of the statement in

your safety manual.

WHAT POSTERS ARE REQuIRED?

QuesTion:.What posters do I have to put up in the office? Where do they go? I keep getting mail

with solicitations to buy my required workplace postings, but I’m not sure if it’s worth the expense.

Can’t I get these from the government for free?

Answer:.Although.most.of. the.workplace.posters.are.beyond.the.scope.of.OSHA,. the.safety.

officer.often.ends.up.with.bulletin.board.duty..As.you.know,.any.posters.that.are.required.can.

be.obtained.for.no.cost. through.the.appropriate.government.agencies..Lots.of. times,.you.can.

download.and.print.them.yourself.instantly,.so.you.don’t.even.have.to.wait.for.them.to.come.in.

the.mail..Hang.copies.of.each.poster.in.a.conspicuous.place.where.they.are.visible.to.employees.

and.applicants.for.employment..The.main.benefit.of.purchasing.a.composite.poster.from.a.poster.

company.is.that.it.includes.all.the.notices.in.less.space.than.it.would.take.to.post.each.one.indi-

vidually..However,.since.it’s.all.one.piece.of.paper,.when.one.notice.changes,.you’ll.have.to.replace.

the.whole.thing.as.opposed.to.just.the.changed.part..The.following.are.the.basic.requirements,.

although.not.every.employer.will.meet.the.requirements.for.each.posting:.

•Job.Safety.&.Health.(OSHA)

•Equal.Employment.Opportunity

•Fair.Labor.Standards.Act—Minimum.Wage

•Employee.Right.for.Workers.with.Disabilities/Special.Minimum.Wage.poster

•Family.&.Medical.Leave

•Uniformed.Services.Employment.and.Reemployment.Rights.Act—Veteran.Rights

•Employee.Polygraph.Protection

•Federal.contractor.posters

To.find.out.if.your.practice.meets.the.requirement.for.a.specific.poster,.such.as.having.government.

contracts.or.employing.more.than.50.employees,.check.out.the.Department.of.Labor’s.Small.Busi-

ness.Resource.Center.Poster.Page.at www.dol.gov/oasam/programs/osdbu/sbrefa/poster/matrix.

htm.or.do.a.Google.search.for.“Department.of.Labor’s.Small.Business.Resource.Center.poster.”



9

We’ve already talked about creating a safety committee, and I know you’re working on getting

it rolling. Another area you’ll want to consider is how you can give everyone in your office a

“safety voice.” Can you use current meetings? A bulletin board? A comment box? The chain of

command? (Ensure no repercussions!) Ultimately, your goal is for safety to become everyone’s

responsibility, not just yours. You must ensure everyone is comfortable voicing his or her safety

concerns.

When safety-driven changes take place, spell them out to everyone. Tell and show your staff

what the new process will be and, most importantly, explain why. Do it up front and jot down

some notes concerning the training and who attended for your safety records. Don’t wait,

because when the rumor mill starts to crank up regarding upcoming changes, people naturally

tend to resist them even when the improvements are obvious. For example, if you aren’t sure

what new device you’ll be buying, communicate with staff members that several items are

being evaluated and solicit their thoughts. Use your safety committee members to spread the

word, get input, and squash misinformation. Don’t forget to keep it upbeat and keep staff

members motivated by celebrating your safety success stories.

Resources

There are two main types of help you’ll find that you need as a safety officer: information on

what to do and support to get it done.

InformationAs I mentioned, OSHA is a federal agency, part of the U.S. government. However, some states

(and even territories) have decided that they want to maintain jurisdiction over workplaces

within their boundaries, which is perfectly fine with the federal government as long as the

state’s plans are approved by federal OSHA and are at least as restrictive as the federal law.

TAke noTe: States can make more requirements for safety but never less than what is

required by the federal government.

There are currently 25 states and territories with their own OSHA plan. Of these 25 states and

territories, 23 have jurisdiction over both private and public (state and local government) sector

employees. Connecticut and New York plans cover public employees only, while federal OSHA

covers private-sector employers. If the state or territory is not listed in Figure 1.1, federal OSHA

assumes jurisdiction.


Chapter 1

10

Figure 1.1

states with osha-approveD plans

Alaska Arizona California Connecticut*

Hawaii Indiana Iowa Kentucky

Maryland Michigan Minnesota Nevada

New.Mexico New.York* North.Carolina Oregon

Puerto.Rico South.Carolina Tennessee Utah

Vermont Virginia Virgin.Islands Washington

Wyoming

*.State.plan.applies.to.public.employees.only.

TAke noTe: Most states with their own OSHA plans have standards identical to the

federal OSHA standards at least regarding requirements for physician offices. However,

if you are operating under an OSHA state plan (see the list in Figure 1.1), you can

contact your state for information to determine if its requirements differ from that

of federal OSHA.

Usually, a quick Internet search of your state’s name and OSHA (e.g., “California OSHA” or

“New York OSHA”) returns the state website as a top hit. Look for a “.gov” domain in the

search result and look at “.com” results critically—many are trying to sell you something you

probably don’t need! You’ll be better off searching using the term “medical” with OSHA when

looking for products to assist you.

The Internet is truly the information superhighway. You could certainly find everything you

need to be a great safety officer out there—if you had unlimited time, which is usually the

kicker. (For a list of top online safety resources for the OSHA safety professional, see Figure

1.2.) Sorting through the minutiae of regulations is incredibly time consuming. Also, because

the laws are designed to apply to broad situations, including everything from construction sites

to industrial manufacturing to hospitals, exactly what you need for your medical practice isn’t

listed specifically. That leaves the dreaded “interpretation trap.” You read the regulation one

way, the manager at your practice another, the doctor a third, and the OSHA inspector who just

walked in the door has another idea entirely.



11

Figure 1.2

Favorite online resources

website Description

Government Agencies

www.osha.gov Federal.OSHA.home.page

www.osha.gov/SLTC/healthcarefacilities OSHA.Healthcare.Facilities.home.page

www.cdc.gov U.S..Department.of.Health.and.Human..Services,.CDC.

www.cdc.gov/sharpssafety The.CDC.Workbook for Designing, Implement-ing, and Evaluating a Sharps Injury Prevention Program.

www.cdc.gov/niosh NIOSH

www.cdc.gov/niosh/topics/healthcare NIOSH.Healthcare.Workers.home.page

www.cdc.gov/niosh/topics/bbp NIOSH.Bloodborne.Infectious.Diseases.home.page

www.dir.ca.gov/DOSH/PubOrder.asp California.OSHA.publications.download.page.(alphabetical.by.topic);.some.information.is.California-specific,.like.the.long.best-practices.guide.on.bloodborne.pathogens,.but.some.isn’t—especially.check.out.“Ergonomics.for.Very.Small.Business.Health.Care.(Poster)”.under.“E”

www.flu.gov Influenza.resources

www.epa.gov U.S..Environmental.Protection.Agency.(EPA)

www.epa.gov/epahome/comments.htm#11 EPA.regional.office.and.state.contacts

private organizations

www.hcpro.com/safety HCPro.Safety.home.page,.with.a.link.to.a.blog,.books,.and.training.products

www.isips.org International.Sharps.Injury.Prevention.Society,.with.news.articles,.safety.product.listings,.and.real-life.“it.happened.to.me”.needlestick.incident.stories

www.aorn.org Association.of.periOperative.Registered.Nurses;.enter.“sharps.safety”.in.the.search.box.to.find.a.PowerPoint®.presentation.on.sharps.safety.in.the.operating.room.and.other.resources

www.healthsystem.virginia.edu/internet/epinet

International.Healthcare.Worker.Safety.Center

www.nursingworld.org American.Nurses.Association;.check.out.the.“safe.needles”.section.under.the.occupa-tional.health.tab


Chapter 1

12

To help practices correctly apply the regulations to their situations, OSHA has published some

online e-tools. OSHA recently expanded its Compliance Assistance Quick Start e-tool by adding

a Healthcare Industry Module. This tool is a free compliance assistance resource offered by

OSHA. The module uses eight steps to help employers understand OSHA regulations applicable

to the healthcare industry. Although the Health Care Industry Quick Start is a great resource,

most folks that I’ve spoken with left the website feeling a bit overwhelmed by all that is re-

quired to stay compliant. In fact, what you’ll find there is also contained here in a more user-

friendly format.

Another offering you’ll find at OSHA.gov and through OSHA state plan offices is individualized

service offered through OSHA’s consultative services. The following is direct from its published

information: “The On-Site Consultation Service offers free and confidential advice to small and

medium-sized businesses in all states across the country. ... Consultation services are totally

separate from enforcement and do not result in penalties or citations.”4 Offering to help employ-

ers comply is part of OSHA’s reinvention move. OSHA’s goal is a partnership with employers in

creating safe workplaces as opposed to acting solely as a compliance-oriented organization.

One requirement of this consultative program is that you commit to correcting any issues that

are identified on a given timeline. If you don’t, you may find yourself facing a punitive inspec-

tion or fines. If you are thinking, “Hmm, correcting our problems sounds easy enough, and we

could get a free consultant in here to tell me what to do,” stop right there! This isn’t necessarily

a magic bullet to fix all your problems, and you will still be the one doing all the work. I have

known folks at practices who have had great experiences with the on-site consultation service,

but there are horror stories out there, too. And remember, a visit by the OSHA consultative

services doesn’t “guarantee that your workplace will pass an OSHA inspection.”5

In looking for help online, another thing you’ll find a lot of are companies promising to solve

all your OSHA compliance problems for the low price of [fill in the blank here]. Whether they

are selling a book, an on-site visit, an OSHA compliance package with medical waste pickup,

or a training program, you’ve got to figure out the answers to the following two main questions:

• Does this company know what it is doing?

• Is the service provided reasonable for the fee charged (and can I get the funds

authorized)?



13

wArninG: Unfortunately, the old roman adage caveat emptor (“let the buyer beware”)

should be one of your guiding principles when selecting OSHA compliance materials.

How can you tell whether an OSHA compliance company or product is any good? As the

safety officer, you will be on the hook, so determining who to trust can be daunting.

Use the following questions to help you ascertain whether a company or product is worth

bringing on board:

• Is the product or service offered related to OSHA for a medical facility?

• Does the company specialize in helping medical practices or is healthcare just one

of the many fields serviced?

• Is your facility located in a state with a state-specific plan? If so, is the product or

service customized to your state? Some companies seem to think that California is

the only state that needs to be mentioned, which is probably not a good indicator

of their knowledge level. (Note: Since the state plan requirements are nearly iden-

tical for medical offices, this isn’t a deal breaker, but you can test the representa-

tive’s understanding of the matter to see if you’re impressed.)

• Does the representative look and sound professional and knowledgeable?

• What is the website like? Is there a blog, white papers, articles, or another forum

where you’re able to get a feel for the advice given? Is it grammatically correct?

Are there typos? (Note:No website in this day and age should raise a red flag!)

• What is the company’s track record?

• How long has the company been in business?

• Who are its satisfied customers?

• Are there any free trials or samples you can review?

• Is a money-back guarantee offered?

If you like where we’ve gone so far, HCPro offers complete OSHA compliance and training

solutions. Check out these offerings on the safety page at www.hcpro.com/safety.


Chapter 1

14

Do you need a consultant? It depends, but most medical office hazards are fairly straightfor-

ward, and you most likely have, or will learn in this book, the skills you need to assess the

hazards in your facility and to implement the necessary controls. The checklists and resources

provided are designed to be your go-to source to tell you exactly what to do so you can manage

your safety program without a consultant. Still, some practices feel better with the reassurance

of a “professional” to come in and say everything looks okay. Other folks don’t have time to

take on all the responsibilities and find that outsourcing is a valuable investment (if the funds

are available).

You’ve gotten the go-ahead to hire an OSHA consultant to help get your safety program in

order. Lucky you! But how do you find a good one? Networking with other safety officers can

help you find good local resources. Contacting your local medical society or practice manage-

ment association is another source for referrals. The employee health department of a nearby

hospital may be able to direct you to a resource. Review articles on safety in medical practice

publications, taking note of the authors who mesh with you. Writing in local publications is

often a way for consultants to get their name out there. Review websites of associations that

specialize in health education, practice management, state medical associations, and the like.

Look for training resources, compliance assistance, and similar terms.

If your practice is going to hire a consultant, consider all the purchasing questions listed earlier,

as well as the following factors:

• His or her formal education and professional qualifications/memberships.

• References from previous clients.

• Experience working in a similar facility to your own. Has he or she solved the

type of problems you are confronting?

• Who will be your main contact? Is the consultant a sole proprietor, or will you be

receiving service from one of his or her employees?

• If an employee will be helping you, ask for his or her credentials and whether you

may meet him or her in advance.

• What is the rate of staff turnover?

• What is your gut feeling? Is he or she easy to get along with? Does he or she seem

to understand what you need?



15

Once you find someone who seems like a good fit, nail down what is expected. Consider the

following questions:

• Will the consultant provide written safety policies, including the appropriate cop-

ies of the OSHA regulations?

• Will he or she provide forms to document employee vaccinations/declinations?

Accidents/incidents? Safety meetings?

• Will he or she provide and document training for your staff?

• Will he or she provide mock inspections with written follow-up reports?

• Will he or she be on call to guide you after an exposure incident?

• What other assistance will be provided?

• What are the customary fees? Are there any additional charges for follow-up calls

or visits? Get this information in writing by drawing up a contract.

OSHA PROGRAM FROM MY MEDICAl-WASTE COMPANY

QuesTion: Our medical-waste-pickup company offers an OSHA program. It sure looks easy! It

takes care of everything for you: the OSHA manual, annual site inspection, training on CD, the

works. It even has a guarantee about OSHA fines! Should I use it, or is it too good to be true?

Answer:.The.largest.medical-waste-disposal.company.in.the.United.States.offers.this.service,.

as.do.several.smaller.competitors..The.big.dog’s.program.is.on.point.OSHA-wise.and.will.keep.

you.in.compliance..However,.after.looking.into.alternatives,.many.practices.have.discovered.that.

it.is.exorbitantly.expensive..The.waste-pickup.companies.do.a.good.job.of.bundling.their.services.

to.make.it.difficult.to.see.just.how.much.you.pay.for.the.OSHA.program.portion..Get.quotes.and.

compare. the.cost.of. the. full.enchilada. to.a.basic.plan. that. just. includes.getting.your.medical.

waste.disposed.of,.and.you’ll.see.how.much.extra.you’re.paying.and.can.decide.whether.it’s.a.

good.return.on.your.dollar.or.if.you’ll.get.more.bang.for.your.buck.elsewhere..


Chapter 1

16

Support

You will need support to achieve your goals and develop a strong safety culture. How easy or

difficult this will be depends on whether you have top management buy-in. If not, this is the

very first step that you should try to accomplish.

wArninG: If top managers aren’t on board, safety and health will compete against

patient care and profitability, a battle that will drive you crazy and detract from your

effectiveness.

Top leaders ideally will understand the need for a safe workplace and be on board with changes

to get there. If they aren’t quite seeing it yet, the best way to convince leaders to support safety

is to show the costs of an unsafe work environment. These expenses fall into three categories:

direct costs, indirect costs, and intangible organizational costs.

Direct costs are expenses that can be traced directly to (or identified with) a specific activity or

incident. For example, usual expenses after a sharps injury include the cost of:

• Baseline and follow-up laboratory testing of an exposed healthcare worker and

testing the source patient

• Postexposure prophylaxis (PEP) and other treatment that might be provided

However, if there are complications, such as side effects from PEP, these can add additional

costs to managing needlestick injuries. Some of the second-most common and expensive

on-the-job injuries are musculoskeletal disorders from repetitive strain or lifting.

When an injury occurs, whether it be sharps related, a chemical exposure, or even a twisted

ankle, work hours and wages normally used for employees to accomplish their day-to-day job

responsibilities are diverted to incident-related treatment and follow-up. These indirect costs

include time spent:

• Reporting the incident and filling out required paperwork

• Receiving initial and follow-up treatment

• Contacting the source patient and obtaining consent for testing (in the case of an

exposure incident)



17

• Dedicated to the incident if one of your providers performs the employee’s evalu-

ation and treatment (if an outside provider gives this service, his or her bill would

be a direct cost)

• Dedicated to the incident if one of your providers performs the source patient’s

evaluation and treatment (if an outside provider gives this service, his or her bill

would be a direct cost)

Thinking about how an accident or incident takes everyone away from their busy schedules at

the most inopportune moment can be quite eye opening for those who haven’t thought about

the indirect costs before. You can almost imagine as the row of dominos starts to fall how the

diverted workload affects the entire facility.

Several additional organizational costs can result from an unsafe work environment or specific

incident. These include:

• Employee’s fear of the employer

• Lack of trust among staff members

• Heightened rates of staff turnover

• Fear and anxiety from worrying about the possible consequences of an exposure

• Societal cost associated with an HIV or hepatitis C seroconversion

• Possible loss of a worker’s services in patient care after seroconversion

• Burden of medical care after a seroconversion

• Legal expenses

If all these theoretical costs aren’t hitting home with your management team, use the appendix

in the CDC’s Workbook for Designing, Implementing, and Evaluating a Sharps Injury Prevention

Program at www.cdc.gov/sharpssafety. The included worksheets can help you calculate specific

costs at your facility that are associated with sharps-related accidents.


Chapter 1

18

Top 10 Safety Officer Action Items

1. Get organized.

2. Obtain top management buy-in. Have leaders show their support publicly at

meetings, through memos, etc.

3. Involve others in your organization through a safety committee.

4. Give everyone a safety voice. Actually listen to what they have to say. Show

interest and ask for more details. Sometimes, complaints/concerns might seem

silly to you but are very important to the employee who brings them up. When

you don’t listen, frustrated employees call OSHA, and you get inspected.

5. Raise safety visibility. Use posters, talk up success stories, send out a safety

scorecard via e-mail, and post safety awareness briefs in places people will be

forced to read them (like in the toilet stalls). Try things to see what works for

your facility.

6. Bring your OSHA manual to staff and safety committee meetings to reinforce

that your practice has a tangible safety program that contains policies to ensure

staff safety.

7. Rushing, or feeling time pressure, is often a root cause of accidents. Encourage

everyone to work with deliberate motions, especially when times are super busy.

8. Conduct a short safety-related demonstration at weekly/monthly staff meetings.

Use practical lessons and employee interaction to reinforce employee safety.

9. Take notes and document everything.

10. Take a deep breath and try not to take criticisms personally.

References

1.. “OSH.Act.of.1970,”.OSHA,.www.osha.gov.

2.. “OSHA.35-Year.Milestones,”.OSHA,.www.osha.gov/as/opa/osha35yearmilestones.html.

3. Workbook for Designing, Implementing, and Evaluating a Sharps Injury Prevention Program,.CDC,.www.cdc.gov/

sharpssafety/pdf/sharpsworkbook_2008.pdf.

4.. “OSHA.Small.Business:.On-Site.Consultation,”.OSHA,.www.osha.gov/dcsp/smallbusiness/consult.html.

5.. “OSHA.Small.Business:.How.to.Get.Started.with.Consultation,”.OSHA,.www.osha.gov/dcsp/smallbusiness/

consult_gettingstarted.html.

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