Ensure that your facility complies with OSHA deadlines and regulations.
These 19 action items for annual OSHA (or other regulatory agency) requirements affect most healthcare facilities, including medical practices, dental offices, and community providers.
1. Document that you have reviewed and updated your bloodborne pathogens exposure control plan (ECP).
2 Document that you have evaluated and implemented safer medical devices, including documentation that you have solicited nonmanagerial input regarding safer devices.
3 Provide and document bloodborne pathogens training to all employees.
4 Log all sharps injuries for your office or facility (unless exempt).
5 Log all work-related injuries and illnesses with the OSHA 300 form (unless exempt).
6 Document injuries and illnesses on OSHA 301 incident reports (unless exempt). Be aware that new reporting requirements mean that any work-related hospitalization of even a single employee now requires notifying OSHA within 24 hours.
7 Summarize and post from Feb 1 to Apr 30 all work-related injuries and illnesses, using the OSHA 300A form (unless exempt).
8. If you have not already done so, train all your employees on the following updates to the Hazard Communication Standard:
- Revised label elements for hazardous chemicals
- Revised Safety Data Sheet format (replacing MSDS)
- Pictograms manufacturers will be required to use on product labels.
This updated training was required to have been completed by Dec 1, 2013 and is in addition to the basic Hazard Communication training mentioned in item 9 below.
- Initial Hazard Communication training is required in all states for all employees who have the potential for exposure to hazardous chemicals. Consider offering this training annually instead of just initially. (Annual Hazard Communication training is required in some states but is a best practice even in those states not mandating annual training.)
- Train your employees on formaldehyde use, if affected.
- Provide required respiratory protection training and fit testing, if affected.
- Provide annual tuberculin skin testing, if required.
- Provide annual notice to employees about the location of employee exposure and medical records and how they may obtain access.
- Ensure employees are aware of the Emergency Action Plan, Facility Rally Point and Fire Prevention Plan for your facility.
- Ensure your employees know and understand fire safety, and train all your employees who may use portable fire extinguishers on the appropriate use, if applicable.
- Provide Department of Transportation (DOT) training (required every 3 years) for your employees who package biohazardous waste for transport or who sign the shipping papers.
- Provide annual Biohazardous Waste Training as may be required in your state or recommended annually as a best management practice in all states.
- Check your waste acceptance protocol for your service provider, and review with staff to ensure you are complying with the requirements. Minimize what must go out as regulated medical waste.
- Contact Stericycle to help make compliance easy with the Steri-Safe program.
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