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What do OSHA inspectors look for in healthcare settings?

By: February 6th, 2013 Email This Post Print This Post

OSHA inspectors are usually interested in (and legally entitled to) review of:

  • The bloodborne pathogens exposure control plan
  • The hazard communication program/MSDSs
  • Posters and logs (e.g., “It’s the Law” poster and sharps injury logs)
  • Hepatitis B vaccination records
  • OSHA yearly training records
  • General safety records

*This is an excerpt from The OSHA Training Handbook for Healthcare Facilities by Sarah E. Alholm, MAS.

Reporting a patient fatality to OSHA

By: January 16th, 2013 Email This Post Print This Post

Q: We had a patient experience a fatal reaction to an injection. We understand we have to do an incident report for our risk management, but didn’t know whether we need to complete an OSHA incident form since it wasn’t a safety incident per se but rather an unexpected allergic reaction.

A: Since OSHA is only concerned with employee safety, you do not have to report a patient fatality to OSHA. However, since the fatality was associated with a drug (injection), voluntary reporting to the FDA under the MedWatch program does apply. A patient death is considered a “serious adverse reaction,” and the FDA states it should be reported. The report is made on form FDA 3500. It is voluntary to file this report, but I encourage you to do so, as the MedWatch is how the FDA tracks the safety of pharmaceutical products on the market. If the FDA were to get a number of reports on a particular lot of product, a recall could be initiated. For more information, see

*This is an excerpt from The OSHA Training Handbook for Healthcare Facilities by Sarah E. Alholm, MAS.

Adding “Negative Nellie” to the safety committee

By: January 9th, 2013 Email This Post Print This Post

Q: Our office’s “Negative Nellie” wants to be on the safety committee. I am sure she would see plenty of horribly dangerous issues. She seems to have problems with how everything else works, after all. She makes working toward change impossible. I’m afraid if I say no, she’ll bad-mouth safety to everyone. What can I do?

A: First, consider whether it makes sense for her to be on the committee based upon her job position. If it totally doesn’t make sense, explain to her nicely that you have a limited amount of space and really need clinical (or fill-in-the-blank) people on the committee. If it does make sense for her role to join the committee, work hard to make sure it doesn’t become a complaint venue. Set clear ground rules that emphasize finding solutions, not just listing problems. Work hard to make her feel heard and understood. Employees may get frustrated if they don’t feel their concerns are being taken seriously and call OSHA just to be heard. These types of calls are the top reason an inspector will come knocking at your door.

*This is an excerpt from The OSHA Training Handbook for Healthcare Facilities by Sarah E. Alholm, MAS.

Organizing the MSDS

By: December 11th, 2012 Email This Post Print This Post

Q: I am trying to standardize and simplify the organization of the MSDS in our organization. Many products that we use have a constituent in them that may be hazardous. In a true emergency, the employee may not know what hazardous substance is in the product but should know to look it up in the MSDS manual. An example is laboratory test kits that may contain a diluent or extraction solution. In that case, do you organize the MSDS by the manufacturer’s brand name, or by the common name of the product? What are you suggestions/guidelines?

A: My recommendation is to organize alphabetically based on the common names, since in an emergency this is where staff members will look first for information. OSHA requires that the name on the actual container label match up with the name on the MSDS, so do a spot check of this, too. If you use an identical product from multiple manufacturers, you don’t have to file an MSDS for each company. A single representative MSDS is okay as long as the information is complete and your staff members know which product it’s for.

*This is an excerpt from The OSHA Training Handbook for Healthcare Facilities by Sarah E. Alholm, MAS.

Portable fire extinguishers

By: December 3rd, 2012 Email This Post Print This Post

Q: How should I mount and mark portable fire extinguishers? Is it mandatory for fire extinguishers to be mounted on the wall or poles? Do they need to have a sign? Do they need to be painted red?

A: According to OSHA’s Fire Protection standard (29 CFR 1910.157), “the employer shall provide portable fire extinguishers and shall mount, locate, and identify them so that they are readily accessible to employees without subject the employees to possible injury.” So yes, please mount your portable extinguishers within 75 feet of employee work areas, 50 feet for class B or C extinguishers. Also, use appropriate labels/signs so the extinguishers can be identified. Regarding painting the extinguishers, in the United States they are usually red, but this is not a requirement. The color of the extinguisher often depends on its contents. For example, sometimes dry chemical extinguishers are yellow to distinguish them from carbon dioxide extinguishers (red), especially if both types are used in the same area.

Finally, obtain the MSDS for the fire extinguisher you use in your facility and keep it on file.

*This is an excerpt from The OSHA Training Handbook for Healthcare Facilities by Sarah E. Alholm, MAS.

Pamphlet racks in exit routes?

By: November 26th, 2012 Email This Post Print This Post

Q: In exit hallways, if there are items that are attached to the walls, such as computers or pamphlet racks, is this a problem? There is still about four feet of space to exit.

A: It could be a problem, but if there actually is four full feet of space, it’s probably not. OSHA states: “Objects that project into the route must not reduce the width of the exit route to less than the minimum width requirement.” Exit hallways must be 44 inches wide, so measure carefully how far your computers and pamphlet racks extend into the corridor.

*This is an excerpt from The OSHA Training Handbook for Healthcare Facilities by Sarah E. Alholm, MAS.

View the OSHA Emergency Exit Routes fact sheet here:



Who needs to wear lab coats?

By: November 20th, 2012 Email This Post Print This Post

Q: Are medical doctors and nurse practitioners obligated to wear lab coats when seeing patients?

A: It depends. PPE in the form of fluid-resistant garments (gowns or lab coats) is required to be worn by employees whenever the procedure being performed may be reasonably anticipated to splash or spray blood or OPIMs.

Lab coats may or may not be considered PPE, depending on whether the fabric they are made out of is fluid resistant. If lab coats are fluid resistant and provide coverage in the form of high necks, etc., they can be considered PPE. The lab coats would have to be worn during procedures in which a splash/spray exposure could be expected. If the procedures performed cannot be reasonably anticipated to result in splashing or spraying blood or OPIMs, body protection garments are not called for.

The requirement to wear PPE also depends on whether the providers are employees of a corporation or if they are owners of a practice. As employers (if the providers were the owners), the requirements of the Bloodborne Pathogens standard placed upon employees technically do not apply. However, we encourage employers to abide by OSHA requirements to reinforce the important of safety in the facility.

*This is an excerpt from The OSHA Training Handbook for Healthcare Facilities by Sarah E. Alholm, MAS.

Who should attend safety meetings?

By: November 12th, 2012 Email This Post Print This Post

Q: I’m planning safety meetings for our staff (not yearly retraining). Are clerical employees required to attend every meeting if only medical issues are being discussed? Is a quarterly meeting okay?

A: No, clerical employees do not need to sit through meetings solely on clinical safety items. Quarterly meetings are good, but don’t overlook all the opportunities you already have at your normal staff meetings. Take a couple of minutes to talk about a safety-related topic. Timely events and examples really hit home. You’d be surprised how many poeople in your office can’t describe where to find the fire alarms or how to operate the eyewash station. Just three to five minutes at the start of the meetings really reinforces a safety-first attitude. For maximum impact, keep these mini-presentations short and to the point. You may not even need another quarterly staff safety meeting!

*This is an excerpt from The OSHA Training Handbook for Healthcare Facilities by Sarah E. Alholm, MAS.

Hello from the new Managing Editor

By: October 29th, 2012 Email This Post Print This Post

Greetings, OSHA Healthcare Advisor readers!

My name is Will Kilburn, and I’m the new managing editor for several of HCPro’s safety newsletters and ezines, including Medical Environment Update, Briefings on Hospital Safety/Healthcare Security Alert, OSHA Healthcare Connection, Infection Control Weekly Monitor, and Hospital Safety Connection.

In addition to sending news and information out to you, I’ll also take an active role in the conversation between HCPro and you: Posting and moderating discussions on the OSHA Healthcare Advisor Blog as well as Mac’s Safety Space, and monitoring the OSHA Compliance Hotline to make sure your questions get answered by one of HCPro’s experts.

Over the next few months, I’ll also be asking for your opinions and ideas about what we at HCPro do, and how we can do it better. If you have comments, story suggestions, or requests for healthcare safety-related material, please let me know by emailing or calling 800-650-6787 x3714.

Ask the expert: Training for an electronic MSDS system

By: October 22nd, 2012 Email This Post Print This Post

Q: We use an electronic MSDS access system. Are there any special training requirements we need to know about?

A: The most important training requirement beyond those listed in the standard would be teaching staff members how to use the electronic system to access the required information (how to launch the program, any login requirements (e.g. a password), how to navigate the system to find the desired document, etc.) According to OSHA Hazard Communication standard (29 CFR 1910.1200), MSDSs must be “readily available,” so I wouldn’t be surprised if an OSHA inspector asked one of your staff members to demonstrate the use of the system. Another aspect you’ll need to include is how to get an MSDS in the event of an electronic system failure, such as a power outage. Is there a backup generator to power computers on the system? Is the information available by phone? Are there (current) paper copies of the MSDSs somewhere in the office?

*This is an excerpt from The OSHA Training Handbook for Healthcare Facilities by Sarah E. Alholm, MAS.

Ask the expert: Safety training in a medical office

By: October 15th, 2012 Email This Post Print This Post

Q: How often does safety training (bloodborne pathogen, hazardous materials, respiratory, etc.) need to be done within a medical office?

A: Strictly speaking, the only education pieces with specific recurring frequencies are the bloodborne pathogens education and respiratory protection education, which are required to be provided prior to initial work assignment and then annually thereafter.

Also, if there’s an expectation that folks in your office would use fire extinguishers as part of the fire response plan, then there is an annual requirement for extinguisher education as well (OSHA doesn’t specify the nature of the education, so it could be hands or on by demonstration, which could include a video presentation).

Interestingly enough, there is no OSHA  requirement for annual fire drills, but if your medical office operates under the auspices of a hospital, there is an annual requirement for fire drills (and to be quite honest, it would have to be considered an excellent practice to conduct fire drills at least annually).

Other education concerns such as hazard communications and emergency response are required prior to initial work assignment and then whenever there is a change to procedures. There are a number of other potential education concerns that are promulgated as a function of General Industry; to that end, you may find the information on the following webpage ( to be of use, depending on your circumstance.

- Answered by Steve MacArthur, consultant for The Greeley Company, a division of HCPro, and author of Mac’s Safety Space.

Ask the expert: Should biohazard bins be kept behind closed doors?

By: August 27th, 2012 Email This Post Print This Post

Q: We are based in Colorado. Do our red bins for biohazard waste need to be locked in a closet or if it is OK to keep them behind a closed door that is not necessarily locked?

A: There is no specific OSHA regulation that requires medical waste to be locked in a closet, and in looking at the Colorado state public health regulations, it appears that there is no specific requirement to keep medical waste in a locked closet on that count either. If there is a relationship with a local hospital, it may be worth checking with them to see if there is a specific requirement (if there is one anywhere, it would be in the state regulations as there are none at the national/federal level), but it looks like a closed door will suffice.

Now, I will complicate things just a little bit by saying that if you have clinic settings that provide care and services to at risk populations like pediatric and/or behavioral health patients, then you might be better off locking the closet to ensure their safety. It’s definitely a judgment call, but there are certainly instances in which erring on the side of caution is more than appropriate.

–Steve MacArthur

Steve MacArthur is a safety consultant for The Greeley Company, a division of HCPro. He brings 30 years of healthcare management and consulting experience to his work with hospitals, physician offices, and ambulatory care facilities across the country. He is the author of HCPro’s Hospital Safety Director’s Handbook and is contributing editor for Briefings on Hospital Safety.

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