EXECUTIVE SUMMARY

Occupational Safety and Health Administration (OSHA) inspections require preparation for the best results. Healthcare facilities must meet certain industry-specific requirements.

  • Some states are covered by state OSHA plans.

  • Bloodborne pathogen rules are frequently cited in OSHA healthcare inspections.

  • Requirements for hazardous chemicals also are cited often.


Healthcare risk managers should prepare for an inspection by the Occupational Safety and Health Administration (OSHA) because deficiencies can bring significant fines and administrative burden, says Richard Best, PhD, director of regulatory affairs with Stericycle, a company headquartered in Bannockburn, IL, that provides OSHA compliance training and other services to healthcare organizations.

OSHA requires healthcare employers to provide workers with a safe and healthful workplace, free from any known hazards that cause or are likely to cause injury or illness, Best says. OSHA has set forth guidelines to help healthcare facilities ensure their workforce remains healthy amid the COVID-19 pandemic.

While these guidelines are not regulatory requirements, employers should begin implementing them in their daily protocols to get a head start on compliance in preparation for a future OSHA move to issue these guidelines in the form of an Emergency Temporary Standard (as some states have done) that is applicable to COVID-19 or other infectious diseases.

“While OSHA requirements can vary by state, some common protocols related to COVID-19 include conducting risk assessments, creating preparedness and response plans, performing health screenings, and displaying workplace signage that communicates the necessary safety measures,” Best says. “To ensure employers are compliant and adhering to regulations, OSHA can perform unannounced on-site inspections, and employers should expect closer scrutiny concerning providing protections against COVID-19.”

More important than the potential for penalties, noncompliance with OSHA standards and regulations can jeopardize the safety and health of employees.

Upon arrival, the inspecting officer should provide his or her OSHA credentials, Best says. If this does not happen, ask for credentials to confirm the inspector’s legitimacy. The inspection will begin with an opening conference during which the officer will state the reason for the visit.

From there, the inspection may consist of private interviews of employees and could even involve the collection of air samples, photographs, and video of the facility. The visit will conclude with a closing conference to discuss findings.

Preparing for an on-site OSHA visit and inspection can help your facility achieve compliance with OSHA’s requirements. Knowing the OSHA standards with which your facility must comply with is the first step in preparing for a site visit, Best says.

These standards depend to some extent on where the facility is located, as this determines whether it is covered under federal or state OSHA jurisdiction. State plans are required to be at least as strict as the federal standards, and they may carry additional requirements as well.

Aside from knowing which OSHA jurisdiction your facility falls under, there are specific steps that can help you prepare for an OSHA inspection, such as ensuring compliance with applicable standards for your specific workplace, Best says. For example, what about your written bloodborne pathogens exposure control plan (ECP)? The ECP is one of the first things an OSHA inspecting officer will ask to see in a facility.

Are safety data sheets readily accessible in the work area? Is the hazardous chemical inventory master list up to date? Have you considered organizing that list by assigning a number key to the safety data sheet for each hazardous chemical listed?

Such a method of organizing safety data sheets can help employees and associates readily access the safety data sheet they may be looking for, Best says.

Watch for Most Common Citations

While inspections should be thorough, OSHA does look for common violations known as “most frequently cited standards,” Best explains. One of the most frequently cited standards during healthcare facility inspections is the Bloodborne Pathogens Standard, which protects employees who are at risk of exposure to blood or other potentially infectious materials.

OSHA requires all healthcare facilities with such exposure potential to establish a written bloodborne pathogens ECP. An inspector likely will ask to see this plan early in the process.

OSHA’s Hazard Communication Standard, which ensures safety when working with hazardous chemicals, is another commonly cited standard. It requires hazardous chemical inventory lists and safety data sheets to be consistently updated as they inform employees about chemical hazards in the workplace.

The four requirements for compliance include properly labeling chemicals, providing safety data sheets, training employees on all hazardous chemicals to which they may be exposed, and creating a written hazard communication program, Best notes.

Citations are not issued at the time of inspection, but only after further review by the OSHA area director or the equivalent in OSHA state plans.

“If your facility is issued a citation, it will arrive at your office by mail with the notice of any applicable penalties and an abatement or correction date. The notice of violation and citations must then be posted in an area where all impacted employees can view them,” Best says. “If you feel you have been wrongfully issued a citation, you can appeal it to a formal OSHA review board that is separate from OSHA itself. However, overturned citations are not common.”

SOURCE

  • Richard Best, PhD, Director of Regulatory Affairs, Stericycle, Bannockburn, IL. Phone: (847) 367-5910.