OSHA

OSHA’s Injury and Illness Prevention Program (I2P2) provides a framework by which employers can develop and maintain an effective workplace safety and health plan. The six major safety and health plan elements include the following.

1. Practice leadership: A dermatology practice should establish goals for its safety and health program and determine a processes for achieving these goals. The practice should designate and appoint a safety officer, who will have responsibility for implementing and maintaining program compliance. The appointed individual must be granted appropriate authority and provided sufficient resources (time and money) to carry out those responsibilities and tasks.

2. Worker participation: While management has primary responsibility for the safety program, OSHA also requires that management encourage the input of employees throughout the process. Often, clinical staff members are aware of hazards that nonclinical individuals may not see or understand. Those working in exam rooms, treatment areas, or the laboratory will be more attuned to the chemicals used and procedures performed there. Individuals who have recently joined the practice may also be aware of more effective controls, because they have seen them in action at a previous employer.

3. Hazard Identification and assessment: Use the Hazard Assessment form to identify, assess, and document hazards in the practice. Inspect the workplace, solicit input from workers, and document all findings. Review documentation of injuries and illnesses experienced in the practice and identify hazards that may have caused them. Give workers an opportunity to report concerns they may have with an open-door policy, assuring them that there will be no discrimination against those who actively participate.

What are the primary hazards in dermatology practices?

• Blood-borne pathogens (BBPs)

• Hazardous chemicals

• Fire and electrical hazards

• Exit routes

• Lasers

• Ergonomics

To use the Hazard Assessment form, walk through the practice and answer the questions. For example, are the electrical panels accessible and labeled? If yes, no further actions are needed. If no, corrective actions must be implemented immediately. Remove obstacles blocking electrical panel access; OSHA requires a three-foot clearance. Label all active breakers. This will be extremely important when a problem arises and quick action is needed. The persons responding to the emergency must be able to get to the breakers, and they also must be able to determine which breakers to switch.

4. Hazard prevention and control: Using the information gathered in the previous step, develop a written hazard control plan. This plan should provide details on the hazards found and protections that are available against them.  OSHA’s priorities for preventing injuries and illnesses start as far away from the body as possible, working closer with additional controls.

• Elimination or substitution: Safer substitutions have already been made for some chemicals. For example, formaldehyde, a known carcinogen, was once used as a disinfectant; glutaraldehyde is now used. 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. Hoods are used to protect employees from exposure to chemicals. Another example of an engineering control is sharps containers, into which contaminated sharps are discarded.

• Administrative controls: Lasers are used in many skin procedures, but they can have harmful effects to employees unless the proper precautions are followed. Administrative controls for this hazard include the appointment of a laser safety officer, developing and following policies and procedures, and documentation.

• Personal protective equipment (PPE): PPE is the last line of defense; it is a safety net when other controls are not available or effective. PPE such as gloves, gowns, and masks protect employees from blood-borne pathogens when dealing with potentially infectious materials, including blood and unfixed tissue.

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5. Education and training: Schedule a safety meeting to inform employees of the hazards to which they may be exposed while fulfilling their job responsibilities, along with the hazard controls implemented. Train them on the injury and illness prevention program, how they may access the written plan, and their right to receive a free copy. Let them know that management welcomes their input, and that there will be no negative repercussions for those who do. Train the entire staff to recognize hazards and know how to protect themselves and others. Include how employees can report injuries, illnesses, and concerns, and give them an opportunity to ask questions. This training must be documented, and the documentation must be retained for a minimum of three years (some state programs require retention for five years). Refresher education and training must be provided at least annually, but periodic reminders during staff meetings or on bulletin boards are also helpful.

6. Program evaluation and improvement: About six months after implementing the controls and providing training, repeat the hazard assessment, confirming that all control measures have been implemented and remain effective. Sometimes implementing one control can inadvertently introduce another hazard. Repeating the hazard assessment at least every two years will help ensure that the program remains current and effective. Personnel changes and procedure additions or revisions may create new hazards that must be addressed. 

What should employees know?

OSHA provides protection to all workers exposed to hazardous chemicals in all industrial sectors under its Hazard Communication Standard (HCS). This standard is based on the concept that employees have both a need and a right to know the hazards and chemicals they are exposed to while on the job. They also need to be informed about protective measures available. 

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