Compliance Corner: OSHA Written Standards and Annual Training

You have patients in the waiting room, two patients in exam rooms, your receptionists has a question for you, and right as your cell phone goes off, your assistant is asking you about a prescription. And when the sun sets, you are returning calls to patients and colleagues. OSHA compliance may not be at the top of your to-do list.

Nearly all employers have to comply with the Occupational Safety and Health Act of 1970. That means that providers must have a written program in place that prevents injuries and protects workers. For medical and dental practices, the written program must address at least the following standards:

  1. Bloodborne Pathogens
  2. Hazard Communication
  3. Ionizing Radiation
  4. Emergency Planning, Exit Routes
  5. Electrical Safety

These five OSHA standards address important workplace safety requirements for physician and dental practices. Each identify the hierarchy of controls for situations most likely encountered by workers in a medical office setting, such as, needlesticks and other sharps related injuries, the need for appropriate personal protective equipment and proper labeling of contaminated waste, and the use of universal precautions. Additionally, requirements include a response to pathogen exposure, hepatitis B vaccination, safe handling of x-rays, proper handling of hazardous chemicals, proper electrical wiring for equipment, emergency planning, workplace violence, record keeping and training.

Having a written manual, however, is not enough to ensure compliance. In addition to written protocols, healthcare providers are required to have, at a minimum, annual training for employees and provide training when a new employee joins the practice, an employee’s responsibilities change or there is a new regulation.

All it takes is a complaint from an employee or a patient to trigger an inspection from OSHA. The Agency told American Medical Association news recently that “[i]n small medical practices, more than half of all OSHA inspections occur as a result of complaints to OSHA.” With limited exceptions, inspections are conducted without advance notice.

Providers should be aware that retaliation against employees who complain is prohibited.