Columns , Leadership

Uh-oh, it’s OSHA

Don’t be caught unprepared and out of compliance when an inspector shows up. Your employees’ health and safety are at stake.

Uh-oh, it’s OSHA
Regular and structured safety training is an OSHA requirement. Employees must be trained upon hiring, when OSHA standards change, and annually.
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The Occupational Safety and Health Administration (OSHA) was established in 1970 under the U.S. Department of Labor to ensure that Americans have safe and healthy work environments. The agency’s rules and regulations apply to veterinary hospitals and all other businesses.

Regardless of whether an OSHA standard exists, each workplace is responsible for ensuring that safeguards are in place to prevent avoidable injuries and illnesses.

In 2012, OSHA introduced the Globally Harmonized System (GHS), an international effort toward standardization. Some notable updates centered on the identification and labeling of hazardous chemicals (Hazardous Communication Plan), the implementation of an Injury and Illness Prevention Program (I2P2), and the change from Material Safety Data Sheets (MSDS) to Safety Data Sheets (SDS).

So, what does all this mean for veterinary practices? For starters, it means we need to identify all the hazardous chemicals within the hospital and implement a plan to identify and correct potential workplace hazards. The ultimate goal is to mitigate and reduce employee injuries and illnesses. The Hazardous Communication Plan and I2P2 are central pieces of your overall safety program.

Let’s go into more detail.

Hazardous Chemicals

You are probably wondering how to begin your OSHA compliance effort and Hazardous Communication Plan. Take it one step at a time.

  • Perform a workplace assessment and document every hazardous chemical.
  • Create a list of the product name, hazardous chemical, manufacturer and manufacturer telephone number.
  • Obtain an SDS from the manufacturer for each hazardous chemical and every medication kept in the hospital.

Secondary Container Labeling

Part of the requirement for identifying hazardous chemicals is the proper labeling of secondary

containers. This means that anything taken from its original container and placed in another container — something that happens frequently in veterinary hospitals — must be properly labeled.

Systems must be in place to make sure the labeling happens and that label protocols are maintained. The labels are not hard to create and can be purchased from a veterinary product distributor. The updated OSHA requirement states that labels must include the following information:

1. Product identifier: the product name
2. Harmonized signal word: danger, caution etc.
3. Hazard statement: flammable, corrosive, etc. 
4. Precautionary statement: what not to do
5. Company information: who and where
6. Harmonized Pictograms

Safety Data Sheets

Every chemical has a Safety Data Sheet. It is important that the practice have a complete set of SDS’s for all onsite chemicals. Start with your hazardous chemical list and then work on collecting sheets for every medication and chemical, whether hazardous or not. SDS’s are available from suppliers or from the place of purchase in the case of cleaning supplies (usually the website). Whether you keep printed copies in a binder or store them on a computer, every employee must know how to access them.

Safety Personnel

Gone are the days of the solo safety officer. Although someone needs to take the lead on employee safety, a safety committee is more appropriate and more effective. Consider building your committee with a representative of each department. A well-rounded committee spreads the workload, leading to more accountability.

The functions of the safety committee are to:

  • Perform regular facility inspections and hazard assessments.
  • Participate in quarterly incident reviews.
  • Develop action plans for correcting hazards.
  • Maintain an SDS library.
  • Ensure secondary label compliance and maintenance.
  • Develop training programs and updates.
  • Institute safety plan updates.

Facility and Hazard Assessments

Hospital inspections are required to take place annually, when OSHA regulations change, when a facility changes, or following an incident or quarterly trend analysis. Part of the inspection is the hazard assessment, which should focus on:

  • Known or potential hazards in each work area.
  • Hazards that can be avoided or minimized with personal protective equipment (PPE).
  • PPE limitations.
  • The use of signs or tags to signal potential hazards or dangers.
  • Compliance with required OSHA postings and reporting forms (Poster 3165 and forms 300, 300A and 301).

When hazards are identified and PPE is required, training on when and how to utilize PPE, and its proper care and maintenance, is necessary. Employees must comply with newly enacted safety protocols and procedures. Hospital leaders should set the example, and employees who fail to adhere to safety protocols must be held accountable.

Employee Training

Regular and structured safety training is an OSHA requirement. Employees must be trained upon hiring, when OSHA standards change, and annually. Make safety training a part of every meeting. This means more than just presenting information to employees. OSHA has moved from a “right to know” to a “right to understand” requirement.

Also, keep a copy of training records. Document the attendees, the safety issue addressed and any programs instituted. Make sure every employee knows where the Injury and Illness Prevention Program (IIPP) and Hazard Communication Standard (HCS) — materials developed by the safety team — are located. These are resources an OSHA inspector will ask to see during a visit.

When it comes to OSHA, all practices must take a proactive, rather than reactive, approach.

As you identify potential hazards, develop a safety manual. Prepare detailed safety plans that outline policies and procedures designed to prevent injury and illness.

Where Trouble Lurks

Here are the top 10 OSHA violations committed by veterinary practices, as reported by AVMA PLIT.

  1. No hazard communication program.
  2. No certification of personal protective equipment assessment.
  3. No fire and emergency plans.
  4. Poor employee training documentation.
  5. Lack of Safety Data Sheets.
  6. Inappropriate personal protective equipment.
  7. Poor or no chemical labeling.
  8. OSHA forms not utilized.
  9. Human food in unsafe areas.
  10. No control of waste anesthetic gases.

Financial Penalties

Need an incentive to be compliant? OSHA fines jumped by about 80 percent in August 2016 — the first increase in 25 years — and will rise annually to keep pace with inflation. If you think compliance is expensive, consider the list below as a reality check. The fines shown are per violation and are cumulative.

No business wants to be on the receiving end of an OSHA inspection and fine, but by paying attention to rules and regulations you can achieve and maintain compliance and provide a safe work environment for employees.

Additional OSHA information, resources and updates can be found at www.osha.gov.

Getting Technical columnist Sandy Walsh is a practice management consultant, speaker, writer and instructor for Patterson Veterinary University.

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