The OSHA regulations applicable to the offices of medical professionals are aimed at creating a safe and healthy practice. Compliance creates a positive work environment and minimizes employee complaints. There are six OSHA general standards that apply to physician offices of all sizes and a seventh requirement that applies only to offices that offer X-ray services. We will discuss each in this article.
The seven standards are:
1. Bloodborne Pathogens;
2. Hazard Communication;
3. Exit Routes;
4. Electrical;
5. Reporting Occupational Injuries and Illnesses;
6. OSHA Poster; and
7. Ionizing Radiation (applicable only if X-ray services offered).
1. Bloodborne Pathogens
The OSHA requirements aimed at reducing occupational exposure to HIV, Hepatitis B and Hepatitis C are found in the OSHA bloodborne pathogens standard (1991), which was updated in 2000 by the Needlestick Safety and Prevention Act. There are eight key requirements regarding bloodborne pathogens. They include:
Exposure Control Plan. An exposure control plan is required where an employee is subject to occupational exposure (reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee’s duties).
Exposure Determination. The exposure determination shall be made without regard to the use of personal protec-tive equipment and shall contain lists of job classifications in which all or some of the employees have occupational exposure. Safety Equipment. Engineering and work practice controls shall be used to eliminate or minimize employee exposure and shall be examined and maintained or replaced on a regular schedule. Where the controls do not eliminate exposure, personal protective equipment must also be used.
Personal Protective Equipment. The employer shall provide, at no cost to the employee, appropriate personal protective equipment (e.g. gloves, gowns, laboratory coats, mouthpieces).
Information and Training. Employee training on safety devices, work practices, and personal protective equipment is required and must be given during work hours at no cost to the employee.
Prohibited Practices. Bending, recapping, or removing of contaminated needles is prohibited unless the employer can demonstrate that no alternative is feasible or that such action is required by a specific medical or dental procedure.
Housekeeping. Employers shall ensure that the worksite is maintained in a clean and sanitary condition. All equipment and working surfaces shall be cleaned and decontaminated after contact with blood or other potentially infectious materials.
Disposal of Needles, Materials, Protective Equipment. Contaminated materials must be discarded immediately or as soon as possible in containers that are closed, puncture resistant, leak-proof, and color-coded.
Hepatitis B Vaccination and Treatment After Exposure. The employer must make the Hepatitis B vaccination available to all employees who have occupational exposure. Employees that are exposed must receive immediate confidential medical screening and follow-up care.
2. Hazard Communication
If an office contains hazardous chemicals of any kind, the employer must have a written listing of them and the employees must have access to the manufacturer-supplied Material Safety Data Sheet for each hazardous chemical. The requirement covers chemicals that are physical hazards (e.g. flammables, explosives, combustibles) and those that are health hazards (e.g. irritants, carcinogens, corrosives).
3. Exit Routes
At a minimum, employers must establish exit routes to accommodate all employees in a defined workspace and must post easily visible evacuation diagrams.
4. Electrical
Electrical equipment (e.g. copy machines, X-ray machines, microwaves) must be safely located and used. Sufficient access and working space must be provided and maintained around all electrical equipment to permit safe operation and maintenance.
5. Reporting Occupational Injuries and Illnesses
Medical professionals are exempt under federal law from keeping an injury and illness log. State law may require a log if the state has its own occupational safety and health plan. However, Pennsylvania does not have such a plan; therefore the log is not required. All work-related fatalities and work-related incidents resulting in hospitalization of three or more employees must be reported.
6. OSHA Poster
An OSHA poster displaying a notice of employee rights and information on filing a complaint must be posted in a conspicuous place. Posters are available for free from OSHA (www.osha.gov/Publications/poster.html or 1-800-321-OSHA).
7. Ionizing Radiation
If X-ray and related imaging services are offered, employers must:
– survey the different types of radiation used;
– designate restricted areas to limit employee exposure;
– supply personal radiation monitors to employees working in restricted areas; and
– label rooms and equipment with caution signs where necessary.
There are several options to assist an employer in ensuring compliance with the above OSHA standards. An obvious but underused resource is OSHA itself. The Administration offers free state-run consultation services and the results of the consultation are confidential. In addition to the consulting, OSHA offers a wealth of materials on its Web site www.osha.gov that is helpful in verifying compliance with the requirements. Other potential sources of help are county, state, or national medical societies. A final option is the hiring of a private health and safety consultant.
