For dentists and physicians alike, running a busy practice can be daunting enough without the burden of keeping up with OSHA compliance. Annual requirements include providing OSHA training for your staff, policy reviews and typically an inspection of your facility to look for other potential issues.
Number one, you can absolutely do this yourself and it doesn't have to be overwhelming, time consuming or expensive. One of the biggest challenge is being aware of how quickly time can pass and how fast OSHA training records, policies and other documentation requirements can become outdated. Fortunately, OSHA is primarily concerned about what you are currently doing. Don't stress out about being out of compliance and focus on what you can change now.
Although everything is equally important, OSHA policies are first and foremost. They outline the site-specific details on how you keep your employees safe. All employees need to be familiar with general details like who to report an unsafe condition or injury to. Typically this person is identified as your Safety and Health Officer and their name or job position is identified in your policies. Other general polices would include details like your fire plan, workplace violence and natural disasters among others.
The Bloodborne Pathogen Standard is the biggie in healthcare and dentistry and applies to any employee that has the risk of exposure (All clinical positions, non-clinical if there is any risk of exposure - example: a small practice where the front desk occasionally helps to turn over an exam room or operatory.) Any job position with the risk of exposure must be identified in your Exposure Control Plan and those individuals are required to be trained annually on the Bloodborne Pathogen Standard. Training records need to be signed by all employees and maintained for a minimum of 3 years.
"Any job position with the risk of exposure must be identified in your Exposure Control Plan and those individuals are required to be trained annually on the Bloodborne Pathogen Standard."
The Hazard Communication Standard (HCS) is another important requirement. Your OSHA manual will have updated policies that identify any hazardous chemicals that employees might be exposed to. Safety Data Sheets (SDS) should be available and employees should be trained on their use and availability. Annual training typically includes the HCS aligned with the Globally Harmonized System of Classification and Labeling (GHS) training covering pictogram, SDSs and secondary container labeling. Chemicals that are removed from their original containers should be identified to include their identity and any warnings. Cold sterilization, alcohol and ultrasonic solutions are examples of products that are regularly removed from their original packaging. Inspect your facility to make sure all secondary chemicals are identified per GHS requirements.
Biohazardous and infectious waste management. Although the majority of these principles would be covered under the Bloodborne Pathogen Standard. Most states require training to not only include the safe handling, but the proper disposal of infectious wastes. Employees need to be trained on sharps and red bag waste, definitions, safe handling including PPE. Your policies should include the type of waste you generate, where it's generated and if applicable, the name and frequency of your licensed transporter. Pick-up / disposal receipts should be kept for a minimum of three years.
Although you don't need to purchase a new manual annually, you should review your polices annually and sign off to show that the site-specific details are current. If corrections are needed, it's okay to make changes to keep the policy up-to-date. Unlike your HIPAA policies, where any and all revisions need to be maintained for 6 years, OSHA is concerned with your present day policies. Documentation like Hepatitis B vaccinations and needlestick injuries should be up-to-date and kept confidential.
If you need to get into OSHA compliance, we can help. We've provided common-sense solutions for doctors and dentists for over 25 years. Our 2022 OSHA Compliance System for Healthcare or Dentistry includes everything you need to get into compliance fast and easy. Our policy manuals are flagged to highlight the most important features, but also include step-by-step instructions for compliance down to the smallest details. Like always we provide toll-free support for your OSHA, HIPAA and other regulatory questions. Don't wait any longer to get into compliance with OSHA. We offer get discounts on our bundles too!