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Safety First: Utilizing OSHA to Protect Practice Staff

Wednesday, September 11, 2019 9:00 AM

Billing, Coding & Compliance

Written by: C. Jolynn Cook

C. Jolynn Cook
Former Senior Consultant

Whether you are a construction worker at a job site or a practice administrator sitting at a desk, the Occupational Safety and Health Administration — commonly known as OSHA — is responsible for ensuring a safe, healthy work environment for all. While standard safety precautions (e.g., fire prevention and injury safeguards) are common sense, it can be difficult to determine how more nuanced OSHA regulations apply to vastly different work environments. With that said, it’s not surprising that a common question I receive as a consultant is, “What OSHA rules and regulations apply to my practice?”

Medical Practices and OSHA

The application of OSHA standards can vary between practices, depending on the services offered and the risk of injury to employees. This can result in procedure variations among different clinics or departments. Regardless of slight distinctions in procedures, there are two OSHA standards that consistently apply to medical practices: the Bloodborne Pathogens Standard and the Hazard Communication Standard.

The Bloodborne Pathogens Standard

To protect workers against health hazards caused by bloodborne pathogens, OSHA places specific requirements on employers whose workers may encounter blood or other potentially infectious materials (e.g., unfixed human tissues and certain body fluids). These requirements are known as the Bloodborne Pathogens Standard (BBP).

The BBP dictates that related OSHA guidelines are contained within the practice’s Exposure Control Plan (ECP), otherwise known as the "OSHA Manual." Specifically, the ECP must address (1) how the practice assumes responsibility for an employee’s exposure to bloodborne pathogens and (2) how to safely handle hazardous chemicals. Furthermore, since OSHA dictates that each practice/office is unique, the ECP plan must identify specific risks in each practice work environment. The ECP must also include a list of the potential risks related to each job category within the practice.

OSHA training is required at the time of hire for all positions while ongoing training must be conducted annually. Instruction must also occur when anything is added or changed (such as incorporating a new piece of equipment or an employee being reassigned to a different work area). For example, if an employee who previously worked in the billing office is interested in becoming a technician, he or she should partake in an OSHA review. Topics should include the Bloodborne Pathogens Standard and the location and care of sharps containers. In addition, the transitioning employee should be offered the Hepatitis B immunization series.

The Hazard Communication Standard

In order to ensure chemical safety in the workplace, OSHA’s Hazard Communication Standard (HCS) mandates that information about the identities and hazards of chemicals must be available and understandable to workers. The HCS requires chemical manufacturers, distributors, or importers to provide a Safety Data Sheet (SDS), previously referred to as a Material Safety Data Sheet (MSDS), to communicate the safety risk for an employee while using a hazardous chemical product.

An additional requirement of the HCS states that new SDS sheets must follow uniform formatting, including 16 section numbers and headings.* Finally, employers must ensure that SDSs are readily accessible to employees.

It's recommended that you review your Exposure Control Plan to ensure it is up to date. To determine if you have current OSHA information, look at your SDSs. If SDS updates were not made, your ECP is likely out of date, and it is time to review and revise it.

Staff Safety

Protecting your employees is paramount, and OSHA is there to help guide you. By following OSHA's rules and regulations you are providing the proper resources, education, and training to keep your staff safe while in the workplace. An added bonus is being compliant.

*While OSHA does not enforce sections 12-15, these sections are regulated by other agencies.

WE CAN HELP. Contact us if you need assistance navigating the regulatory compliance landscape. 


  • Charlie Nungaray said Reply

    I have been unable to find a clear answer to this question: Do we need SDS sheets for sample drugs in the office that are given out to patients such as glaucoma drops or artificial tears?

    Thank you,
    Charlie Nungaray, COT
    Clinic Operations Manager
    San Luis Obispo Eye Associates

    • BSMAdmin said Reply

      Hello Charlie,

      Excellent question. OSHA requires Safety Data Sheets to inform employees how to safely handle hazardous chemicals. Glaucoma drops and artificial tears are likely not considered to be classified as hazardous chemicals, unless perhaps if ingested, as they are intended to be administered topically. The best way to confirm this is with the manufacturer, who has a responsibility to provide you with the Safety Data Sheet, if there indeed is one. I hope this is helpful.

      C. Jolynn Cook
      BSM Senior Consultant

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