Running a busy medical or dental practice is difficult enough as it is without having to deal with regulatory compliance like OSHA or HIPAA. This checklist will assist you in addressing some of the most common or overlooked areas we see during our inspections. This is an abbreviated version that's perfect to use annually to help maintain your OSHA compliance.
If you don't already have a COVID-19 Protection Policy or you need an Injury and Illness Prevention Program (IIPP) our 2021 OSHA Compliance System for Healthcare or Dentistry includes these too and a more comprehensive checklist to address all the required elements.
In most medical and dental facilities we visit for the first time we see shortcomings with documentation, outdated OSHA polices and violations of the Hazard Communication Standard. This has been even more evident since the alignment with the Globally Harmonized System of Classification and Labeling of Chemicals (GHS).
Documentation, or lack thereof, is one of the biggest mistakes we see medical and dental practices make. Every new employee should be trained within 10 days of assignment. This training doesn't have to be as elaborate as annual training, but it should include who to report an injury to and locations of various items, like your OSHA manual, SDS book, eye wash station and final destination medical waste box. If you have specialized equipment, like a laser, explain how and what's required to operate it. In the case of lasers it's usually protective eye wear and/or engineering controls like guards or evacuation systems. Have every employee sign a New Employee Training Form.
Clinical employees and any employee with the risk of exposure should be offered a Hepatitis B vaccination series at the time of hire. If they aren't vaccinated and want it, start the vaccination series and document the date of the initial shot. If they are, get documentation. They can provide a copy of their vaccination record or the easiest way is to have them sign the Hepatitis B Vaccination Acceptance/Declination Form. Have them check and initial the box that states, "I am signing this declination form because I was vaccinated prior to my employment in this facility and do not have a copy of a vaccination certificate for my medical records."
Safety needles and other medical devices need to be evaluated annually. This isn't optional or dependent on how many needlestick injuries you've had in the past year. OSHA amended the Bloodborne Pathogen Standard years ago and it require you to evaluate these devices and implement them if appropriate. If you aren't using these devices, use the Safer Sharps Evaluation Form to document you evaluation. This is important and must to be done annually.
Hazard Communications is a important part of your obligations. It was the 2nd most frequently cited standard for the fiscal year 2020. Healthcare and Dental facilities often have a handful of products that would be subject to labeling requirements. Examples might include disinfectants, alcohol dispensers, cold sterilization, ultrasonic solution and lab chemicals. If you remove a product from it's original container make sure it labeled appropriately. Under GHS these secondary containers should include product Identity, pictograms, signal word, hazard statements, precautionary statements and the manufacturer's information. Labels should be inspected on a regular basis to ensure legibility and Safety Data Sheets (SDS) should be requested for any new products. You Master List should be updated to reflect any changes in inventory. We have hundreds of custom labels created that we provide to our customers as part of our Guardian Service.
Medical waste disposal should also be evaluated at least annually. Sharps containers and red bags should be located at the "Point of Origin" or the immediate area the waste is generated in. If you have wall mounted sharps containers make sure they are securely mounted and at a height that is accessible by all employees. Pick-up receipts need to be kept for 3 years and your contract with your transporter should be evaluated. Too often we find facilities with auto renewing contracts that they're paying way too much for.
Our free Annual Checklist for OSHA that we're providing covers quite a bit more than I've had a chance to summarize in this blog post. Although, it's not required, the checklist highlights the important areas and allows you to show an ongoing commitment to a safe workplace.
We've provided OSHA and HIPAA consultation services, training and compliance manuals for over 25 years now. Oshaguard provides toll-free phone support, including help with inspections and audits at no charge for our customers. If you need a 2021 OSHA Manual or you have any questions don't hesitate to give us a call at 1-800-522-9308.