As we all know, OSHA is the regulatory body that provides the rules to ensure our staff safety, and offers its own challenges in compliance.
Sometimes the rules can be confusing and complex. How do we feel confident that we are both covering all the rules and are well prepared should a staff exposure or injury occur?
Here is the way I approached it, and I now feel like I covered all the bases.
First,
I created an OSHA manual and divided it into three sections:
- Education
- Prevention
- Exposure Response.
I then added an annual appointment on my Outlook calendar as
“OSHA day”
to remind me to review and update policies and verify training and health updates. I recommend getting everyone on the same annual review time frame so that you don’t need to track individually. I also re-post my sharps injury log and workplace injuries form.
I started the manual with a Resource page~
that includes my OSHA contact information:
- Worker’s Comp Carrier (name, address, contact information)
- Employee care referral contact information (urgent care, emergency room, infectious disease specialist)
- Hazard disposal provider
- Linen provider
Then I added the following tabs:
Education:
I included the following:
- My annual training information and documentation
- All OSHA policies, including my Exposure Control Plan, Sharps injury prevention, and Safe injection practices policies.
I also included the form I utilize to attest the policy annual review. The Exposure Control Plan needs to include:
- Exposure determination (the risk related to job description)
- Utilization of universal precautions
- Engineering controls (how you remove hazards-sharps containers, etc.)
- Work practice controls (how you protect employees-PPE)
- How hazards are communicated (SDS book)
- Exposure plan (what to do when)
As far as training, you probably know, it needs to be upon hire and annually,
If you haven’t already, make sure your staff is all trained in the conversion from MSDS to SDS, and that you converting your book to the new forms.
Prevention:
Here, I have copies of the following forms:
- Hepatitis B form
- Tuberculosis screening form
- influenza immunization/declination form
- Safer sharps evaluation form. Fill this form out annually and involve your staff-can you decrease risk by using a safer product? –and keep it in the manual.
Exposure Response:
In this section, I included a Post-exposure form I created that includes a step by step process on what to do in the event of an exposure. I also included an informed refusal form and a lab requisition form for our contracted lab. It is a great reference tool to avoid scrambling should you have an exposure. I keep a lab bag with drawing supplies and the appropriate tubes secured in a ziplock in case an exposure draw is needed.
I found a really great resource on the OSHA web site. Here is the link: https://www.osha.gov/OshDoc/data_BloodborneFacts/bbfact01.pdfI
As you do your OSHA review, do a walk-through and check your eye wash stations, PPE, spill kit and the like. Or make it part of your monthly safety checklist. Hopefully, with these tips to make the process simpler, you will be well prepared for that next audit or potential employee incident.