OSHA, MSDS, and OSHA, MSDS, and other letters you other letters you

should knowshould know

OSHAOSHA Occupational Safety and Occupational Safety and

Health AdministrationHealth Administration www.osha.govwww.osha.gov Can be stiff penalties for non-Can be stiff penalties for non-

compliance (up to $70,000)compliance (up to $70,000) OSHA ProgramOSHA Program

Has 4 basic parts:Has 4 basic parts: Mandatory administrative Mandatory administrative

tasks and posting of required tasks and posting of required notices.notices.

Evaluation of hazards and Evaluation of hazards and selection of appropriate and selection of appropriate and useable protection useable protection equipment.equipment.

Development and Development and enforcement of written plans enforcement of written plans for managing hazardous for managing hazardous materials or dangerous tasks.materials or dangerous tasks.

Documented, appropriate Documented, appropriate training of employees on the training of employees on the hazards associated with their hazards associated with their job. job.

OSHA and veterinary OSHA and veterinary medicinemedicine

Compressed air Compressed air cylinderscylinders Should be stored in a Should be stored in a

dry, cool place, away dry, cool place, away from potential heat from potential heat sources.sources.

Must be secured in an Must be secured in an upright position by upright position by holder, bracket, chain holder, bracket, chain or strap. or strap.

Sign should identify Sign should identify where these cylinders where these cylinders are kept. are kept.

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Food and BeveragesFood and Beverages Consumption of food Consumption of food

and beverages must and beverages must be limited to areas be limited to areas free of toxic and free of toxic and biologically harmful biologically harmful substances.substances.

Staff lunches, drinks, Staff lunches, drinks, condiments and condiments and snacks must be stored snacks must be stored in an area free from in an area free from biological or chemical biological or chemical hazards.hazards.

Housekeeping and Housekeeping and MaintenanceMaintenance

Need to establish a good cleaning Need to establish a good cleaning routine so that hospital will stay clean routine so that hospital will stay clean even during busy times.even during busy times.

Should be free from physical and Should be free from physical and health hazardshealth hazards

Should include tasks to be performed:Should include tasks to be performed: DailyDaily WeeklyWeekly MonthlyMonthly Semi-annuallySemi-annually

Administrative OSHA Administrative OSHA PoliciesPolicies

““It’s the law” poster must be It’s the law” poster must be prominently displayed. prominently displayed.

If OSHA lets you know of an If OSHA lets you know of an inspection, then you must notify inspection, then you must notify employees of the date and time employees of the date and time that they may meet the that they may meet the compliance officer.compliance officer.

Copies of citations for violations Copies of citations for violations must be posted for at least 3 days must be posted for at least 3 days or until violation is corrected.or until violation is corrected.

Businesses with more than 11 Businesses with more than 11 employees must maintain a log of employees must maintain a log of related injuries and illnesses and related injuries and illnesses and an injury and illnesses incident an injury and illnesses incident report. report.

Appropriate warning signs should Appropriate warning signs should be displayed.be displayed.

Written plans for preventing fire, Written plans for preventing fire, handling chemicals, and handling chemicals, and prevention injury are required for prevention injury are required for all workplaces with more than 10 all workplaces with more than 10 employees.employees.

Employer’s RightsEmployer’s Rights Rights:Rights:

Enforce workplace rulesEnforce workplace rules Be present during an inspection or Be present during an inspection or

investigation.investigation. Require a warrant for inspection.Require a warrant for inspection. Request postponement of inspection.Request postponement of inspection. Expect that no trade secrets will be divulgedExpect that no trade secrets will be divulged Consult an attorneyConsult an attorney See any complaintsSee any complaints Have employees interviewed at a time that does Have employees interviewed at a time that does

not interfere with staff member’s jobnot interfere with staff member’s job Right to appeal findingsRight to appeal findings

Employer’s Employer’s ResponsibilitiesResponsibilities

ResponsibilitiesResponsibilities Provide a hazard free workplaceProvide a hazard free workplace Set and enforce safety rulesSet and enforce safety rules Provide Personal Protective Equipment Provide Personal Protective Equipment

(PPE) with proper instructions (PPE) with proper instructions Provide training on any potential Provide training on any potential

workplace hazardsworkplace hazards

Staff’s RightsStaff’s Rights Work in a hazard free workplaceWork in a hazard free workplace Be informed of their rights under OSH ActBe informed of their rights under OSH Act Be informed of known hazardsBe informed of known hazards Be provided with training and instruction on how to Be provided with training and instruction on how to

use PPEuse PPE View and have copies of OSHA standardsView and have copies of OSHA standards Access personal medical records that may be Access personal medical records that may be

maintained as a part of businessmaintained as a part of business Be present during safety testingBe present during safety testing Present complaints to employer or OSHA when Present complaints to employer or OSHA when

hazard is suspected.hazard is suspected. Speak with compliance officer privately during Speak with compliance officer privately during

inspection.inspection.

Staff ResponsibilitiesStaff Responsibilities

Read the OSHA posterRead the OSHA poster Comply with standardsComply with standards Follow rules and regulationsFollow rules and regulations Wear PPE while workingWear PPE while working Report hazardous conditionsReport hazardous conditions Report any job-related injury or illness Report any job-related injury or illness

to employer and seek treatmentto employer and seek treatment Cooperate with OSHA compliance Cooperate with OSHA compliance

officers officers

OSHA InspectionsOSHA Inspections Know who is allowed to admit inspectors.Know who is allowed to admit inspectors. On-site inspection must be triggered by at least On-site inspection must be triggered by at least

one of the following:one of the following: Written complaint and OSHA must believe that a safety Written complaint and OSHA must believe that a safety

or health danger exists.or health danger exists. Complaint must allege that physical harm has occurred Complaint must allege that physical harm has occurred

and that hazards still exists.and that hazards still exists. Must allege imminent dangerMust allege imminent danger Employer failed to provide adequate response to a Employer failed to provide adequate response to a

compliantcompliant Business has history of failure-to-abate citations during Business has history of failure-to-abate citations during

last 3 years.last 3 years. Discrimination issues for filing complaints about OSHA Discrimination issues for filing complaints about OSHA

standardsstandards

How to Survive How to Survive InspectionInspection

Be polite and cooperativeBe polite and cooperative Verify credentialsVerify credentials Request that inspection take place at a more Request that inspection take place at a more

convenient timeconvenient time Make time for inspectionMake time for inspection Take notes and pay attention during inspectionTake notes and pay attention during inspection Have employees “stand-by” during inspectionHave employees “stand-by” during inspection Show officer only what he or she asks to seeShow officer only what he or she asks to see Have copies of hospital policies readily Have copies of hospital policies readily

availableavailable Correct any violations immediatelyCorrect any violations immediately

Anesthetic GasesAnesthetic Gases

Practices are expected to properly store, Practices are expected to properly store, label and use chemicals safely.label and use chemicals safely.

Should help to keep employee exposure Should help to keep employee exposure under allowed limits.under allowed limits.

Should:Should: Have periodic monitoring of equipment and Have periodic monitoring of equipment and

exposure levels.exposure levels. Have proper ventilation.Have proper ventilation. Have proper scavenging systems.Have proper scavenging systems. Train staff appropriately. Train staff appropriately.

Masking and Tank Masking and Tank InductionInduction

Make sure masks and tanks have tight-fitting Make sure masks and tanks have tight-fitting seals and are connected to scavenging seals and are connected to scavenging systems.systems.

Use proper fitting masks for patientsUse proper fitting masks for patients Only use masking procedures when medically Only use masking procedures when medically

indicatedindicated Remember to turn on oxygen, place mask, Remember to turn on oxygen, place mask,

then turn on gas, reverse order to remove then turn on gas, reverse order to remove mask.mask.

Simple Anesthetic Exposure Simple Anesthetic Exposure BadgesBadges

Used to help test Used to help test exposure to exposure to anesthetic gases.anesthetic gases.

Can be obtained from Can be obtained from several labs.several labs.

Should be worn by a Should be worn by a typical employee on typical employee on typical workload day.typical workload day.

OSHA recommends OSHA recommends testing every 6-12 testing every 6-12 months.months.

Waste Anesthetic Gas Waste Anesthetic Gas ScavengersScavengers

Active ScavengersActive Scavengers Fan in a box that creates Fan in a box that creates

vacuumvacuum Cost from $400-$1000Cost from $400-$1000 Will need maintenance and Will need maintenance and

replacementreplacement Manual activation, must be Manual activation, must be

turned on turned on Passive ExhaustPassive Exhaust

Channels gases through a Channels gases through a tube from patients tube from patients diaphragmdiaphragm

Limited distanceLimited distance AbsorptionAbsorption

Charcoal absorption Charcoal absorption canisterscanisters

Should be monitored and Should be monitored and changedchanged

Animal Handling and Animal Handling and HusbandryHusbandry

Animal related Animal related injury number one injury number one injury in a vet injury in a vet clinicsclinics

Potential of Potential of zoonotic diseaseszoonotic diseases

Training is a must Training is a must with new with new employees!!employees!!

Bathing, Grooming and Bathing, Grooming and InsecticidesInsecticides

Wear appropriate PPE.Wear appropriate PPE. Make sure that wet areas or Make sure that wet areas or

dangerous areas are identified.dangerous areas are identified. All chemicals should be stored and All chemicals should be stored and

labeled properly.labeled properly. Anything changed from one Anything changed from one

container to another should be container to another should be properly labeled. properly labeled.

Common Zoonotic Disease Common Zoonotic Disease FactorsFactors

Be diligent with protection when handling known disease Be diligent with protection when handling known disease carriers.carriers.

Always wear PPE when unsure of a disease status.Always wear PPE when unsure of a disease status. Common diseases include:Common diseases include:

Bacterial infectionsBacterial infections RingwormRingworm ParasitesParasites MangeMange LeptospirosisLeptospirosis ToxoplasmosisToxoplasmosis CryptospiridiosisCryptospiridiosis PlaquePlaque Lyme DiseaseLyme Disease BrucellosisBrucellosis Cat Scratch Disease (Bartonella henselae)Cat Scratch Disease (Bartonella henselae) RabiesRabies

HIV/ AIDs RiskHIV/ AIDs Risk

Always use precautions when Always use precautions when dealing with other team members dealing with other team members bodily fluids.bodily fluids.

Person with HIV or AIDs may be Person with HIV or AIDs may be more susceptible to other zoonotic more susceptible to other zoonotic diseases.diseases.

Can an employer ask HIV status?Can an employer ask HIV status?

Noise HazardsNoise Hazards Generally the kennel Generally the kennel

area.area. If prolonged If prolonged

exposure, may be exposure, may be harmful.harmful.

Should be identified Should be identified by a sign and ear by a sign and ear protection should be protection should be provided.provided.

Sound Panels may Sound Panels may be used to help be used to help reduce noise.reduce noise.

Rabies Vaccine for Rabies Vaccine for EmployeesEmployees

OSHA does not OSHA does not require the vaccine require the vaccine but it is highly but it is highly recommended.recommended.

Most vet schools Most vet schools require the vaccine as require the vaccine as a pre-emptive strike a pre-emptive strike against exposure.against exposure.

Should be considered Should be considered by all employees that by all employees that have significant have significant contact with animals. contact with animals.

Personal HygienePersonal Hygiene Regular Hand washing is strongly Regular Hand washing is strongly

encouragedencouraged Before eating, drinkingBefore eating, drinking Before smokingBefore smoking Before leavingBefore leaving Before and after using restroomBefore and after using restroom After handling specimensAfter handling specimens After handling animalsAfter handling animals

How to perform a thorough How to perform a thorough Hand WashingHand Washing

Wet both forearms with warm waterWet both forearms with warm water Apply a generous amount of disinfecting soap in Apply a generous amount of disinfecting soap in

the palm of one handthe palm of one hand Using a vigorous motion, scrub each side of the Using a vigorous motion, scrub each side of the

hand, between the fingers and at least halfway up hand, between the fingers and at least halfway up the armthe arm

If there is debris under the fingernails, use a hard If there is debris under the fingernails, use a hard pick or stiff brush to remove matierial while soap pick or stiff brush to remove matierial while soap is still on the handsis still on the hands

Rinse both hands thoroughly with warm or tepid Rinse both hands thoroughly with warm or tepid waterwater

Dry both hands and arms with a towel or air dryerDry both hands and arms with a towel or air dryer

Physical InjuriesPhysical Injuries

BitesBites ScratchesScratches Use appropriate PPEUse appropriate PPE Have adequate training to avoid Have adequate training to avoid

situationssituations Prevention is key! Prevention is key!

ChemicalsChemicals Five Specific requirements that veterinary Five Specific requirements that veterinary

clinic must follow:clinic must follow: 1. Practice must have a written chemical plan.1. Practice must have a written chemical plan. 2. A complete list of all hazardous chemicals 2. A complete list of all hazardous chemicals

must be maintained.must be maintained. 3. The practice must maintain a library of 3. The practice must maintain a library of

material safety data sheets.material safety data sheets. 4. All containers of hazardous chemicals must 4. All containers of hazardous chemicals must

be properly labeled.be properly labeled. 5. The practice must train all staff members 5. The practice must train all staff members

on the dangers and safety aspects of the on the dangers and safety aspects of the chemicals. chemicals.

Ethylene OxideEthylene Oxide Form of sterilization procedure.Form of sterilization procedure. Not used as commonly today.Not used as commonly today. MUST be used with a ventilation system.MUST be used with a ventilation system. Link with cancer.Link with cancer. Fines associated with trying to shortcut the Fines associated with trying to shortcut the

process. process. OSHA requires monitoring to take place. Will OSHA requires monitoring to take place. Will

use bade devices to detect exposure levels. use bade devices to detect exposure levels. Detailed written plan also required. Detailed written plan also required. Make sure to follow manufacturer instructions. Make sure to follow manufacturer instructions. Make sure to follow proper storage and training Make sure to follow proper storage and training

recommendations. recommendations.

Ethylene Oxide Ethylene Oxide ContinuedContinued

Emergency PlansEmergency Plans If exposed, adequate fresh air is the If exposed, adequate fresh air is the

treatment of choice. treatment of choice. If irritation persists, consult physician.If irritation persists, consult physician. If in contact with liquid form, removal all If in contact with liquid form, removal all

contaminated clothing and wash skin contaminated clothing and wash skin surfaces for 15 minutes.surfaces for 15 minutes.

If in contact with eyes, use eyewash for If in contact with eyes, use eyewash for at least 15 minutes and consult an at least 15 minutes and consult an ophthalmologist. ophthalmologist.

Bulk ChemicalsBulk Chemicals If more than 20 gallons, If more than 20 gallons,

should consult with fire should consult with fire department about department about storage. storage.

Should make sure areas Should make sure areas with large amount of with large amount of chemicals are properly chemicals are properly identified.identified.

Should have plans in Should have plans in place if emergency place if emergency occurs for avoiding occurs for avoiding areas with bulk areas with bulk chemicals.chemicals.

Chemical Safety TrainingChemical Safety Training

Conduct training as soon after the Conduct training as soon after the person is hired as possible. person is hired as possible.

Prepare workbook or handout for Prepare workbook or handout for training. training.

Include worker’s rights.Include worker’s rights. Provide hospital policy copies.Provide hospital policy copies. Stress importance of PPE.Stress importance of PPE.

Determining Chemical’s Determining Chemical’s HazardHazard

Health Hazard: chemical for which there is evidence that acute Health Hazard: chemical for which there is evidence that acute or chronic health effects may occur in exposed employees. Falls or chronic health effects may occur in exposed employees. Falls into following categories:into following categories:

CarcinogenCarcinogen ToxicToxic IrritantIrritant SensitizerSensitizer Any agent which damages the lungs, skin, eyes or mucous Any agent which damages the lungs, skin, eyes or mucous

membranes.membranes. Physical Hazard: chemical that is:Physical Hazard: chemical that is:

Combustible liquidCombustible liquid Compressed gasCompressed gas ExplosiveExplosive FlammableFlammable Organic peroxideOrganic peroxide OxidizerOxidizer PyrophoricPyrophoric UnstableUnstable Water-reactiveWater-reactive

Hazardous chemical Hazardous chemical LabelsLabels

All chemicals should be All chemicals should be properly labeledproperly labeled

Should always label Should always label secondary containerssecondary containers

No special labels are No special labels are required, but should be required, but should be uniform throughout uniform throughout practice. practice.

If can’t physically label, If can’t physically label, use a color code system. use a color code system.

If is a prescription, no If is a prescription, no additional information is additional information is needed than is what is needed than is what is found on a customary found on a customary prescription label. prescription label.

Formalin/FormaldehydeFormalin/Formaldehyde

Make sure properly identified and stored.Make sure properly identified and stored. Keep least amount on hand as possible. Keep least amount on hand as possible. Wear Appropriate PPE. Wear Appropriate PPE.

Material Safety Data Material Safety Data SheetsSheets

Produced by the Produced by the chemical chemical manufacturer.manufacturer.

Should be kept Should be kept together in one together in one location.location.

Should be indexed in Should be indexed in a systematic way.a systematic way.

Call distributor or Call distributor or manufacturer if need manufacturer if need a MSDS.a MSDS.

ExemptionsExemptions Hazardous waste- by EPA not OSHAHazardous waste- by EPA not OSHA Tobacco productsTobacco products Wood or wood productsWood or wood products Articles (what is product of hazardous materials)Articles (what is product of hazardous materials) Food, drugs, cosmetics or alcoholic beverages Food, drugs, cosmetics or alcoholic beverages

that are packaged to be sold to consumers and that are packaged to be sold to consumers and that are not opened in the hospital.that are not opened in the hospital.

Foods, drugs, cosmetics intended for personal Foods, drugs, cosmetics intended for personal consumption by the employee while in the consumption by the employee while in the workplace.workplace.

Any common cleaner that is is used in way as is Any common cleaner that is is used in way as is used by average consumer.used by average consumer.

Any drug sold in final solid form to client for Any drug sold in final solid form to client for immediate consumption by patient. immediate consumption by patient.

Written Chemical PlanWritten Chemical Plan

Should be reviewed and revised Should be reviewed and revised often.often.

Should include hazardous material Should include hazardous material and what PPE is recommended for and what PPE is recommended for use while using this chemical. use while using this chemical.

Should describe training offered to Should describe training offered to employees on a chemical.employees on a chemical.

Should outline MSDS system. Should outline MSDS system.

Eye wash devicesEye wash devices Mounted and eyewash Mounted and eyewash

bottles. bottles. Mounted stations should Mounted stations should

not be on faucet used for not be on faucet used for bathing animals because bathing animals because of exposure to other of exposure to other chemicals.chemicals.

Device should not be Device should not be locked. locked.

Hand held bottles are Hand held bottles are designed for foreign designed for foreign bodies and not chemicals. bodies and not chemicals.

Employees should be Employees should be trained as to location and trained as to location and operation. operation.

ElectricityElectricity

Hazards include electrical shock and Hazards include electrical shock and physical hazards.physical hazards.

May not have ground for electrical plugs.May not have ground for electrical plugs. May use extension cords, etc.May use extension cords, etc. Inspect if circuit breakers trip often.Inspect if circuit breakers trip often. Check for damage or burnt cords and Check for damage or burnt cords and

outlets routinely. outlets routinely. OSHA requires adequate and reliable OSHA requires adequate and reliable

lighting for all exitslighting for all exits

ErgonomicsErgonomics

Repetitive movements. Repetitive movements. Have computers and office Have computers and office

equipment comfortable and able to equipment comfortable and able to prevent injury.prevent injury.

OSHA requires adequate and OSHA requires adequate and reliable lighting for all exits.reliable lighting for all exits.

One- Hand Recapping of One- Hand Recapping of NeedlesNeedles

Step 1Step 1 - Place the cap for the needle on a - Place the cap for the needle on a hard surface like the countertop. Do not hard surface like the countertop. Do not hold the cap with your hand. hold the cap with your hand.

Step 2 -Step 2 - Hold the syringe by the barrel in Hold the syringe by the barrel in your fingertips with the needle pointing your fingertips with the needle pointing away from you.away from you.

Step 3 - Step 3 - Place your fingertips on the Place your fingertips on the counter and "slide" your hand along the counter and "slide" your hand along the counter until the needle is inside of the counter until the needle is inside of the cap.cap.

Step 4 -Step 4 - "Pick up" the cap with the "Pick up" the cap with the needle. You may now use your other needle. You may now use your other hand to completely seat the cap on hand to completely seat the cap on the hub.the hub.