Let OSHA Compliance Be Known in Your Practice
When it comes to your employees’ health and safety, show that you set OSHA standards.
By Julie E. Chicoine, Esq., RN, CPC, CPCO and Michelle A. Dick
On-the-job safety wasn’t always a priority in the United States. Before the late 19th century, workers had no protection from occupational hazards. Workers were often injured, subjected to unhealthy environments, and even died on the job. Employees worked at their own risk.
Today, practices and healthcare organizations have OSHA standards they must follow to ensure employee and patient safety. Let’s take a look at ways you can make your healthcare employees aware of these standards, so they follow OSHA compliant procedures. But first, let’s take a look at a brief history of how OSHA became involved in ensuring healthcare worker safety.
Legislation Evolves to Better Conditions
The first state to pass safety and health legislation was Massachusetts in 1877, which required belts, shafts, and gears to be guarded to prevent injury; protection from falling down elevator shafts; and accessible fire exits in factories. Since then, much legislation has been passed to ensure better working conditions; and in the 1970s, the U.S. Department of Labor Occupational Safety and Health Administration (OSHA) was formed. OSHA has evolved over the years to set the standard for occupational safety and health compliance.
Infectious Disease Standards Set
In the 1990s, OSHA expanded its scope of safety and health hazards, and they began addressing new issues such as infectious diseases, indoor air quality, and ergonomics. During this time, they developed comprehensive health standards for bloodborne pathogens. The hepatitis B virus and human immunodeficiency virus (HIV) were the focal points of the standard. The introduction of HIV/AIDS in the United States played a large part in getting the standard finalized. OSHA already had standards applied in the healthcare setting, but the Bloodborne Pathogens standard has had the most influence on healthcare work practices and safety.
According to an OSHA Fact Sheet (www.osha.gov/OshDoc/data_BloodborneFacts/bbfact04.pdf):
OSHA’s Bloodborne Pathogens standard (29 CFR 1910.1030) requires employers to make immediate confidential medical evaluation and follow-up available for workers who have an exposure incident, such as a needlestick. An exposure incident is a specific eye, mouth, other mucous membrane, non-intact skin, or parenteral contact with blood or other potentially infectious materials (OPIM), as defined in the standard that results from the performance of a worker’s duties.
Because healthcare organizations are at a higher risk than other occupations to exposure of blood, potentially infectious materials, and pathogens such as hepatitis B, healthcare organizations should vaccinate employees for hepatitis B upon hire. Your practice or healthcare organization should perform in a manner minimizing the risk of exposure to blood or OPIM.
Display Proper Signage in Your Practice
There are a lot of websites that charge money for OSHA signage. The signs explain anything from state minimum wage requirements to fire safety. OSHA provides a free poster on their website (www.osha.gov/Publications/osha3165.pdf) that you can download, print, and use in several locations, rather than paying $10 and up, per sign, from a vendor. The “It’s The Law” poster addresses employees’ rights to a safe workplace and, by law, must be displayed for employees to see.
Use biohazard labels and signs to identify containers for biohazardous materials such as biomedical waste, blood, specimens, and OPIM. Containers can include laundry receptacles and waste cans. According to “Most Frequently Asked Questions Concerning the Bloodborne Pathogens Standard,” the following categories of waste require special handling, should be labeled with a biohazard label, and employees should know how to safely handle them:
- Liquid or semi-liquid blood or OPIM;
- Items contaminated with blood or OPIM and which would release these substances in a liquid or semi-liquid state if compressed;
- Items that are caked with dried blood or OPIM and are capable of releasing these materials during handling;
- Contaminated sharps; and
- Pathological and microbiological wastes containing blood or OPIM.
If employees are exposed to a healthcare-wide hazard, such as tuberculosis, OSHA has a non-mandatory Sample Exposure Control Plan (ECP) for hospitals to use in the event of employee exposure. The procedures in the ECP will help to minimize occupational exposure to the contaminant by isolating and managing care. The ECP can be used until the suspected or confirmed infected individual(s) are determined to be non-infectious or until the diagnosis has been ruled out. You can find the ECP at: www.osha.gov/SLTC/etools/hospital/hazards/tb/sampleexposurecontrolplan.html.
Other General Safety Plans
Besides OSHA health and safety items that are unique to healthcare organization compliance, there are a wide array of measures and plans to ensure general safety of employees and patients. For example, here are just some basic OSHA compliance plans your organization should have:
- General Safety Compliance Plan – This includes displaying No. 3165, “It’s The Law,” signage.
- Fire Safety Plan – You need pre-arranged escape routes. Exits, escape routes, and fire extinguishers should be clearly marked and easy to locate.
- Building Safety Plan – This includes electrical safety.
- Workplace Safety Plan – This covers a large area and includes, for example, clearly marking eye washing stations, having plans for natural disasters and workplace violence, providing a code of conduct to employees, giving employees the right to accessing his or her own medical records, injuries, keeping records of every blood borne exposure incident and all other work-related injuries requiring medical attention, etc.
- First Aid Plan– Have first aid supplies handy and make the locations known to employees and mark them clearly.
- Housekeeping Plan – This includes handling spills, cleaning, decontaminating, and sterilizing environmental surfaces and equipment that may be contaminated with blood or OPIM.
These are just the tip of the iceberg on ways to be OSHA compliant. It’s best to hire an OSHA compliance officer to make sure you follow regulation and display proper signage in your practice or facility.
Find Resources and Assess Compliance
Periodically, practices should assess their compliance with OSHA requirements. This can be a daunting task, however, due to the myriad of regulations that come into play.
OSHA’s website provides resources to help practices understand applicable OSHA requirements and how to achieve compliance. This information is provided at no cost.
For example, with regard to preventing or minimizing workplace illnesses and injuries, OSHA provides a step-by-step guide to help employers identify some of the more significant requirements and how those requirements might apply to your workplace.
OSHA also features a Quick Start program, which can be helpful as an introduction to its compliance assistance resources. Although the Quick Start feature is not comprehensive — and does not cover all of the applicable standards — it allows for practice managers or compliance professionals to develop a baseline for initiating a compliance program assessment for OSHA safety.
Finally, OSHA offers a Health Care Quick Start Library, which features a collection of forms, resources, publications, sample programs, and additional compliance assistance resources that allow practices to identify requirements applicable to their healthcare facility.
To learn more about OSHA’s educational resources, visit: www.osha.gov/dcsp/compliance_assistance/index.html.
Julie E. Chicoine, Esq., RN, CPC, CPCO, is senior attorney for Ohio State University Wexner Medical Center. She earned her Juris Doctor degree from the University of Houston Law Center. Chicoine also holds a Bachelor of Science and nursing degrees from the University of Texas Health Sciences Center at Houston. She writes and speaks widely on healthcare issues, and is an active member of the AAPC community and the Columbus, Ohio, local chapter.
Michelle A. Dick is executive editor for AAPC.
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