American Association for Physician Leadership

Operations and Policy

Being OSHA Compliant

Mandy E. Martin, RPSGT, BSBM

February 8, 2019


Abstract:

This article is designed to give the reader a better understanding of how to stay compliant with requirements from the Occupational Safety and Health Administration in the office, how regulations and recommendations differ, how to prevent exposure injuries, and how bloodborne pathogens are transmitted.




Regulations and Recommendations

Have you ever wondered why there are regulations and recommendations for businesses? Office managers must take into consideration that regulations keep us in line with the law, and recommendations are best practice for our offices. Usually the question is, “Will I be fined if I don’t follow the regulations?”; and sometimes the question is, “Will I be fined if I don’t follow the recommendations for my office?” We must consider two questions.

First, what is a regulation? A regulation is one element of a concept of management of complex systems according to a set of rules. Then we need to understand what a recommendation is. A recommendation is an opinion given by an inspector or compliance consultant about what is best practice for the office, also known as a General Advisory. Once we understand the difference between the two, we can then move forward and understand what the office needs to do. One thing to keep in mind, is this: following a recommendation is just as important as following a regulation. Let me provide an example:


Inspectors have gone into an office and conducted an Occupational Safety and Health Administration (OSHA) assessment of the facility. Concerns have been identified, and a corrective action plan has been put into place.

Recommendation: The facility does not have an adequate functional emergency light. Egress during a power outage may be hampered without emergency lighting. It is recommended that emergency lights be added to the facility.

Regulation: An illuminated exit sign in the facility is nonfunctional. In the event of an emergency, it is important that employees be able to quickly locate the nearest exit. It is required that all exit signs be checked and documented on a monthly basis. {Reg.29. CFR 1910.37 (B)(6)}


The difference is that the regulation states the reference number with the law, and the recommendation comes as a general advisory. Understanding what makes a regulation and following the regulations pertaining to your office will keep your office from being fined. Following recommendations for your office will help employees to follow best practices and will keep employees from making mistakes. When we don’t understand the difference, we can’t move forward with best practices; and when we don’t follow regulations that are pertinent to our office, we then incur fines. It is recommended that all practices have an OSHA assessment of their office done annually to prevent unnecessary fines from the government. This will help employees to understand what needs to be done and answer any questions that many come up as to what is recommended “best practice.”

Work-Related Hazards

Needlestick Injuries

Injuries or illnesses can happen frequently in the medical office. Have you ever wondered, or been concerned, about what to do if you have an employee who suffers a needlestick injury? What would you say to the employee? “How did this happen? What paperwork should be filled out?” Most needlestick injuries involve clinical staff, which would include doctors, nurses, medical assistants, and laboratory staff. A needlestick can happen at any time, but is more likely to happen when there is a new device being used and the work team has not been properly trained in its use. There are, of course, other common reasons for needlesticks, such as when a staff member is overwhelmed with work, stressed, rushed, a bit distracted, or overtired.

Several things can be done to avoid these issues. First, understand and determine the risk of exposure. The risk of exposure occurs when there is little regard for personal protective equipment. Isolating and removing hazards is essential in the prevention of injuries. For a safer office, evaluate and use safety-engineered devices, such as safety needles or retractable scalpels, whenever possible. Remain well informed on what is safe and what is the proper use of all equipment. A Safety Evaluation Device Form should be filled out by clinical staff prior to using any new safety device, to determine whether a device will be conducive to specific job duties.

More than 20 bloodborne pathogens have been reportedly transmitted from exposure injuries. Severe, or even fatal, infections can include hepatitis B, hepatitis C, or HIV. A small, but definitely significant, 2% of needlestick injuries are likely to be contaminated with HIV, according to the CDC.

Implementing and setting priorities and strategies will ensure that staff members are aware of any risks in their work environment.

Certain necessary and immediate steps must be taken after a needlestick. First, wash the wound with soap and water. Then report the incident to a supervisor and seek immediate medical treatment at the nearest treatment facility or emergency department.

Preventive measures include avoiding recapping needles, and having a plan in place for the safe handling and proper disposal of needles. Evaluate devices, and dispose of all used needles in appropriate sharps containers.

Employees should keep their employers informed of any hazards observed at work that could lead to exposure to bloodborne pathogens from needles. Also, the use of needles should be avoided when other safe alternatives are available. First and foremost, try to prevent work injuries and keep the staff current on exposure information. Implementing and setting priorities and strategies will ensure that staff members are aware of any risks in their work environment. All will benefit from a high safety percentage when good risk prevention is practiced.

Other Hazards

We talk about needlesticks, because that is the most common injury in practices; however, we need to remember that an exposure can also come from a spray, splash, or spatter to the eyes, nose, or mouth. In case an injury happens this way, an office needs to be equipped with an eyewash station that all employees can access. According the American National Standards Institute (ANSI), in the event that a worker were to get a foreign object, substance, or bodily fluid in his or her eyes, there would be no way to properly rinse or irrigate the eye if there is no eyewash station. It is required that an eyewash station that complies with ANSI standard be installed for emergency use.

Conclusion

Staying OSHA-compliant is an important priority in any workplace. Take the time to assess your office and understand the concerns that need to be corrected.

Mandy E. Martin, RPSGT, BSBM

Compliance Consultant, Regional Director, MedSafe: The Total Compliance Solution, 210 Sylvan Avenue, Suite 29, Englewood Cliffs, NJ 07632; phone: 800-255-6387 x 113; email: mmartin@tcs-inc.us.

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