Compliance Corner

OSHA Compliance and the Ophthalmology Practice

Is your staff fully appraised of safety regulations?

By Jolynn Cook

Part one of a two-part series

The mission of the Occupational Health and Safety Administration (OSHA) is to save lives, prevent injuries and protect the health of America’s workers. OSHA covers private sector employers and employees in all 50 states and other US jurisdictions, either directly through Federal OSHA or through an OSHA-approved state program. This, the first of two articles, will help guide the reader through the hundreds of pages of regulations that deal with the OSHA mandated Exposure Control Plan (ECP). Please note that state plans may require training in addition to what’s referred to in this article.

Complying with Programs

Specifically, we want to provide assistance with meeting the requirements of the OSHA bloodborne pathogens standard and the hazard communication program, which meets the requirements of OSHA’s hazard communication standard.

One of the primary areas identified for the safety of health-care workers is OSHA’s bloodborne pathogens standard. This standard applies to employees who provide care and services for patients, as these employees are at risk of exposure to blood or other potentially infectious materials.

In addition to the bloodborne pathogens standard, OSHA’s hazard communication standard protects employees who may be exposed to hazardous chemicals in the office or the ASC. Both standards require the practice to develop written documents to explain how the practice establishes methods to comply with the standards, provides training to employees, and protects the health and safety of workers. These two standards are the most applicable to an ophthalmic practice.

The information provided here should not be considered a definitive interpretation of all OSHA requirements. The reader should consult the OSHA bloodborne pathogens and hazard communication standards in their entirety for specific compliance requirements at the OSHA website.

Keep in mind that OSHA safety programs and the associated training should be under the direction of a qualified individual (e.g., a registered nurse). It is important to provide this individual with access to current educational programs and to review this information annually to be sure any updates are included in your program. Of course, remember to document all training and educational programs.

Make Information Available

The administrator or supervisor is responsible for keeping OSHA documents and information readily accessible to all employees at all times. If your practice has an ASC, the same OSHA requirements will apply there. You may consider providing copies via an online manual depending on employees’ access to computers. OSHA standards in the ASC are typically included in an ASC’s policy and procedure manual.

Developing an ECP

The first step in developing an OSHA program is to assess potential risks and training needs for employees who have potential exposure risk during daily routines. Like many other tasks we do each day, “if it isn’t documented, it wasn’t done.” The most comprehensive documentation method is to provide an overview of compliance and training. To this end, OSHA requires the practice to develop an ECP. The OSHA Web site provides user-friendly models of ECPs that can be customized to ophthalmic practices. However, it takes a commitment of time and work to complete this process. These model documents can be used as templates for writing or revising an ECP and hazard communication program for the ophthalmic practice or ASCs, but you must tailor them to the specific requirements of your office. OSHA’s sample plans contain all elements required by the bloodborne pathogens and hazard communication standards, so the information should not be changed nor should you eliminate any items when converting them for use in your practice. Your written plans must be accessible to all employees,

Note: The full text of these two OSHA standards, including the requirement for written documents, is found in 29 CFR 1910.1030 and 29 CFR 1910.1200, respectively. You can access the full text of these standards through the OSHA Web site (www.osha.gov) by using the alphabetical index at the top of the page. OP

Ms. Cook is the Administrator of the Laurel Eye Clinic and the Laurel Laser & Surgery Centers. A Certified Ophthalmic Executive and a Certified Administrator Surgery Center (CASC.), Ms. Cook is a registered nurse and also has a degree in Health Care Administration.