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OSHA Regulations – A Health Care Organization Guide

There are several OSHA standards that apply to health care facilities regardless of their size. The standards referenced below merit constant vigilance in patient/resident and employee safety. “All Employees are becoming more aware of the law and their rights as employees,” according to the Occupational Safety and Health Administration. As a result, complaints are on the rise, especially in the area of bloodborne pathogens exposure.

OSHA’s Bloodborne Pathogens Standard, published in Title 29 of the Code of Federal Regulations 1910.1030, details what employers must do to protect workers whose jobs put them at a reasonable risk of coming into contact with blood product and other potentially infectious materials. Management’s commitment and employee involvement are required. A worksite analysis must occur regularly to identify and correct any existing or potential hazards. The OSHA web site contains a reference site entitled, “OSHA Small Business Handbook” that can be downloaded and checked regularly for current information on OSHA Regulations.

  1. Bloodborne Pathogens Standard:
    • Establish an Exposure Control Plan. This is a written plan designed to decrease employee exposure or completely remove the potential for an exposure. This plan must be site specific and updated on an annual basis to reflect technological changes that will help eliminate or help reduce an exposure to bloodborne pathogens. The plan must demonstrate that the organization is taking into account innovations in medical procedures and technological developments that reduce the risk of exposure such as needleless devices, syringes with a sliding sheath that shields the attached needle after use, or needles that retract into a syringe after use. The organization must also solicit input from front-line employees responsible for direct patient/resident care in the identification, evaluation and selection of safer medical devices. Employers are required to document, in the Exposure Control Plan, how they received input from their employees.
      • For a sample OSHA Bloodborne Pathogens Exposure Control Plan access  www.osha.gov.
    • Use Engineering Controls. These are the devices that isolate or remove the bloodborne pathogen hazard from the workplace. This includes sharps disposal containers, self-sheathing needles, and safer medical devices.
    • Enforce Work Practice Controls. This standard mandates universal precautions for treating all body fluids/materials as if infectious. Organizations should develop appropriate procedures for hand washing, disposing of sharps, lab specimen packaging, laundry handling and cleaning of contaminated material.
    • Provide Personal Protective Equipment. It is the healthcare organization’s responsibility to provide gloves, gowns, masks and goggles and to clean, repair and replace this equipment as needed.
    • Provide Hepatitis B Vaccinations. These vaccinations should be offered to all employees with an occupational exposure to bloodborne pathogens within 10 days of their hire. Employees that refuse the vaccination should sign a statement declining the offer. This signed statement should be maintained on file.
    • Provide Post-Exposure Follow-Up.  Any worker who experiences an exposure incident will be provided with medical follow-up at no expense to the worker. The medical follow-up includes laboratory testing and confidential medical evaluation.  If the source patient consents, they should be offered laboratory testing and confidential evaluation and counseling.  (Refer to state statute if testing is for the diagnosis of HIV status.)  A confidential sharps injury log must be maintained. The medical records of employees with an exposure to bloodborne pathogens must be retained for the duration of employment plus thirty years. All medical information must remain confidential.
    • Use Labels and Signs Identifying Hazards. The standard requires warning labels to be affixed to containers of regulated waste such as sharps disposal boxes, refrigerators and other containers used to store or transport blood or other potentially infectious materials. Facilities may use red bags or containers instead of labels. Employers also must post signs to identify areas where hazardous waste is stored.
    • Provide Information and Training to Employees. Employers must ensure that their workers receive annual training that addresses the dangers of bloodborne pathogens, preventive practices and post-exposure procedures. An instructor must be present to answer any questions. A tape or video can be used to augment the instruction. The employer is responsible for maintaining a record of all employees’ training.

  2. OSHA’s Hazard Communication Standard (Title 29 C.F.R. 1910.1200)  is also known as “The Right to Know” Law:
    • Material Safety Data Sheet (MSDS). If the office or long term care facility contains hazardous chemicals of any kind, the employees have the right to know about them.  OSHA requires that this information be made available in the form of a Material Safety Data Sheet (MSDS). The MSDS outlines the proper procedure for working with a specific substance, for handling and containing a “spill,” first aid for an exposure and other hazards such as fire. Employees must have access to the manufacturer’s supplied MSDS for each hazardous chemical.
    • Material Safety Data Sheets are available from the product manufacturer, are often included with shipping documents and can be found on the manufacturer’s website. Store these in a notebook in a centralized location so that they are readily available to all employees.
    • Exclusion for Consumer Products. “Ordinary consumer products,” such as window cleaners, household cleaners and the like are exempt from OSHA’s Hazard Communication Standard if their use in the workplace is similar to how a typical consumer would use the product.
    • Maintain a current written list of the hazardous chemicals stored or used in the organization. Cabinets or areas where the chemicals are stored should have a hazard warning label affixed to the door.  
    • Emergency Eyewash Stations may be required. Please use the OSHA Hazard Communication Standard Eyewash Algorithm at the end of this document to guide decision making.
  3. Tuberculosis:
    • Staff knowledge of how TB is transmitted.
    • Knowledge of actions to take if a patient presents to the facility with active TB.
    • Requirements of initial TB testing.
  4. Exit Routes:
    • Provide Safe and Accessible Building Exits. Display diagrams of exit routes to facilitate evacuation in case of fire or other emergencies.
  5. OSHA Poster:
    • Poster. Every organization must display this notice of employee rights in an obvious, central area. It outlines the staff’s rights to a safe workplace and provides instructions on how to file a complaint.
  6. Ionizing Radiation:
    • For Organizations that Offer X-ray and Related Imaging Services:
      • Designate restricted areas to limit employee exposure.
      • Supply personal radiation monitors (film badges or pocket dosimeters) to employees working in restricted areas.
      • Label appropriate rooms and equipment with caution signs.
  7. Samples of other occupational health issues to be reviewed and considered:
    • Eyewash [PDF]
    • Latex sensitivity
    • Ergonomics
    • Noise level
    • Indoor air quality including mold
    • General safety issues:  Stairs, walkways, uneven surfaces, trip hazards
    • Security

Employee and patient/resident safety in the practice/long term care facility setting is a shared goal for all health care employers. These standards/rules are not hard to comply with and they create a safer working environment for the patients/residents and employees. Monitor your environment regularly and address staff concerns personally and globally at staff meetings. This OSHA law requires your employees be involved in maintaining and investigating safety measures that apply to all areas discussed in this practice tip. Record your safety activities in staff meeting minutes.

To request information on training and education materials, you may contact your State OSHA or Federal OSHA office at the numbers listed below.

State of Maine
Augusta office: 207-626-9160
Bangor office: 207-941-8177

New Hampshire
Federal office: 603-225-1629

Vermont
OSHA office: 802-828-2288


Medical Mutual's "Practice Tips" are offered as reference information only and are not intended to establish practice standards or serve as legal advice. MMIC recommends you obtain a legal opinion from a qualified attorney for any specific application to your practice.