Notes from the field: Hide the coffee cup; the OSHA Lady is here!

By: Kathy Rooker September 25th, 2009

I hear that coffee-cup-OSHA-Lady description of myself almost everyday when I visit medical practices. I am not from OSHA (Department of Labor), and I am not in your office to perform a real, reportable, OSHA inspection. I am a healthcare consultant, who specializes in OSHA compliance. As a part of your facility’s OSHA compliance program, I will perform an annual “mock” OSHA inspection.

I will not report my finding to OSHA. That is not my intention. I am there as your safety officer, and to assure that all of the staff and physicians are working in a safe environment.

Here is what I, and other good consultants, can do for your practice, and why an annual mock inspection is an essential component to a comprehensive OSHA compliance program.

There are four main areas of focus for OSHA compliance in the healthcare setting. They are:

1. General health and safety
2. Bloodborne pathogens
3. Hazard communication
4. TB/ infection control

I will inspect the facility to assure that engineering and work practice controls have been implemented. These are the primary means of eliminating or minimizing employee exposure to bloodborne pathogens. I will ask to see all sharps used in the office. Is the office using safety needles, lancets, scalpels? Have proper evaluations been performed during the implementation process? Are sharps containers properly placed? Is personal protective clothing and equipment available for employee use?

Are the fire extinguishers inspected on an annual basis? Are there boxes piled at the back door blocking your means of egress? Does the solution used to clean the counter tops list the efficacy for HIV, HBV, and TB? Are you using an autoclave and performing the proper monitoring?

The Quality America OSHA Safety Program manual contains an excellent “Annual Facility Review Checklist” (Go to the Tools page to download the checklist). It is very important to do these annual inspections. With staff changes and the everyday, hectic schedule in the office, it is just too easy to let things slip.

Your office should always be ready for “WHEN” not “IF” an inspector from OSHA comes to your office.

Annually review your OSHA manual to assure all new policies have been documented in the manual.

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Kathy Rooker



Kathy Rooker is the safety officer and owner of Columbus Healthcare & Safety Consultants, Canal Winchester, OH (krookerchsc@gmail.com or 614-833-9092). Rooker has more than 35 years experience working in the healthcare field and currently provides OSHA and CLIA consulting and inspections for physician practices and conducts OSHA annual training seminars in and around Central Ohio. In her "Notes from the Field" posts, she shares real life OSHA compliance issues and offers solutions to these sometimes complicated situations.

Kathy has written 19 posts.

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