10 Steps To OSHA Compliance

Occupational Safety & Health Administration (OSHA) compliance is not an option in your clinic. Here are 10 steps to getting your practice OSHA compliant.


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Do you have OSHA labels on every secondary container or spray bottle? If not, each violation could cost you.

Do all staff members wear appropriate protection equipment against radiation and chemicals? If not, each violation could cost you.

Do you eat or drink in the treatment area or the laboratory? If so, each violation could cost you.

The average fine levied by the federal Occupational Safety and Health Administration is around $1,000.

Sterile Trays

Phil Zeltzman

Cold sterile trays are more strictly regulated than you might think.

OSHA compliance is not an option. It should not be an item on your never-ending to-do list. It’s the law.

Few clinics are fully OSHA compliant, and arguably fewer are aware of the new Globally Harmonized System of

Classification and Labeling of Chemicals — also known as the GHS protocols. GHS is a modification of the 1994 Hazard Communication Standard, to make it more understandable and uniformly recognized nationally.

Karen Andrews, an office manager, technician and OSHA consultant in Michigan, shares 10 easy and affordable ways to become OSHA compliant.

1) Labels

The GHS enhancement regarding hazardous chemicals in the workplace is taking place right now.

The OSHA website explains that the standard that gave workers the right to know now gives them the right to understand.

OSHA wants all employees to not just be told about hazardous chemicals, but to fully understand their dangers and how to be safe around them.

Older labels with diamonds and a number-coding system will be changing to actual pictograms—for example, a small picture of a man with a face mask.  Signs will also say DANGER/WARNING.  And surprise: Employees must be trained by Dec. 1, 2013.

During the GHS phase-in period, you may continue to use the Diamond Code NFPA labels (as long as they convey the required information), new GHS labels, or both.

If you have not yet started to update bottles (or have never had labels), start now.  Also update your material safety data sheets, or MSDS, with the newly named safety data sheets, or SDS. They have a standardized 16-section layout. Safety Data Sheets are not widely available at this time, but that will change as the June 2015 date for transitioning to GHS nears.

Which containers should have an OSHA label? Any  “secondary container” in which a chemical has been placed.  

Under GHS, “‘Secondary containers’ will be called ‘workplace containers.’” Every time you pour a chemical, such as alcohol or peroxide, from a large bottle into a spray bottle, you are creating a secondary container. Any chemical that is reconstituted or diluted, such as chlorhexidine, is also deemed to be in a secondary container.

Fire extinguisher

phil zeltzman

Other required signage includes five extinguishers and an eyewash station.

The new bottle needs a label which is filled out by hand, usually with a permanent marker. It should mention the chemical name and a pictogram (if using GHS labels) that shows the personal protection equipment required, or the Diamond Code appropriately filled in if using National Fire Protection Association labels.

Because labels have a sneaky tendency to peel off, simply cover them with clear packaging tape to increase their longevity, or laminate them and attach them with rubber bands.

2) Documents

It is wise to have signed documents to show attendance at OSHA training meetings. They certify that employees have been trained and understand the risks, that they know the proper use of hazardous chemicals and protective equipment.

All new employees should be trained in OSHA compliance. All employees should receive refresher training once a year.

Other necessary documents are health records and emergency contact information for each employee. The hospital should also have OSHA 300 forms in place, a hazard communication plan and an annual safety review.

The OSHA 300 form is a yearly detailed log of reportable injuries that have occurred.  The OSHA 300A form is a summary of these injuries. The 300A form must be posted in a conspicuous place, such as the break room, from Feb. 1 to April 30.

3) Radiation Protection

It is surprising how frequently employees (including veterinarians) take radiographs with little to no protection.

Yet OSHA and common sense require that they wear a gown, leaded gloves, a thyroid shield and, ideally, leaded glasses. An even better situation would be one where no employee has to be in the radiology room; sedated patients can often be placed in a position that does not require human “holders.”

Any human being who is present while radiographs are taken must wear a dosimeter, also known as a radiation badge. Dosimeters are sent in quarterly to be read. The radiation exposure report from the dosimeter company should be posted for all employees to see.

The risks of radiation are well known: fetal malformations and cancer top the list. Protect yourself accordingly.

4) Protection Control

In veterinary medicine, we don’t need to worry quite as much as in human medicine about contact with blood and ill patients. Still, we must take zoonotic diseases seriously.  Employers need to teach workers how to stay safe around animals that are thought to have zoonotic diseases, including rabies.

Eyewash Station

Phil Zeltzman

An eyewash station is an OSH requirement.

Have an accident investigation plan in place, including forms to be filled by the employer and signed by the affected employee. Name the witnesses. They can all be interviewed in hopes of preventing future similar accidents.

You also need an evacuation plan in place and the process should be rehearsed.

5) Food And Drinks

Food and drink should not be  in any area of the hospital except the  designated break or lunch room.

As for drinks, OSHA allows only a closed container with a small opening; a coffee cup with a lid, a covered bottle or a cup with a straw is acceptable. An open cup is not.

Lab samples, medications and diagnostic chemical reagents should not be kept in the same refrigerator as human food or drinks.

6) Hearing Protection

When should you wear hearing protection? If you can’t hold a normal conversation because of excessive noise such as barking, you should wear ear protection. You don’t need anything fancy or expensive; simple foam ear plugs are enough.

7) Signage

Signs are another important OSHA requirement to notify employees of specific health hazards such as radiation, laser and anesthetic gases. Exits should be clearly marked. But  “not an exit” signs are not mandatory.

You may also want to consider signs designating “employees only” areas because pet owners should never be allowed in radiology. Clients may be allowed in the treatment area for visitation, but that is up to your own hospital policy. Other required signage includes fire extinguishers and an eyewash station.

8) Eyewash

An eyewash station is an OSHA requirement. It should be located close to the area where there is the most risk of getting chemicals into your eyes. Most of the time, this means that your eyewash station should be located in the lab. Eyewash stations should be tested monthly.

9) Shoes

Formalin

Phil Zeltzman

Toxic products, like formalin, need to be handled with the appropriate personal protection equipment. 

OSHA requires shoes that are completely enclosed and that are impermeable.

They should be enclosed to prevent stabbing your foot with a sharp object, such as a needle on a syringe. And they should be impermeable to prevent foot contamination by chemicals, as well as contamination of skin by feces or urine containing zoonotic agents (think leptospirosis and hookworms).

10) A New Requirement In 2014

A complete list of hazardous chemicals present in your clinic, with the exception of tablets, is required. The list should mention four pieces of information for each product: name, chemical, manufacturer name and manufacturer contact phone number.

You now also need an index of every hazardous chemical in your practice to make it easy to find information when something needs to be referenced. You can create that list by looking at your MSDS and SDS documents, or you can purchase one from an OSHA specialist.

OSHA requires that employers protect their employees from workplace hazards that can cause injury. It is a legal requirement, not an option.

If you’ve been trying to launch an OSHA program in your practice with no success, you may want to consider investing in an OSHA specialist such as Karen Andrews.

Kelly Serfas, a certified veterinary technician in Bethlehem, Pa., contributed to this article.

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