OSHA compliance: More important than ever
Answers in Practice
By Faiza Wasif, MPH, May 1, 2020
Each month DermWorld tackles issues “in practice” for dermatologists. This month Faiza Wasif, MPH, the Academy’s practice management manager, explains OSHA.
Established in 1970, the Occupational Safety and Health Administration (OSHA) ensures safe and healthy working conditions for people, enforces standards, and provides training, outreach, education, and assistance. In other words, OSHA’s mission is to save lives, prevent injuries, and protect the health of American workers. This mission has become increasingly important given the ever-changing global environment and its direct impact on work environments — including staying compliant during the COVID-19 pandemic.
Nearly all dermatology practices must comply with OSHA requirements. Therefore, practices are encouraged to become familiar with OSHA requirements and implement a complete OSHA compliance program. An effective safety and health program can save time and money — about $4–6 for every $1 spent — and can increase productivity as noted on the official OSHA website. So, what does compliance entail?
The six major safety and health plan elements include the following:
1. Practice leadership: A dermatology practice should establish safety goals and determine a process for achieving these goals, including designating and appointing a safety officer who is responsible for implementing and maintaining program compliance. Most dermatology practices will look to their office manager/administrator as the safety officer. The officer must be granted appropriate authority and provided enough resources — time and money — to carry out those responsibilities and tasks.
2. Employee participation: While management has primary responsibility for the safety program, OSHA also requires that management encourage the input of employees — both clinical and non-clinical — throughout the process. Often clinical staff tends to be more attuned to OSHA standards given the nature of their work, but it is important to ensure non-clinical staff is equally educated and prepared. The same holds true for new employees who should be properly trained and ready to mitigate any issues.
3. Hazard identification and assessment: Use the Hazard Assessment Form (PDF) to identify, assess, and document hazards in the practice. Typical hazards in a dermatology practice include:
Blood-borne pathogens (BBPs)
Hazardous chemicals
Fire and electrical hazards
Exit routes
Lasers
Ergonomics
4. Hazard prevention and control: Using the information gathered with the hazard assessment form, develop a written hazard control plan that outlines the identified hazards and related safeguards. OSHA’s priorities for preventing injuries and illnesses include the following measures:
Elimination or substitution: Use safer chemical substitutions when possible. For example, formaldehyde — a known carcinogen — was once used as a disinfectant but an alternative, glutaraldehyde, is now used. Similarly, toluene can be replaced by Americlear, ProPar Clearant, and other similar compounds.
Engineering controls: Formaldehyde and xylene — both known to be hazardous — are used extensively in histology procedures, but hoods are used to protect employees from exposure to these chemicals. Another example of an engineering control is sharps containers, into which contaminated sharps are discarded.
Administrative controls: Lasers are commonly used in many skin procedures, but they can have harmful effects on employees unless the proper precautions are followed. Administrative controls for this hazard include the appointment of a laser safety officer, developing and implementing policies and procedures, and documentation.
Personal protective equipment (PPE): PPE is considered the last line of defense as it is a safety net when other controls are not available or effective. PPE such as gloves, gowns, and face masks protect employees from blood-borne pathogens when dealing with potentially infectious materials.
5. Education and training: Education and training is key to successful compliance. You can complete the AAD’s new OSHA compliance certification series, or follow these steps:
Schedule a safety meeting to inform employees of hazards to which they may be exposed while fulfilling their job responsibilities and hazard controls that have been implemented.
Train them on the overall injury and illness prevention program for the practice.
Identify how employees can access your practice’s written plan and their right to receive a free copy.
Let employees know that management welcomes their input and that there will be no negative repercussions for sharing it.
Train the entire staff to recognize hazards and know how to protect themselves and others including how injuries, illnesses, and concerns, can be reported.
Give staff an opportunity to ask questions ensuring that they are answered honestly and comprehensively.
Document the trainings and retain the documentation for a minimum of three years (some state programs require retention for five years).
Annually, conduct a refresher education and training, but be sure to send out periodic reminders and put up pertinent information on bulletin boards.
6. Program evaluation and improvement: About six months after implementing the controls and providing training, repeat the hazard assessment (PDF), confirming that all control measures have been implemented and remain effective. It’s important to reassess at least every two years because sometimes implementation of one control inadvertently introduces another hazard and often there are personnel changes, procedure additions, or revisions to certain practices that may create new hazards which must be addressed.
Before delving into these steps though, see how compliant your practice is by completing a short, Academy-developed OSHA questionnaire. After completing the questionnaire, you will be able to see gaps in your practice and will get a list of resources to help you become compliant.
In addition to completing the questionnaire, be sure to visit the Academy’s OSHA webpage to get timely dermatology-relevant guidance.
As always, visit the Member Practice Center to get your practice management questions answered!
Additional DermWorld Resources
Sidebar
Academy OSHA resources
Visit the Academy's OSHA Resource Center for timely dermatology-relevant guidance on OSHA.
COVID-19 resources
Visit the Academy's COVID-19 Resource Center for a variety of resources on how to manage your practice during COVID-19,
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