Thank you for enrolling in OSHA training for employees provided by Doctors Management. This training is intended to give you a comprehensive overview of health and safety policies your practice has adopted to ensure your safety as an employee and to meet the requirements established by OSHA. Doctors Management is a full-service consulting firm that helps physicians and health care professionals increase profits and productivity, mitigate compliance risks, and reduce stress for providers and staff. OSHA and HIPAA compliance is just one of the service lines we offer to assist practices by simplifying the business of medicine. The basic premise behind OSHA is that no employee should have to choose between their life and their job. Congress created the Occupational Safety and Health Administration as a national health agency, and it was established within the Department of Labor. OSHA establishes and enforces standards in an effort to save lives and prevent injuries and illnesses. OSHA was developed for the protection of employees, and the rules and regulations define the employer's responsibility to provide that protection. Not covered under OSHA would be the self-employed and hazards regulated by another federal agency such as the Department of Energy or the Coast Guard. OSHA does not cover patient care. There are several key components we'll cover in this training. These elements are fundamental to creating an effective safety policy to foster a secure and healthy work environment for all employees. As with any program or policy, how well these are implemented and followed depends on the practice leadership. The safety coordinator for your practice is your primary point of contact for any questions employees may have about hazards, training, or recordkeeping. Your safety coordinator is responsible for maintaining revisions to your policies and procedures as well as administering and documenting employee training. Annual training is conducted for all employees and needs to be completed within ten days of the hire date. Employees are required to receive annual training or as needed should there be a position change or if there is an update or final rule issued by OSHA. The OSHA poster needs to be in a location that is visible to employees. This poster informs workers of their rights under the OSHA Act. This poster is occasionally updated, but OSHA does not find a facility for an outdated poster. Posters in other languages are also available for free from the OSHA website. Should your practice have an OSHA notice as a result of a violation, a copy of that notice must be posted near the violation location for three days or until the violations are corrected. Federal OSHA covers employers and workers in the private sector in 29 states and specific territories and covers the public sector in all 50 states and certain territories and jurisdictions. Private sector workers in 21 states and Puerto Rico are covered by OSHA-approved state plans. State plans must be at least as effective as the federal OSHA program. Employers have certain responsibilities under OSHA, and those include providing a safe and healthy work environment, providing employee training and access to policies and procedures, providing medical exams, access to exposure and medical records, and supplying PPE, documenting injuries, illnesses, training, and confidential employee records, displaying OSHA posters in prominent locations, posting citations and abatement verifications notices, and prohibiting retaliation against staff. Employees have more rights but fewer responsibilities than their employers under OSHA. Employees should have access to a safe work environment, but there is a responsibility to adhere to the policies and procedures established by your practice, to attend and complete all training that would provide knowledge of hazard exposures, to properly use personal protective equipment provided by the employer, to ask questions, and to report any hazards or concerns to your employer without fear of retaliation. Employees have a right to file a safety and health complaint with OSHA if concerns are ignored by their employer. The practice's policies and procedures should be available and accessible to all staff and modified when new tasks are introduced or if revisions are made. The mandatory written components of those policies include Blood-Borne Pathogen Exposure Control Plan. This is mandatory if there is potential for exposure to human blood. Hazard Communication Plan. Mandatory and should include a list of chemicals present, properly labeled containers, and a safety data sheet for each chemical. Written Emergency Action Plan, which is site-specific. First Aid Program. This refers to kits in the workplace, protective equipment checklist to identify when and what type of equipment should be used, OSHA posters required to be posted in a visible location for staff, training records which document initial and annual training for each employee, and finally, a copy of the OSHAC. Blood-Borne Pathogen and HESCOM standard must be accessible to staff in a hard or electronic copy. Your safety plan may also include these items if they apply to your facility. Fire Prevention Plan. Workplace Violence Prevention Plan is mandatory only if an incident has occurred. Laser Safety Plan only if lasers are utilized at your practice. Exposure Control Plan for TB only if there have been reported incidents of TB. After reporting forms, offices of physicians, dentists, and other health care practitioners are exempt unless they are asked in writing to do so by OSHA or if there are specific types of injuries and illnesses. Those forms will be addressed later in this training. OSHA standards affecting health care facilities fall into three major categories. 1. The Blood-Borne Pathogen Standard 2. The Hazardous Communication Standard, and 3. The General Industry Standard. General Industry Standards typically apply to any industry except construction, maritime, and agriculture. Health care falls under General Industry. Where the General Duty Clause and a specific OSHA standard addresses an identical hazard, you must comply with the specific standards, which are generally more stringent. The General Duty Clause is the bucket that captures hazards not covered by a specific standard. An example of this is workplace violence. This is a recognized hazard within the health care industry, and while OSHA provides guidelines, there is no official standard. Nonetheless, employers have the responsibility to abate this hazard, and OSHA relies on this clause for enforcement authority. Enforcement plays a vital role in OSHA's efforts to reduce workplace injuries, illnesses, and fatalities. Inspections are part of the enforcement responsibility of OSHA with the goal of assuring compliance with requirements and helping employers reduce on-the-job hazards. Inspections are initiated without advance notice and performed by trained compliance officers. Upon receipt of a complaint, OSHA will determine if an inspection is necessary and may request the employer provide them with information via fax or mail. OSHA is prohibited from providing any advance warning to an employer that they will be conducting an on-site inspection, but follow-up visits may be coordinated for various reasons. Inspections are based on the following priorities. 1. Imminent Danger – Hazards that could cause death or serious physical harm. 2. Catastrophes – These would include fatalities or hospitalizations. 3. Employee Complaints and Referrals – These receive high priority and are anonymous. 4. Precedented Inspections – These would be a result of particular hazards or high injury rates. 5. Follow-up Inspections which are intended to check for abatements. Should OSHA contact a practice via mail or phone call to request information, the practice or facility is required to respond within five working days. Should an OSHA compliance officer arrive to conduct an on-site inspection, the safety coordinator should be notified immediately to begin the process. During the opening conference, the officer will explain the reason for the inspection, the scope of the inspection process, the procedures of the walk-around, and the process for employee interviews and employee representation. During the walk-around, the safety coordinator or another representative will accompany the officer and should take the same notes and photos as the compliance officer. There may be some violations noted that can be remedied immediately, and doing so shows a sign of good faith on the part of the employer. Following this step, the officer will hold a closing conference to discuss the findings and course of action. Violations are identified in the categories you see here. OSHA's penalty limits and reductions are reviewed annually, and the agency has continued to adjust the penalties for inflation. The maximum penalty amounts as of January 15, 2025 are listed here. OSHA does grant penalty adjustments based on the employer's size, good faith, and history or previous violations. Should an inspector find violations of OSHA standards or serious hazards, OSHA may issue citations and fines. OSHA must issue a citation and proposed penalty within six months of the violation's occurrence. Citations describe OSHA requirements allegedly violated, list any proposed penalties, and give a deadline for correcting the alleged hazards. As mentioned earlier, the OSHA standards affecting health care facilities fall into three major categories. We will look closer at the blood-borne pathogens standard and the hazard communications standard in the next several slides. Blood-borne pathogens are infectious microorganisms in human blood that can cause disease in humans. The pathogens of primary concern are Hepatitis B, Hepatitis C, and Human Immunodeficiency Virus. We're going to use the terms universal precautions and OPIM when looking further at this standard. This standard requires the use of universal precautions as an approach to infection control. Universal precautions refers to the treatment of all human body fluids as if they were known to be infectious. OPIM stands for Other Potentially Infectious Material. The four universal precautions are illustrated here and are addressed in the OSHA standard for general industry. Some Precautions to Consider. When providing CPR or first aid, protect yourself first and treat the patient second. Wear appropriate PPE as required and dispose of contaminated clothing in appropriately labeled bags or containers. Contain spills immediately and disinfect area. Treat all trash as if it contains sharps or infectious items. Wash hands or affected body parts thoroughly and place potentially infectious materials or items in color-coded bags and containers. A pathogen is harmful microorganisms like viruses, bacteria, fungi, and parasites that have been known to cause infectious diseases. The blood-borne pathogens of primary concern are Hepatitis B, Hepatitis C, and Human Immunodeficiency Virus. Pathogens can be transmitted by the physical contact, droplets, or airborne. All occupational exposure to blood or OPIM places workers at risk for infection from blood-borne pathogens. OSHA defines occupational exposure as any reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee's duties. An employer must develop a written exposure control plan to comply with the OSHA standard. The items listed here include all elements required by the standard, which requires employers to offer the HBV vaccination series to all workers who have occupational exposure. Vaccination must be offered at no cost to the worker and at a reasonable time and place, and it must be offered within 10 days of initial assignment where there is exposure, should an employee decline the vaccination. A declination form must be signed by the employee stating they understand they remain at risk of acquiring Hepatitis B. There is currently no vaccine for Hepatitis C or HIV, so prevention measures are critical to ensuring a safe environment. OSHA's HESCOM standard became effective in 1989 and was revised in 2012 to align with global standards. The basic goal of an effective hazard communication program is to ensure employers and employees know the identities and hazards of chemicals in their workplaces. When employers and employees have this information, appropriate protective measures can be designed and implemented to reduce incidents of injury or illness. This standard applies to all chemicals that are defined as hazardous and are used in the workplace. Workers can be protected from exposures to hazardous drugs through administrative controls and proper protective equipment. If this is a concern for your practice, preparing a policy to protect the workers exposed is recommended. To be exposed to a health hazard, the chemical must enter the body. A physical hazard poses a danger to a person's physical safety such as flammables or combustibles. The HESCOM standard requires pictograms on labels to alert users of the chemical hazards to which they may be exposed. Each pictogram consists of a symbol on a white background, framed within a red border and represents a distinct hazard or hazards. The pictogram on the label is determined by the chemical hazard classification. Of the nine pictograms, only eight are mandatory by OSHA standards. The environment label is optional, but a manufacturer may choose to apply this label if a hazard exists. The HESCOM standard requires chemical manufacturers or distributors to provide safety data sheets, and they must be in uniform format and include the section numbers, headings, and associated information under the headings. The SDS includes information such as the properties of each chemical, the physical, health, and environmental hazards, protective measures, and safety precautions for handling, storing, and transporting the chemical. Sections 1 to 8 contain general information about the chemical, such as 1. Identification, 2. Hazards, 3. Composition slash ingredients, 4. First aid measures, 5. Firefighting measures, 6. Accidental release measures, 7. Handling and storage, and 8. Exposure controls and personal protection. Employers are responsible for storing safety data sheets where they are accessible to all employees at all times in their work area. OSHA allows employers to store safety data sheets in electronic form if the employee's work area includes the area where the SDSs can be accessed. Failure to establish a written HAZCOM program is considered a serious violation by OSHA. Employers must provide a written policy that describes how it will meet the requirements of the standard. A copy of the policy or plan must be available for all employees to read and must be easily accessible to all employees. Employees must receive training on details of the employer's HAZCOM program, such as methods used to detect a hazardous chemical, physical and health hazards of chemicals, and measures employees can take to protect themselves. Employees have responsibility to attend all training to ensure they understand the hazards and protective measures for all chemicals in their work area, the label and safety data sheets for each chemical they need to use, the need to report missing labels, illegible labels or damaged containers to supervisors, and to avoid using these chemicals. It is also important to understand emergency procedures, including how to evacuate, report an incident, respond to a spill or leak, and how to properly administer first aid. If unsure about these responsibilities, employees are encouraged to ask the safety coordinator for additional guidance. OSHA specifies the need for appropriate personal protective equipment for health care workers under the Blood-Borne Pathogen Standard, the Hazardous Communication Standard, and the CDC's Guidelines for Preventing the Transmission of Tuberculosis in Health Care Facilities. Procedure gloves are the most common form of protection. Gowns and face protection are added if splashing, splattering, or misting is anticipated. Heavy-duty utility gloves may be used for cleaning up spills. Foot protection is only required where there is danger of foot injuries. In clinical areas, there is often the potential for spills or contamination from biohazardous materials, so we suggest your policy restrict sandals or fabric shoes. An approved TB respirator is required for employees who enter areas occupied by a confirmed or suspected case of TB. Goggles may be required for employees present during LACER procedures, and lead-lined equipment would be used for employees performing x-rays. An employer should assess the workplace to determine if hazards are present or likely to be present, which require the use of personal protective equipment. Based on the hazard assessment, employers will 1. communicate the appropriate protective equipment to staff, 2. provide the equipment at no cost to the employees, and 3. train each employee to know when it is necessary, what is necessary, and how to properly done, doff, adjust, and wear the equipment. Employees should also be educated on the proper care or disposal of the personal protective equipment. The sequence for removing personal protective equipment is intended to limit opportunities for self-contamination. If only gloves are worn as protective equipment, it is safe to remove and discard them in the patient room. The example you see in the bottom right corner of this slide shows an example of removing your gown and gloves together. This method is recommended in hospital environments rather than removing gloves independently and assumes that both the gown and gloves are disposable. Laundry in a health care facility may include bed sheets, blankets, personal clothing, uniforms, scrubs, gowns, and drapes. The purpose of the laundry portion of the standard is to protect the worker from exposure to potentially infectious materials during collection, handling, and sorting of contaminated textiles through the use of personal protective equipment, containment, labeling, and hazard communication. Uniforms without blood or body substance contamination do not differ much from street clothes in the degree and microbial nature of soilage. Home laundering would be expected to remove this level of soil adequately. OSHA revised the Blood-Borne Pathogen Standard to conform with the requirements of the Needlestick Safety and Prevention Act. This standard identifies engineering controls as the primary means of eliminating or minimizing employee exposure. The best practice for preventing sharps and needlestick injuries include implementing a plan for safe handling and disposal before any procedure, utilizing needles with engineered sharps injury protection, activating the device's safety features, avoiding recapping, shearing, or breaking contaminated needles, and immediately disposing of contaminated needles in proper sharps containers. Needlesticks are the most common type of sharps injury with estimates that 600,000 to 800,000 needlesticks occur annually. Sharps injuries are the most common way health care workers are exposed to blood-borne pathogens. If you experience a sharps injury, you should immediately wash the wound with soap and water, report the incident to your supervisor, and seek medical evaluation and treatment as directed. All employers, including medical and dental offices partially exempt from reporting requirements, must report to OSHA any workplace incident that involves a needlestick or sharps injury if it involves another person's blood or other potentially infectious material. These should be reported within seven calendar days after you receive information about the incident and determine if it is recordable. OSHA's forms and instructions for completing those can be found on the OSHA website. The 300 log is used to report specific details about the incident and should be evaluated yearly and kept for five years from the date of exposure. The form 301 is an injury and illness incident report. This form must be used in a manner that protects the confidentiality of employees to the extent possible while being used for safety and health purposes. The 300A summary is intended to provide transparency to employees regarding injuries and illnesses in their workplace. Hand hygiene is considered to be the single most important measure for preventing pathogen transmission in health care settings. Hand washing also prevents you from transferring contamination from your hands to other areas of your body or to other surfaces you may contact later. The CDC recommends alcohol-based hand rubs contain between 60% and 95% alcohol content by volume. Unless hands are visibly soiled, an alcohol-based hand rub is preferred over soap and water in most clinical situations, simply due to evidence of better compliance compared to soap and water. As with every recognized workplace hazard, each employer must determine the risk of employee exposure to respiratory infections. At this time, OSHA does not require employee TB testing initially or annually in private practices unless the practice performs high-risk procedures on patients expected or known to have active pulmonary tuberculosis or the practice performs dental procedures in a hospital or a correctional institute. OSHA has no TB standard. However, OSHA can cite employers under the General Duty Clause for not protecting employees from risks of TB exposure. There are several known activities that increase a worker's risk of MSDs, such as frequent lifting of heavy objects, frequent reaching overhead, repetitive forceful pushing and pulling, working in awkward positions, and highly repetitive hand activity. Health care professionals are among the highest rates of MSDs. Assessing the hazards and identifying possible solutions for each of those hazards decrease ergonomic stressors for employees. Reviewing records of injuries and illnesses regularly will also help identify patterns of injury that occur over time, so the hazards can be addressed and prevented. Workplace violence ranges from offensive or threatening language to homicide. Some of the risk factors for workplace violence include working directly with volatile people, especially if they are under the influence or have a history of violence, working understaffed, especially during mealtimes, long waits for service or to be seen by a physician, crowded waiting rooms, or inadequate security. While many of these risk factors apply to a hospital setting more often than a private practice, staff may not be as experienced with managing crises with potentially volatile patients. This enhances the importance for employers to develop and implement a plan and then train employees on what signals to watch for and what steps to take should an incident occur. OSHA has identified four categories of workplace violence with type 2 noted as the most common in health care settings. This category also includes threats from a patient's family members and visitors. Should a violent incident occur, the threatening remark or covert act of physical violence needs to be reported and documented. This includes violence against a person or property and whether it was reported or observed. Our main exposure to ionizing radiation is through the use of diagnostic medical exams, including x-rays, CDs, or CAT scans. These radiation sources can pose a health risk to workers if not properly controlled. Radioactive atoms decay spontaneously to emit radiation. Ionizing radiation can injure any tissue in the human body. A radiation exposure plan is needed only if the practice is utilizing equipment that emits radiation and should include appropriate monitoring equipment for employees entering a restricted area that may be exposed to radiation exceeding 25% of the maximum dose. Anyone under the age of 18 who may be exposed to an excess of 5% of the limit and all persons in high radiation areas. LASER stands for Light Amplification by Stimulated Emission of Radiation. According to OSHA, during surgical procedures that use a LASER or an electrosurgical unit, the thermal destruction of tissue creates a smoke byproduct and employers should be aware of this emerging problem and advise employees of the hazards of LASER smoke. LASERs can also cause damage to the eyes. Protective equipment for LASER safety generally means eye protections in the form of goggles, clothing, and barriers and other devices designed for LASER protection. If your practice utilizes lasers, the safety coordinator may designate a LASER safety officer to manage the policies and training related to this equipment. Electrical hazards exist in almost every workplace. Causes of electrical hazards are unsafe conditions and unsafe acts, usually a combination of the two. OSHA addresses the control of hazardous energy in the general industry standard. A lockout, tag out procedure needs to be developed in writing and requires that stored energy such as mechanical, hydraulic, or air is released or blocked before equipment is locked out for service and maintenance. Authorized workers need to be trained on the procedure and identified to other employees. Employers should take all reasonable measures to prevent fires and inform personnel about the fire risks associated with the materials, equipment, and chemicals used in the practice. OSHA requires you to communicate your practice's fire prevention plan to your employees and depending on the number of employees you have, this may be verbal or written. In addition to annual fire safety checks, the safety coordinator should check the condition of fire extinguishers monthly and date the attached inspection cards. The emergency action plan details the plans your practice has in place for certain types of emergencies such as medical emergencies, natural disasters, radiation, chemical spills or releases, and exposures. Putting together a comprehensive emergency action plan is not difficult, but it involves taking what is learned from an evaluation and describing how employees will respond to the different types of emergencies. It is important to take into account the specific layout of your practice, structural features, and emergency systems. OSHA does not specifically require posting evacuation maps, but it strongly recommends them. While health care facilities are affected by only three major categories, training is a critical component in the effort to reduce injuries and illnesses in the workplace. Record keeping for initial and annual training should include the employee's name and role, the dates of training, the material covered, and the name of the trainer or tools. A copy of the training record or certificate should be kept in the employee's file. Those documents must be retained for three years from the date of training, but keeping those for the duration of employment is recommended. Employee training records must be provided upon request to the employee or the employee's authorized representative within 15 working days. OSHA has further clarified that annual training can be a review of the previous training material, noting that the more important function of annual training is to inform employees about new or emerging issues affecting health care workers. This concludes the OSHA health and safety training provided by Doctors' Management in collaboration with the American Academy of Dermatology. Thank you again for partnering with us to ensure your practice maintains OSHA-compliant policies and procedures within your organization.

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