Follow these steps to ensure your practice is compliant with workplace safety requirements.

An Occupational Safety and Health Administration (OSHA) assessment for a small medical practice typically involves identifying and addressing potential hazards in the workplace to ensure the safety of employees and patients.

Here are six common steps you can follow to perform your own OSHA-related assessment.

1. Identify OSHA requirements

Review OSHA requirements that apply to many healthcare employers, such as the bloodborne pathogen standard and hazard communication. This includes what and when personal protective equipment (PPE) should be used and how to properly dispose of sharps and contaminated medical waste.

2. Hazard communication program

Develop a program that includes policies and procedures for identifying and controlling hazards. This includes keeping updated safety data sheets for all chemicals used in the workplace, training employees on the proper handling, storage, and disposal of hazardous chemicals, and posting required OSHA notices in the workplace.¹

3. Exposure control plan (ECP)

The required elements of an ECP include exposure determination, which identifies (1) job classifications with occupational exposure and (2) tasks and procedures with occupational exposure. OSHA's bloodborne pathogens standard applies to all employers who have employees with occupational exposure (i.e., reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of the employee's duties). Methods of ECP compliance include:

1. Universal precautions
2. Engineering and work practice controls (e.g., safer medical devices, sharps disposal containers, and hand hygiene)
3. PPE
4. Housekeeping, including decontamination procedures and removal of regulated waste.

Of note, as of Jan. 1, 2015, physicians’ offices are exempt from OSHA's injury and illness recordkeeping requirements, regardless of size.¹

4. Emergency action plan (EAP)

OSHA recommends that all employers have an EAP that describes the actions employees should take to ensure their safety in a fire or other emergency.¹ Develop and implement an EAP that includes procedures for evacuation, sheltering, and response to medical emergencies. OSHA has an eTool to help.² Many practices updated their EAPs during the recent COVID-19 public health emergency, which required exhaustive response measures for an ongoing pandemic.

5. Survey the workplace

Identify additional hazards in the workplace, such as the potential for slips, trips, and falls, and develop a plan to address them.¹ This should encompass fire safety measures, including the availability and accessibility of fire extinguishers, evacuation routes, an inspection of electrical equipment such as cords and space heaters to prevent electrical hazards, and preparation for providing first aid treatment.¹

6. Provide employee training

Train employees on the hazards they may encounter in the workplace and how to protect themselves.¹ This includes training on the risks of bloodborne pathogens and methods to prevent exposure. Review the proper use, maintenance, and disposal of PPE, such as gloves, masks, and eye protection. OSHA provides online training fact sheets and booklets that support staff training,¹ such as the OSHA booklet on PPE.³ Training may include regular fire drills, implementing proper ergonomics to prevent illness or injury, and other applicable health and safety training.⁴

Note that OSHA requirements can vary depending on the state where a practice is located. Local OSHA offices offer free training resources, guidance, and evaluations to ensure compliance with regulations.

Conclusion

It's important for medical practices to stay informed about OSHA regulations and guidelines and to make safety compliance an integral part of their practice culture. Use the recipe above to kick-start or review your existing OSHA program. OP

References

1. Occupational Safety and Health Administration. Compliance Assistance Quick Start. https://www.osha.gov/complianceassistance/quickstarts/health-care. Accessed December 8, 2023.

2. Occupational Safety and Health Administration. Create Your Own Emergency Action Plan (EAP). https://www.osha.gov/etools/evacuation-plans-procedures/expert-systems/create-eap. Accessed December 8, 2023.

3. Occupational Safety and Health Administration. Personal Protective Equipment. https://www.osha.gov/sites/default/files/publications/osha3151.pdf. Accessed December 8, 2023.

4. Occupational Safety and Health Administration. Clinicians. https://www.osha.gov/clinicians. Accessed December 8, 2023.

Laurie K. Brown, MBA, COMT, COE, CPC, CPMA, CPSS, LSSYB, is a senior consultant with BSM Consulting in Tucson, AZ. She has experience in the ophthalmic industry holding managerial, clinical, and surgical roles for more than 30 years.