OSHA Presented by Jennifer Thompson – HR Consultant

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The Occupational Safety and Health Administration (OSHA) was founded April 28, 1971 with a mission to save lives, prevent injuries and protect the health of American Workers. OSHA and their state partners, combined with the efforts of employers, safety and health professionals, unions and advocates, have had a dramatic effect on workplace safety.

WHAT IS OSHA?

OSHA REQUIREMENTS FOR MEDICAL OFFICES:

• Exposure Control Plan (ECP)

• Hazard Communication

Program (HCP)

• X-ray Exposure

• Emergency Exit Routes

• Electrical Safety Requirements

• Reporting Requirements

EXPOSURE CONTROL PLAN (ECP)

Per OSHA regulations, this

plan is designed to

eliminate or minimize

occupational exposure

to bloodborne pathogens

• Effective Employee Training • Provide employee training at time of hiring

• Recommended to provide additional up-to-date training periodically

throughout the year.

• Universal Precautions • An approach to infection control to treat all human blood and bodily

fluids as if it were infected with HIV, HBV(Hepatitis B Virus) or other

bloodborne pathogens

• Engineering and Work Practice Controls • Designed to eliminate or reduce exposure to chemical or physical hazards

through the use/substitution of engineered machinery/equipment

• Personal Protective Equipment • Protective eye wear

• Protective clothing

• Gloves

• Hepatitis B Vaccination • Must be provided at no cost to exposed employees

WHAT’S REQUIRED FOR YOUR ECP?

• Post-exposure & Follow-up • Must be post-exposure follow up with any affected employees

• Must be provided at no cost to the employee • Includes, but is not limited to, office visits, lab work, etc.

• Use of Labels and Color-coding • Properly identify hazardous waste, sharps containers, specimens,

contaminated laundry, etc.

• Proper Containment of Regulated Waste • Regulated waste includes, but is not limited to, blood-soaked gauze,

blood or other potential infectious material in suction containers

• Per OSHA regulations, must be contained and disposed of in a certain

manner

For More Information:

https://www.osha.gov/Publications/osha3186.pdf(Sample Plan)

https://www.osha.gov/Publications/osha3187.pdf (A Guide to Compliance)

WHAT’S REQUIRED FOR YOUR ECP? (cont’d)

This program is also called the “Employee Right-to-Know” Plan. A HCP is a program provides proper warnings and safety precautions needed for dealing with hazardous chemicals in the workplace.

• All chemical containers must be labeled

• All employees are provided access to Material Safety Data Sheets (MSDS)

• Information on potentially hazardous chemicals and how to work safely with

them.

• Employers must provide effective training to employees for

potential exposure to hazardous chemicals and what to do

if exposed.

For More Information:

https://www.osha.gov/Publications/osha3187.pdf

https://www.osha.gov/Publications/osha3186.pdf

HAZARD COMMUNICATION PROGRAM (HCP)

THE HCP STATES:

X-RAY EXPOSURE & SAFETY

OSHA requires:

All equipment used for x-rays be clearly

identified.

These areas should be restricted to trained

employees only to minimize employee

exposure.

All equipment and rooms used for radiology

must be clearly labeled with “Caution Signs”

X-RAY EXPOSURE & SAFETY (cont’d)

OSHA requires:

Employees working in these areas must wear

personal radiation monitors

Film badges

used for monitoring cumulative radiation

dose due to ionizing radiation, usually

processed for reading once a month.

Worn close to the chest area

Pocket dosimeters

a pen-like device that measures the

cumulative dose of ionizing radiation

received by the device, usually over one

work period

Worn in the pocket

Film Badges and Pocket Dosimeters

Film Badge

Pocket Dosimeter

• Emergency Exit Routes are requirements for providing safe and

accessible building exits.

• Emergency exits must be kept clear of debris at all times.

• Arrange emergency exits so staff and patients won’t have to travel

toward a hazardous area.

• If a door can’t be used as an emergency exit, use “Not an Exit”

signage.

• Exit Signs must be clearly visible.

EMERGENCY EXIT ROUTES

• Post evacuation routes in several visible areas throughout the office.

• Hold emergency evacuation drills during office hours with employees and patients

periodically throughout the year.

For more information, contact your local fire department, insurance agent, OSHA

office, or visit https://www.osha.gov/OshDoc/data_General_Facts/emergency-exit-

routes-factsheet.pdf

• OSHA requires that electrical equipment be clearly

tagged with the following information:

Inspection date

Due date of next inspection

The inspectors initial

• If equipment fails/malfunctions, it must be labeled

“Out-of-Service”.

• Employers must provide effective training on use of

electrical equipment to all employees.

• Electrical equipment should not be used by

anyone not properly trained to do so.

ELECTRICAL SAFETY REQUIREMENTS

• Medical and dental offices are currently exempt from maintaining an official log of reportable injuries and illnesses (OSHA Form 300), however it is strongly recommended that you maintain records

• All employers (including medical and dental) must report any work-related:

REPORTING REQUIREMENTS

Fatality within 8 hours

The hospitalization of three or more employees within 24 hours

Amputations within 24 hours

Loss of an eye within 24 hours

• Operators at 1-800-321-OSHA (6742) will direct you to the appropriate state/federal

office.

• Mississippi and Louisiana are covered under Federal OSHA Guidelines for reporting

and record keeping.

• The reporting requirement may differ for state-run OSHA plans. Visit

https://www.osha.gov/dcsp/osp/states_contact.html to see a complete list of state run

OSHA plans and contact information for those states.

OSHA Changes and Reporting • Why? Publicly “Nudge” Employers to Focus on Safety

• Fatality, Significant Injuries, Restricted Duty, or Loss Consciousness

• Who is not subject to the Record Keeping?

• https://www.osha.gov/recordkeeping/ppt1/RK1exempttable.html

• Effective January 1, 2017 Submit/Post Electronically

• Whoops, OSHA wasn’t Ready so now it is July 1st December 1st

• 3 Ways to Submit Data

• Manually

• CSV File Upload

• A created file that is uploaded to the OSHA website

• Automated Tracking System using an Application Program Interface (API)

• Anti-retaliation Protections and Notice (300A Feb 1 – Apr 30)

• Allows employees to file complaints with OSHA if they feel they are being that they have experienced discrimination or retaliation for exercising there right to report a work-related injury

• New Filing Deadlines for Certain High-Risk Industries 3/2/19

• https://www.osha.gov/recordkeeping/NAICScodesforelectronicsubmission.pdf

Screenshot of OSHA Online Tracking

Screenshot of OSHA Online Tracking

Contact Information

Jennifer Thompson

HR Consultant

877-759-5765 Ext. 1292

jennifer.thompson@morganwhite.com