Occupational Safety and Health Administration (OSHA) can be overwhelming, no question about it. All those rules and regulations, the need to dot every “i” and cross every “t.” It’s enough to make you want to run and hide.
The good news is, it doesn’t have to be. This article may help alleviate some of the anxiety arising from preparing for an OSHA inspection by breaking down the regulations into easily digestible information.
The importance of OSHA security
Being OSHA-compliant can provide a good sense of security by relieving the fear of OSHA inspections. While the number one source of OSHA complaints comprises disgruntled ex-employees, we are seeing a new trend in grievances being filed by dissatisfied clients. Depending on what side of the complaint you’re on, OSHA has made it very simple for anyone to file a grievance: people can simply log in online, check off some boxes of suggested violations, and submit it anonymously. All OSHA complaints are followed up, either by a letter (if you are lucky) or an on-site inspection.
Being OSHA-compliant is critical, since noncompliance can lead to potential fines. Consider the average fine for a small-animal practice is approximately $37,560. This OSHA checklist provides the basics of what you need to be an OSHA-compliant clinic—and attain OSHA security.
To comply with OSHA, businesses must meet the following basic requirements:
- identify potential hazards;
- put into place protection from those potential hazards;
- train employees on the existence of potential hazards and the protections available; and
- document everything.
This seems simple enough, but pulling it off can leave one confused and mired in piles of paperwork, especially as you try to sort out fact from fiction regarding various opinions of what you should or shouldn’t do. Let’s take a closer look at the checklist.
1) Inspect and document
OSHA requires businesses to document an initial inspection of the workplace, and then go through a checklist every year to ensure any changes are addressed. Your documentation should be organized and clearly identified. You might want to call it something along the lines of “OSHA Safety Self-inspection Manual.”
So what are you documenting in your inspection? This is an actual physical inspection of your clinic to determine potential hazards and record the corrective actions that need to be taken to fix them. For example, you may notice moldy ceiling tiles from a leaking roof. These would be listed as a potential hazard. (OSHA considers the tiles a respiratory hazard because of the mold.) Your documentation would indicate the leak in the roof is to be repaired and the moldy ceiling tiles are to be replaced. Another example would be observing dusty, dirty ceiling vents and fans, which are also considered respiratory hazards. Here, the practice owner or manager must record the corrective action is to vacuum and clean the vents and fans, and change filters more frequently (monthly is good).
Other items in your clinic inspection include potential hazards from work activities. This is where personal protective equipment (PPE) protocols come in. Consider an employee performing a dental that creates a potential hazard due to aerosolization of bacteria. The protocol requires anyone working in dental wear specific PPE, such as a face shield or other eye protection, mask, and gloves. PPE protocols are important to document to protect employees from potential occupational hazards.
The following are additional OSHA requirements regarding documentation:
Document the names of members of your safety committee and monthly meeting minutes
Practice owners are required to create a safety committee and record its members’ names and monthly meeting minutes. Further, they must designate an employee as the OSHA captain/safety officer to oversee the clinic’s OSHA program. Committees usually include a safety captain(s), the practice manager, the owner, and depending on the size of a clinic’s staff, leaders from each area, such as head of kennel, tech rep, front office rep, etc. Delegating and sharing assignments works best, but sometimes we are simply limited by size.
Monthly safety committee meetings should include a review of any injuries that have happened since the previous meeting, updates on the treatment received, and what training is required to prevent similar injuries. This is the time to review any other issues regarding the clinic’s safety program.
Document emergency action plans
OSHA requires businesses document emergency action plans for situations such as fires, tornadoes, blizzards, or civil emergencies that would require your staff to either shelter-in-place or evacuate. OSHA also necessitates designating a meeting place, establishing protocols for alerting emergency response personnel, and creating a system for contacting owners of hospitalized patients.
Document workplace injuries
Workplace injuries—including those requiring simple first-aid and no further medical treatment—also must be documented to ensure protection of worker’s comp rights, should the injury need follow-up care. For those injuries requiring medical treatment, record those in the summary of workplace injuries that is posted on the employee information board. All injuries get recorded as they occur throughout the year, with the annual summary prepared and posted the following year between Feb. 1 to April 30. This informs staff of all workplace injuries and allows them to study the results.
Document OSHA training program information
Be sure to create procedures for keeping track of staff training (e.g. sign-in sheet). In addition, OSHA requires a clinic keep records of what was covered during training and the dates on which it occurred. Consider using a training verification form that lists specifically what was presented and have all employees sign off on the training they received.
Document OSHA protocols addressing the following:
Your manual should include sections on each of the following areas:
- general safety;
- workplace violence;
- active shooter protocols;
- biological hazards, such as blood-borne pathogens (human) and zoonotic hazards (animals);
- chemical hazards: labels, charts, and safety data sheets (SDS), chemotherapy, radiology;
- animal behavior and handling; and
- other clinic-specific hazards.
In addition, it should also include general emergency action plans for fires, weather emergencies, and civil emergencies, for example.
2) Personal protective equipment
Be sure to document what PPE is needed for what procedures (e.g. X-rays require the use of radiological gowns, gloves, and thyroid protectors). In addition, maintenance of equipment requires us to radiograph gowns, thyroid shields, and gloves annually to ensure no damage that would render them non-protective.
3) Training records
Employees are required to be trained on all potential hazards, including active shooter response scenarios. This should be done when they’re hired and then once a year as a refresher. Keep in mind training can be accomplished using any format you prefer (e.g. via video, online, live, on-demand) as long as it covers all required areas. OSHA isn’t concerned with how you do it or who does the training. Further, there are no requirements for specific training licenses.
4) Eyewash station
OSHA requires veterinary practices or hospitals install eyewash stations that are easily accessible and are located in areas where eye splash may occur. A sink in the treatment area is a good place for one. (Sink-mounted eyewash stations are permitted.) Eyewash stations must be flushed weekly. Further, maintenance records must be kept.
5) Fire extinguishers
Requirements are straightforward when it comes to fire extinguishers. First, their location must be documented and signs indicating where they are must be displayed. Further, gauges must be checked every month and initials recorded on the tag verifying the gauge was in fact checked. Fire extinguishers should be placed in all of the following locations:
- the kitchen;
- the lab;
- treatment area;
- near the surgery suite;
- lobby; or
- a hallway near each exit.
6) Emergency action plan
We live in an unpredictable world and one that can be disrupted from one moment to the next. As such, OSHA requires veterinary practices designate a meeting place in case of evacuation, develop protocols for various weather and civil emergencies, and create procedures for evacuating patients. While patients are a top priority, human safety comes first.
7) Chemical safety
Make sure you are no longer using the hazardous materials identification system (HMIS) or National Fire Protection Association (NFPA) labels with colors and numbers on diamond shapes. OSHA requires the use of globally harmonized system (GHS) labels. Further:
- GHS training must be included in the chemical safety section of your OSHA manual
- GHS labels must be used on secondary containers
- Chemotherapy training and PPE with specific protocols for handling waste are indicated
- Your safety data sheet library must be easily accessible by all and in the current GHS format. You may save your library to a computer as long as you have a backup USB drive.
8) Electrical safety
To ensure electrical safety, access to electrical panels must be free and clear of obstructions; any outlets located near a water source are required to be ground-fault circuit interrupters (GFCIs); flammables should not be stored near gas water heaters; and only use heavy-duty extension cords and power strips.
9) General hazards
There are numerous general hazards within a clinic. As such, use signage to prevent slips and falls on wet floors and address ergonomic issues such as proper restraint and lifting. Workplace violence, including active shooter scenarios, also should be included in OSHA training.
10) Animal behavior and handling
Animal handling and behavior should be addressed in staff training. It is critical to remind your staff to watch the animal’s body language to prevent bite injuries from fearful dogs or cats. Many clinics are undergoing Fear Free training and certification. This is an excellent resource for your staff, clients, and patients.
This list may look overwhelming, but once you are done documenting what is required, it is easy to maintain on an annual basis.
When in doubt, refer to OSHA experts with knowledge of the intricacies of the veterinary profession and the uniqueness of how the regulations apply to us. There are definite differences in rules for medical, dental, and veterinary settings. Being aware of these differences will save time and money, and potential fines. And don’t forget you have to comply with OSHA regulations, even if you have only one employee. Refer to this checklist to simplify this process. Stay safe out there!
Chery F. Kendrick, DVM, MPVM, is the owner of Vet OSHA, an Occupational Safety and Health Administration (OSHA) management consulting firm for the veterinary industry. She facilitates monthly Mastermind groups for practice managers and safety captains, as well as speaks and leads Mastermind groups at conferences and association meetings nationwide. Dr. Kendrick provides OSHA materials and services, as well as represents clinics during OSHA inspections, handling all aspects of the inspection and response to complaints, along with the appeal. She can be reached at firstname.lastname@example.org.