What are your responsibilities as an employer?

If you are an employer covered by the Occupational Safety’s Health Administration (OSHA) Act of 1970, you must provide your employees with jobs and a place of employment free from recognized hazards that are causing, or are likely to cause, death or serious physical harm. Among other actions, you must also comply with the OSHA statutory requirements, standards, and regulations that, in part, require you to do the following:

  • Provide well-maintained tools and equipment, including appropriate personal protective equipment
  • Provide medical examinations
  • Provide training required by OSHA standards
  • Report to OSHA within 8 hours accidents that result in fatalities
  • Report to OSHA within 8 hours accidents that result in the hospitalization of three or more employees
  • Keep records of work-related accidents, injuries, illnesses—and their causes—and post annual summaries for the required period of time.
  • Post prominently the OSHA poster (OSHA 3165) informing employees of their rights and responsibilities
  • Provide employees access to their medical and exposure records
  • Do not discriminate against employees who exercise their rights under the OSHA Act
  • Post OSHA citations and abatement verification notices at or near the worksite
  • Abate cited violations within the prescribed period
  • Respond to survey requests for data from the Bureau of Labor Statistics, OSHA, or a designee of either agency

What are your rights as an employer?
When working with OSHA, you may do the following:

  • Request identification from OSHA compliance officers
  • Request an inspection warrant
  • Be advised by compliance officers of the reason for an inspection
  • Have an opening and closing conference with compliance officers
  • Accompany compliance officers on inspections
  • Request an informal conference after an inspection
  • File a Notice of Contest to citations, proposed penalties, or both
  • Apply for a variance from a standard’s requirements under certain circumstances
  • Be assured of the confidentiality of trade secrets
  • Submit a written request to the National Institute for Occupational Safety and Health for information on potentially toxic substances in your workplace

Visit OSHA's Website for additional facts at www.osha.gov

Source: U.S.Department of Labor Occupational Safety and Health Administration
Source: HPTC ComplianceTraining Partners

Personal Protective Equipment
by Karson L. Carpenter

Personal protective equipment, or PPE, is designed to protect workers from serious workplace injuries or illnesses resulting from contact with chemical, radiological, physical, electrical, mechanical, or other workplace hazards. Besides face shields and safety glasses, protective equipment includes a variety of devices and garments such as gloves, masks, lab coats/jackets and respirators.

Employer Responsibilities

OSHA's primary personal protective equipment standards are in Title 29 of the Code of Federal Regulations (CFR), Part 1910 Subpart I, and equivalent regulations in states with OSHA approved state plans, but you can find protective equipment requirements elsewhere in the General Industry Standards. OSHA’s general personal protective equipment requirements mandate that employers conduct a hazard assessment of their workplaces to determine what hazards are present that require the use of protective equipment, provide workers with appropriate protective equipment, and require them to use and maintain it in sanitary and reliable condition.

Using personal protective equipment is often essential, but it is generally the last line of defense after engineering controls, work practices, and administrative controls. Engineering controls involve physically changing a machine or work environment. Administrative controls involve changing how or when workers do their job, such as scheduling work and rotating workers to reduce exposures.Work practices involve training workers how to perform tasks in ways that reduce their exposure to workplace hazards.

As an employer, you must assess your workplace to determine if hazards are present that require the use of personal protective equipment. If such hazards are present, you must select protective equipment and require workers to use it, communicate your protective equipment selection decisions to your workers, and select personal protective equipment that properly fits your workers.

You must also train workers who are required to wear personal protective equipment on
how to do the following:

  • Use protective equipment properly,
  • Be aware of when personal protective equipment is necessary,
  • Know what kind of protective equipment is necessary,
  • Understand the limitations of personal protective equipment in protecting workers from injury,
  • Put on, adjust, wear, and take off personal protective equipment, and
  • Maintain protective equipment pro

Protection from Eye and Face Injuries
Besides spectacles and goggles, personal protective equipment such as special shields, spectacles with side shields, and face shields can protect workers from the hazards of flying fragments, large chips, optical radiation, splashes from molten metals, as well as objects, particles, sand, dirt, mists, dusts, and glare.

Protection from Hand Injuries
Workers exposed to harmful substances through skin absorption, severe cuts or lacerations, severe abrasions, chemical burns, thermal burns, and harmful temperatures extremes will benefit from hand protection.

Protection from Body Injury
In some cases workers must shield most or all of their bodies against hazards in the workplace, such as exposure to heat and radiation as well as scalding liquids, body fluids, hazardous materials or waste, and other hazards.

When to Wear Respiratory Protection
When engineering controls are not feasible, workers must use appropriate respirators to protect against adverse health effects caused by breathing air contaminated with harmful dusts, fogs, fumes, mists, gases, smokes, sprays, or vapors. Respirators generally cover the nose and mouth or the entire face or head and help prevent illness and injury. A proper fit is essential, however, for respirators to be effective. Required respirators must be NIOSH-approved and medical evaluation and training must be provided before use.

Additional Information
For additional information concerning protective equipment view the publication, Assessing the Need for Personal Protective Equipment: A Guide for Small Business Employers (OSHA 3151) available on OSHA's web site at www.osha.gov.

A small business such as a medical office has a multitude of legal requirements that must be met. While they all are important, none is more important than OSHA compliance, because it makes your facility safer for all who work there and eliminates your exposure to costly and embarrassing fines.

There is often considerable misunderstanding as to what OSHA regulates and many confuse OSHA requirements with infection control recommendations. OSHA, in fact, is concerned with only one thing—the safety of employees. OSHA, which is an acronym for the Occupational Safety and Health Administration, was formed through an act of Congress and its requirements are federal law. OSHA does not care if the hazard is from a chemical, a bloodborne pathogen, an electrical device or a fire. The only concern it has is the protection/safety of the worker, and this includes all employees in the medical profession.

To begin your compliance efforts, choose someone to be your Compliance Director. A trusted and organized medical assistant, nurse, Physician Assistant (PA) or office manager is suggested; by having an accountable individual, progress can quickly be made. Next, assign your Compliance Director to review and implement one step at a time, using the following outline:

Hazard Communication Standard
The Hazard Communication Standard deals with hazardous chemicals in the workplace. In medical facilities, these include disinfectants, laboratory materials, acids, cleaners, etc. This Standard requires a written chemical safety plan, material safety data sheets for each hazardous chemical/product, labeling of these potentially hazardous products, and training of employees who are exposed to them.

Bloodborne Disease Pathogens Standard
Because medical office employees are exposed to blood and saliva every day, this Standard is an extremely important one. Requirements include having a written Exposure Control Plan, providing the Hepatitis B immunization at no cost to exposed employees, and making available personal protective equipment (mask, gloves, safety eyewear, long-sleeved protective clothing).

Electrical Safety
Electricity is such a normal part of everyday life that is often overlooked as being potentially dangerous. Everyone has experienced a minor shock, but may fail to realize that severe shocks can cause death. Medical facilities make considerable use of electrical devices including autoclaves, instrument washers, ultrasonic cleaners, etc. It is important that no extension cords be used, that plugs and cords are checked for wear/intact insulation and that plugs match their outlets (e.g. three-pronged). In addition, cords should not be twisted around each other, but should run in parallel, and circuits/outlets must not be overloaded.

Ionizing Radiation
OSHA regulations require an employer to evaluate their facility for any potential radiation hazard and provide employees with the appropriate training and monitoring equipment. The primary source of ionizing radiation in a medical office is radiographic equipment. It is required that workers who take radiographs wear monitoring badges as there is no such thing as a totally safe dose of ionizing radiation.

OSHA's requirements for medical facilities are designed to make the workplace safer for its employees. By appointing a Compliance Director providing them with the tools they need and making him/her accountable, rapid progress can be made. If their time is limited, it may be advisable to consider a commercially prepared program to guide them through the process. Karson L. Carpenter has designed training programs to achieve compliance with governmental regulations for over 20 years, and currently serves as President and CEO of Compliance Training Partners.

Means of Egress
Every building is required by law to contain adequate exits that allow for escape of all occupants in case of fire or other emergency. There must be at least two of these means of egress in every building. Exits must have no locks or fastening devices that may prevent free escape and must be clearly visible and conspicuously marked with illuminated or glow-in the-dark signs. Non exits need to have similar signs that state “Not an Exit.” In the event of power failure, reliable emergency lighting must also be available for all exits and signs.

Walking and Working Surfaces
This part of the OSHA regulation is often called the housekeeping standard. It requires all rooms and passageways to be kept clean, orderly, and sanitary. All aisles and hallways must be kept free of debris/clutter and floors must be kept clean and dry. Additionally, stairways must have railings/guardrails and any ladders used must be OSHA approved.

Ventilation in the medical office is very important, as a variety of potentially hazardous substances can become airborne and cause illness or injury. To identify if a substance is hazardous in the form of a gas, fume, vapor or dust, consult the appropriate material safety data sheet or product label. One of the best recommendations is to put the heating/cooling system fan in the “on” position during working hours to allow for adequate turnover of air in the office.

Medical and First Aid
This part of the OSHA regulation does NOT dictate what type of medical drugs and/or equipment you have in place for patient medical emergencies, as is often thought. Remember that OSHA regulations are only concerned with employee safety. The requirements include having medical personnel available to provide emergency care if needed and to have an employee trained in first aid available during working hours. A first aid kit should be available as well as CPR microshields or other barrier devices to use when performing resuscitation. Remember to have emergency numbers posted on the phone and to have an eyewash station installed for flushing of the eyes.

Fire Safety
OSHA requires fire safety training. This training must include reviewing a list of all flammables in the workplace and their possible ignition sources. Employees must also know what their responsibilities are in the event of fire and the location of a safe meeting place after evacuation. Having an accessible fire extinguisher and training employees on its proper use is also required.

As in so many other areas, proper record keeping is mandatory. Requirements include employee medical records, records of training, environmental monitoring records (results of radiation or other types of monitoring) and material safety data sheets archiving. Employees have a right to access these records and they must be allowed to do so within 15 days of their request.

OSHA Compliance Product Checklist

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