Annual OSHA Check-Up

Most healthcare providers are aware of the need to comply with the Occupational Health And Safety Act (OSHA) to assure, so far as possible, safe and healthful working conditions for their office staff. Here is a quick checklist of the annual OSHA requirement:

  • Training. Annual training; more often if employees’ responsibilities increase, change or exposes them to new hazards.
  • Hazard Analysis. Providers should try to evaluate their practice from a fresh perspective at least on an annual basis. Evaluate the hazards, attempt to eliminate them and if not possible, implement  engineering controls to reduce occupational exposure to the hazards. Providers should also analyze engineered controls for their effectiveness and replace or modify them as necessary throughout the practice to reduce occupational hazards such as exposure to bloodborne pathogens and other potentially infectious materials, electrical hazards, walking surfaces, exposure to hazardous chemicals, x-rays and lasers, and other potential workplace hazards. Providers should be open to suggestions from staff members.
  • Bloodborne Pathogens Standard. Pursuant to the Bloodborne Pathogen Standard, a practice must have a written Exposure Control Plan (ECP) that is updated at least annually and whenever necessary to include new or modified tasks and procedures. Among other things, check for the following: 1) are universal precautions followed? 2) are labels or color-coding for sharps disposal boxes, containers for regulated waste, contaminated laundry, and certain specimen in place? 3) did provider or staff find safer sharps that can be implemented?  Document annual considerations and implementations of appropriately available and effective safety medical devices designed to eliminate occupational exposure.
  • Hazard Communication. Does the practice have a list of hazardous substances? Do chemical substances carry labels that communicate the specific health and physical hazards? Have efforts been made to become familiar with the revised hazard communication standards that will be aligned with the United Nations’ Globally Harmonized System of Classification and Labeling of Chemicals. The new hazard communication standard goes into effect in 2016.
  • Workplace violence.  Providers should know that workplace violence is a recognized occupational hazard in the healthcare industry. OSHA encourages employers to conduct an analysis of worksites and adopt and implement a written Workplace Violence Prevention Program.
  • Record Keeping. Providers should comply with OSHA’s record keeping requirement and verify that they have the required medical and training records.

It is important to note that other applicable OSHA standards that apply to medical offices have additional requirements that need to be analyzed, maintained and updated, where applicable, on an annual basis.

Our office consults medical practices on OSHA compliance matters, assists with annual training and provides legally required OSHA manual and compliance materials.  For more information, please contact us here.