If the Occupational Health and Safety Adminstration made a surprise inspection of veterinary clinics, most would fail to be in compliance, says Chery F. Kendrick, DVM, of Kendrick Technical Services in Knoxville, Tenn.
One common violation she sees as a provider of OSHA-compliance services for veterinarians is lack of or insufficient labeling of secondary containers—those used to hold chemicals in other than their original containers. These can include spray bottles of disinfectant and cold sterile soak for instruments.
Another sticking point: If inspectors find that even one employee doesn’t know how to access the clinic’s Material Safety Data Sheets, it is a violation.
The fine for potentially harming the health of your employees is $7,000 per incident. “If you have 25 unlabeled containers, that’s 25 times $7,000, or $175,000,” Dr. Kendrick says. “Even if you appeal and get your fines reduced by 95 percent, $8,750 is still a significant amount of money.”
Inspectors may use formulas of comparative risk-taking and take into account the number of employees and the number of days they were at risk by using the unlabeled containers.
OSHA’s stringent documentation requires practice-specific safety manuals and training records, as well as the display of federal and state posters.
Fines for paperwork violations—no record of employee training or no written safety manual, for instance—start at $1,000 per incident. And again, the formula of comparative risk could be applied to the number of days the employees were not trained or the safety manual was unavailable.
Kendrick’s best advice for veterinarians is to know OSHA regulations. “It is in the veterinarian’s best defense to research the law,” she says.
She warns that some inspectors try to apply human standards to animal practices. Veterinarians don’t have to comply.
Kendrick says OSHA inspectors get bonuses based on fines issued to veterinarians.
She suggests that practitioners always appeal fines. “You never want to pay the fine right away,” she says.
“The veterinary industry is a new ‘deep pocket’ for OSHA,” Kendrick says. “Veterinarians are finding themselves more targeted than ever before.
“OSHA is an excellent and necessary regulatory agency,” she notes. “It provides for the safety of employees and provides a route for correction if an employer refuses to comply. Workplace deaths and injuries are down 80 percent since OSHA began working so hard to keep employees safe.”
OSHA inspections are always a surprise, she says. “They can’t tell you when they are coming, though you can call for an inspection yourself.”
No fines are assessed when management calls and infractions or violations are found. Veterinarians are expected to bring their clinic back into compliance.
Many veterinarians hire consultants to set up their practices to OSHA standards.
Services may include inspection of the property, presentation of a safety program, setting up and maintaining MSDS databases and emergency action plans, and proper labeling of secondary containers.
Staff training, follow-up or online training, as well as manuals and training tools, may be included. Costs are usually less than $5,000 for an initial set-up.
“Find someone with proven veterinary knowledge,” Kendrick says, “not just someone who thinks they know about veterinary clinics because they are from the human medical arena.”
OSHA courses are available online and at seminars.
Stericycle’s SteriSafe.com creates OSHA safety plans through a step-by-step, practice-specific online process.
“After considering the monetary risks of non-compliance,” says Bob Tangredi, corporate vice president of Stericycle Inc. of Lake Forest, Ill., “being proactive about maintaining OSHA compliance and protecting the health and safety of every employee is critical.
“While many facilities run tight ships, gaps in compliance are a daily occurrence,” he says. “Busy administrators may be unaware of the many federal mandates of compliance.”
Dick Best, Stericycle’s director of OSHA compliance services, says he consistently finds three potential risks for worker safety: animal bites, zoonotic diseases and hazardous chemicals.
“Veterinarians are great at training and educating new hires,” Best says. “But then most offices get busy. So there’s always room for improvement in the safety arena.”
Louise Dunn of Snowgoose Veterinary Management Consulting in Greensboro, N.C., reminds veterinarians that their staffs don’t have to allow an OSHA inspection if the practice owner is not on site. “Instruct your team to ask them to come back when you will be present,” Dunn says. “It’s a good idea to have that in writing in your procedure manual.
“Every veterinarian knows about OSHA,” she says. “It’s not that they ignore the regulations; they don’t realize the power this agency can have over their practices.”
Dunn notices that many practices she visits, from Alaska to California to Florida, have several OSHA issues in common.
“One out of four offices will not know the regulations about radiation safety badges, a clear citation,” she says. “They either don’t wear the badges over protective gear or don’t wear them at all when taking radiographs.”
Another common violation: lab or exam room refrigerators that house animal medications often hold employees’ soda cans or lunches. “You can’t store human food in the same refrigerator,” she says.
Dunn suggests that procedures for handling animal bites become part of the hospital’s standard operating manual.
On the positive side, she notices that more offices require the wearing of gloves when handling blood or fecal samples, and most offices display their OSHA-mandated posters.