Planning and Strategy
And other things you say and do when an OSHA compliance officer arrives at your facility.
Surprise visits are the norm for inspection officers at OSHA, the Occupational Safety and Health Administration. Therefore, facility staff needs to be prepared for an OSHA officer to walk through the door at any time. This article will highlight how to prepare for an inspection and what resources to refer to for additional information.
When a compliance officer arrives at a facility, the officer will provide his or her credentials and ask to speak to the facility administrator or someone in charge. The officer will then have an opening conference, a walk-through and a closing conference.
Inspection Priorities
OSHA will assess a facility based on established inspection priorities:
- Imminent danger: Any condition that can be expected to cause death or serious physical harm immediately.
- Catastrophes and fatal accidents: Investigation of fatalities and accidents resulting in a death or hospitalization of three or more employees.
- Complaints and referrals: Formal employee complaints of unsafe or unhealthy working conditions or a workplace hazard. An inspection could also be based on a news report, which is considered a referral.
- Programmed inspections: Inspections aimed at high-hazard industries or occupations. OSHA selects these inspections based on injury incidence, previous citations, and exposure to toxic substances. Currently there is not an emphasis on the operating room or on ASCs, but there is one for nursing homes. Facilities in states with a state plan would have to check to see if a hazard in the facility is a focus item.
- Follow up inspections: An inspection to determine if the employer has corrected a previous cited violation.
State and Federal Regulations
There are differences between state and federal regulations. States must adopt standards and enforce requirements that are at least as effective as federal requirements. So, be sure to check with your individual state to make sure there are not additional requirements that need to be met.
There are specific OSHA regulations that apply to health care workers. Examples are hazardous communication, personal protective equipment (PPE) and blood-borne pathogens. And, OSHA's standards apply to ambulatory surgery centers, so if an OSHA compliance officer arrives at your facility the staff needs to be prepared to demonstrate compliance.
OSHA Log
OSHA mandates that the employer keep records of occupational injuries and illness:
- OSHA form 300 is maintained by calendar year
- OSHA form 300 needs to be retained for five years (may vary by state)
- OSHA form 300A should be signed by facility administrator at the end of the year and posted in a conspicuous place for all employees
- OSHA form 301 is the injury and illness report as a follow up record (seven days after an incident)
Written Exposure Plan and Safety Related Policies
Many of the OSHA standards require that you develop, implement and maintain a written exposure plan, policy, procedure, program or rule. You must be able to speak to and produce these written policies, as well as demonstrate compliance. The following OSHA policies should be reviewed, updated and approved annually by the facility's governing board:
- Exposure control plan
- Emergency preparedness plan
- Fire prevention plan
- Safety management plan
- Interim life safety plan
- Blood borne pathogen plan-exposure/post exposure
- Hazardous waste management plan
- Utility management plan
- Health and safety policies for employee exposure and safety
Posting Requirements
OSHA workplace poster (OSHA 3165) form 2203 Job Safety and Health Poster should be posted informing employees of the protection and obligations of the employer. This should be posted in a conspicuous place.
Documentation of Employee Training
Many of the OSHA standards require appropriate employee training and documentation of such training and competence. Training should be demonstrated during the initial employee orientation and refreshed annually. The training should be specific to an employee's job description and exposure to specific conditions:
- Fire drill and extinguisher training (fire plan)
- Emergency preparedness
- Hazardous waste
- Infection control and personal protective equipment
- Blood borne pathogens and post-exposure treatment
- Medical gas
- TB exposure plan
- Sharp safety
Several common citation issues during on-site visits are listed on the OSHA Web site located at www.osha.gov.
It is easy to be intimidated or worried about an impending OSHA inspection but with an organized plan and staff education, OSHA inspections should become a routine part of your operations.
It is crucial that you have appropriate policies that document your practice, and that you are following the policies. Use the e-tools that OSHA has to offer on its Web site to assist with a safety inspection. Recognize that you will need to build a culture of safety in your facility and make sure everyone participates. Remember that OSHA's main priority is to keep staff safe and maintain a culture of safety in your environment.
Colleen Heeter, R.N., B.S.N., senior vice president, Operations Design Nueterra Healthcare