Notes from the Field: Don’t tell me that pile of papers is your OSHA manual!

By: October 19th, 2010 Email This Post Print This Post

During my mock OSHA inspections, I always ask to see the practice’s OSHA manual. I have seen manuals that haven’t been touched for so long that I could blow dust off them.

Sometimes no one in the practice can find the manual. During an inspection last week, the OSHA manual was a collection of notes from previous OSHA seminars. I even saw one of my handouts from a seminar I taught years ago. The manager thought she could just put the power point hand-outs in a notebook and call it her OSHA manual.

OSHA is very serious about what hazards apply to healthcare settings and therefore what policies and procedures to address those hazards you should include in your OSHA manual.

Some of the policies that should be included are from a best practices approach are:

  • Bloodborne pathogens exposure control plan
  • Decontamination/disinfection procedures
  • Ergonomics
  • Emergency action plan/evacuation procedures
  • Hazard communication policies
  • Respiratory protection and infection control
  • Workplace violence prevention plan

You are also expected to document initial and annual OSHA training, annual evaluations of safety sharps, safety exercises such as fire drills (if required), housekeeping procedures, and safety logs such as autoclaves and emergency eyewash stations.

The manual should include documentation that someone has reviewed and updated the manual with any new regulations at least annually.

Every employee covered under the Bloodborne Pathogens standard needs to know the location of the Exposure Control Plan.

I recommend that all offices purchase an OSHA manual from a reputable company. Make sure you are not buying a book that merely tells you what OSHA standards possibly apply, but one that helps you create applicable policies and procedures for your practice and provides tools to help you stay in compliance.

Also, the manual should be well organized and easy to understand.

I have used the same manual for years, the HCPro OSHA Program Manual for medical facilities, and I find it meets all of the Department of Labor requirements for healthcare facilities.

Get into compliance with HCPro’s Basic OSHA Compliance Manual Kits for medical or dental practices. Receive bimonthly electronic manual updates through your newsletter subscription that keep your regulatory manual up to date and in compliance!
 

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