The Compliance INSIDER

Last year OSHA proposed fines of $290,100 to Altamont Ambulance Service, Inc. after investigators found specific guidelines to protect emergency healthcare workers from exposure to bloodborne pathogens and other hazards while providing patient...

Your OSHA and General OSHA courses received a new slide this month.  This update only applies to certain medical facilities. If your organizational type is not included in the following list, we would encourage you to HIDE the slide...

The Occupational Safety and Health Administration (OSHA) issued a final rule that is effective in 2017 that revised requirements for submitting records of workplace injuries and illnesses. Specifically, OSHA is requiring certain employers to...

Occasionally we are asked questions about OSHA’s Regulated Waste Management standard.  These questions include: Is it permissible to dispose of filled sharps containers that are sealed in the regular trash? We have sharps...

Recently, the Occupational Safety and Health Administration (OSHA) issued one serious and one other than serious violations to a residential health care facility for exposing employees to hazards related to workplace violence. As a result, OSHA...

The Centers for Medicare & Medicaid Services (CMS) recently announced a final rule to update health care facilities’ fire protection guidelines to improve protections for all Medicare beneficiaries in facilities from fire. According to...

The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) recently issued a final rule to modernize injury data collection to better inform workers, employers, the public and OSHA about workplace hazards....

Hazard Communications: OSHA has announced that they are extending the public comment period on guidance for determining potential health hazards of chemicals To allow stakeholders more time to review and comment, OSHA has extended the public...

Recently, the Kansas City Royals won the World Series becoming the 2015 champions.  They beat the New York Mets four games to one, leaving the Mets organization feeling “stunned.”  For the New York Mets fans the last two games of...

According to McKay-Dee Hospital, a hospital located in northern Utah, as many as 4,800 patients may have been exposed to Hepatitis C by a nurse who was terminated in November 2014.  The nurse was fired from the hospital in November 2014...

Recently, the Occupational Safety and Health Administration (OSHA) published a Guide to Restroom Access for Transgender Workers.  OSHA’s Sanitation standard requires that all employers under its jurisdiction provide employees with...

Did you know? On June 25th 2015 OSHA released new items of focus for Healthcare Inspections.  The new focus items include:  musculoskeletal disorders, bloodborne pathogens, workplace violence, tuberculosis and slips, trips and...

There is a general belief that the staffing agency is ultimately responsible and holds the majority of risk when temporary workers are injured on the job.  In recent publications OSHA has said that companies that hire temporary workers...

Did you know there are 3 key compliance dates related to OSHA’s adoption of the Globally Harmonized System of Classification and Labeling of Chemicals (GHS)? June 1, 2015 â€" Chemical manufacturers and distributors must complete...

The Occupational Safety and Health Administration (OSHA) is part of the U.S. Department of Labor. Because there is some confusion with OSHA’s jurisdiction and specific laws and regulations, we put together this brief list of 5 OSHA Tips...

Last week, the Occupational Safety and Health Administration (OSHA) and the National Institute for Occupational Safety and Health (NIOSH) released the Hospital Respiratory Protection Toolkit, a resource for health care employers to use to protect...

The Occupational Safety and Health Administration (OSHA) recently announced the comment period on a “Request for Information on Chemical Management and Permissible Exposure Limits” is being extended until October 9, 2015. OSHA initially...

We have pushed back the replacement of the OSHA PPE tool until April 3, 2015.  You have a few more days to transfer your PPE information from the OSHA PPE tool over to the new OSHA Hazard Risk Assessment. HCP now offers an OSHA...

As of January 1, 2015 employers covered by federal OSHA law and regulations  are now required to report work-related fatalities within 8 hours and work-related in-patient hospitalizations, amputations and losses of an eye within 24 hours of...

It is no so secret that Ebola has been a hot topic in the news for the past few months. Some stories about Ebola say the risks are real, while others say we shouldn’t fear. The Centers for Disease Control and Prevention (CDC) released new...

Late last week, the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) announced a final rule requiring employers to notify OSHA when an employee is killed on the job or suffers a work-related hospitalization,...

Sometimes there are safety issues that do not have an associated regulation. In these cases, you simply have to use common sense and your professional opinion. This question applies to that principle. Question: Do our red bins for biohazard waste...

Recapping Fill Needles Q: What guidance does OSHA give on recapping fill needles? A: OSHA is pretty blunt about recapping needles. They don’t recommend it! The Bloodborne Pathogens standard section (d)(2)(vii) states: “Contaminated...

Bloodborne Pathogens: Universal Precautions Your practice must always observe and comply with the concept of “Universal Precautions.” Your employees must be instructed to treat all patients, all blood, and other potentially infectious...

Imagine you have a physician who does not want to use safety needles. He feels hypodermic needles work better with his patients. Is he allowed to use hypodermic needles? OSHA’s standards require a tremendous amount of study and...

Remember the importance of adhering to your infection control procedures.  OSHA standards for sterilization in the medical setting have been set forth to protect patients and office personnel from being exposed to blood or other potentially...

The Centers for Medicare and Medicaid Services (CMS) has recently received reports of the use of insulin pens for more than one patient, with at least one 2011 episode resulting in the need for post-exposure patient notification. These reports...

Healthcare providers observed blood on their hands after surgery more frequently when they wore a single pair of gloves than when they wore two pairs of gloves and generally had a favorable opinion on double gloving, according to a recent study....

Do your employees find it difficult to remember the order in which they should put on and take off PPE? The CDC recommends the order for donning items is not the same as for doffing PPE used for protection from bloodborne pathogens or in...

Whistleblowers covered by one of twenty-two statutes administered by the U.S. Department of Labor’s Occupational Safety and Health Administration will now be able to file complaints online. The online form will provide workers...

What are you doing to train your staff on the new GHS standards? The December 1 deadline to train your staff in the new OSHA hazard communication standard has passed, and we hope you hope you have already introduced your workers to the new...

Experts say that when a person goes into cardiac arrest, normal heart function may be restored up to 60 percent of the time if the victim is treated promptly with an automated external defibrillator (AED). AEDs are computerized electronic devices...

Last week OSHA proposed a new rule that affects the way workplaces will report workplace injuries. It won’t change the fact that you have to report injuries that occur on the job, but it could change the way you do it. Basically, if you...

The fall flu season in the U.S. is unfolding largely unobserved. The CDC’s labs and surveillance programs are idle, thanks to the government shutdown, and outside experts are worried that essential data is being lost. Indeed, a CDC...

The recent shutdown of the federal government due to legislative battles in the U.S. Congress has led many to wonder about how various agencies will be affected. As a division of the Department of Labor, the Occupational Safety and Health...

A recent study from researchers at Harvard Medical School and Brigham and Women’s Hospital in Boston found that the five most common healthcare related infections costs the U.S. healthcare system almost $10 billion per year. The study,...

Despite federal mandates put in place 13 years ago to protect healthcare workers from needlesticks, they are still being stuck at an alarming rate. By some estimates, some 600,000 workers in medical clinics suffer needlesticks and other...

A recent report released by the Association for Professionals in Infection Control and Epidemiology (APIC) chronicled a study in which up to 30 percent of scopes used in gastro-intestinal procedures such as colonoscopies and endoscopies in U.S....

If you’ve ever gagged at having to swallow your pride at work, be thankful that medical waste was not also on the menu. A story from “down under” graphically illustrates for healthcare facilities the importance of proper disposal of...

For nurses, working with IV catheters poses a significant risk for blood exposures, yet most incidents go unreported. Healthcare workers place more than 300 million short peripheral intravenous catheters every year in the United States. A study...

When was the last time you reviewed your facility’s policies on the proper precautions for using alcohol-based hand rub (ABHR)? An unusual case in Oregon may pique your interest. A young girl was injured in a Portland (Oregon)...

Occasionally a physician’s office may feel, due to their specialty or other reasons, that they are an exception to using safety needles in their practice.  Here is an answer from OSHA. Q: Our orthopedic practice only gives steroid...

The new HCS changes many things for manufactures and distributors of hazardous chemicals, and fewer things for other employers who merely use hazardous chemicals in the workplace. A “hazardous chemical” is “any chemical which is classified...

The CDC updated the guidelines for how facilities should manage healthcare providers with hepatitis B so as to reduce the risk of transmitting the virus to patients. The goal of  is to promote patient safety while providing risk management...

OSHA revised its Hazard Communication Standard (HCS) to reflect the Globally Harmonized System (GHS) of Classification and Labeling of Chemicals, the international standard for hazard communications. That means companies in the United States have...

OSHA recently issued its FY 2014 Budget Justification.  The document spans over 130 pages and provides a wealth of information regarding the Agency’s priorities. In FY 2014, OSHA proposes to continue its aggressive...

We recently had questions regarding cleaning up a mercury spill from a thermometer. The following instructions from OSHA and the EPA should help you if you have this occur in your practice. Small Mercury Spill Clean-up Kit 4-5 ziplock-type...

Q: We had a discussion at one of our clinic safety meetings about the practice of placing an “X” with chalk on the patient exam rooms in the event of a fire to identify which rooms were checked for patients before exiting the building. Is...

Do your employees find it difficult to remember the order in which they should put on and take off PPE? The CDC recommended order for donning items is not the same as for doffing PPE used for protection from blood-borne pathogens or in isolation...

The new OSHA Globally Harmonized System for Hazard Communication that was recently adopted and mandated by OSHA is now available to you through Healthcare Compliance Pros. The new GHS information has been incorporated into your current OSHA...

Thousands of patients of an Oklahoma dentist are being urged to get tested for HIV and hepatitis after public health officials found evidence of practices that could have exposed patients to the viruses. The Oklahoma and Tulsa health departments...

OSHA’s recently adopted new standard, the Globally Harmonized Standard (GHS), has a training compliance date of December 1, 2013.  Following are some facts you should know about the GHS: Proposal to modify the HCS to align with the...

There have been a lot of questions and discussion regarding safety needles.  OSHA is very explicit about their use. Q: Is the use of safety needles optional in a group medical practice, or must the employer require the use of safety...

Has your facility ever received a bomb threat?  It is certainly a frightening experience.  The following question and answer can help you employ best practices in the event that you do. Q: Another practice in our medical complex...

You’ve had some complaints and a near miss, so you know you need to replace what you’re using but aren’t sure how to go about picking new safety sharps. First, you’ll need to get some products in-house...

Needlesticks have been ranked as eighth on the list of Top 10 Health Technology Hazards for 2012. The number of reports is staggering even with the emphasis on training and prevention during the past 20 years. Following are steps that employees...

It may not be well known, but OSHA oversees whistleblower protection investigations not only for its own jurisdiction, but for 12 other regulatory areas. Employees reporting violations of federal law (e.g., an OSHA complaint) are protected from...

This is a helpful checklist to help you and your employees wear and use your medical gloves properly: When to wear gloves: * When touching patient mucous membranes or non-intact skin. * While performing phlebotomy and other vascular access...

You may have portable fire extinguishers at your facility. This is how to mount and mark them. 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...

This is a reminder that cleanup procedures for chemical spills depend on the size of the spill and the risks. Make sure employees understand cleanup rules. Even small spills of highly toxic or flammable substances can be hazardous. Large spills...

The Hazard Communication Standard (HCS) (29 CFR 1910.1200(g)), revised this year, requires that the chemical manufacturer, distributor, or importer provide Safety Data Sheets (SDSs) (formerly MSDSs or Material Safety Data Sheets) for each...

The answer to this question offers some interesting information on blood exposure to eyes. Q: Are emergency eyewash stations required for blood exposures to the eyes? A: There is a fine technical debate among healthcare safety officers as to...

Although your OSHA training is required annually, here is a question that many practices may have: Q: Does our annual OSHA training have to happen exactly one year to the day later? We are low-staffed right now and scheduling is a concern, and...

Q: When OSHA insists on the use of safety needles and scalpels, isn’t it overstepping its authority by telling doctors how to practice medicine? A: That’s not how the agency sees things. With regard to the use of safety devices,...

This is a question that is asked frequently. Here is the answer that will help you in your MSDS training. Q: We use an electronic MSDS access system. Are there any special training requirements we need to know about? A: The most important...

Your practice must always observe and comply with the concept of “Universal Precautions.” Your employees must be instructed to treat all patients, all blood, and other potentially infectious materials (OPIM) as if infected with HIV, hepatitis...

Move over hepatitis B, C, and HIV, and make room for MRSA infections as a consequence of unsafe injection practices. A recent post on the CDC Safe Healthcare blog by Dr. Michael Bell, associate director for infection control at the Division of...

Here are some practical tips to prevent mold in your workplace: 1. Get the Wet Out Unfortunately, there’s no feasible way to eliminate all mold and mold spores in the indoor environment. But controlling excess moisture is the key to...

This question is asked quite often. Let’s try to put the problem to rest! Q: What guidance does OSHA give on recapping fill needles? A: OSHA is pretty blunt about recapping needles. They don’t recommend it! The Bloodborne...

Sometimes there are safety issues that do not have an associated regulation. In these cases, you simply have to use common sense and your professional opinion. This question applies to that principle. Q: Do our red bins for biohazard waste need...

Q: Is it OK to store food and medications, such as vaccines, in the same fridge? A: It is not acceptable to store medications, including vaccines, in the same refrigerator. In fact, there should be a separate refrigerator for meds and for food,...

An investigation by the Colorado Department of Public Health and Environment indicates that as many as 8,000 dental patients may have been exposed to bloodborne pathogens from unsafe injection practices. Unsafe re-use of syringes and needles...

Kaiser’s South Bay Medical Center will pay $73,615.40 in fines for unlawful disposal of medical waste. “On April 28, 2010, Kaiser’s South Bay Medical Center delivered a roll-off trash bin containing medical waste, including...

Concerns voiced by staff at an oncology clinic can help protect your workers, who may also handle hazardous drugs. NIOSH posted a new Health Hazard Report prompted by a request from a Florida oncology clinic where staff members complained about...

Q: If an employee agrees to the hepatitis B the vaccination but fails to follow through on the titer one to two months after the series, what should I do for OSHA compliance? A: There is no regulation that says you can force an employee to...

Are your employees bleary-eyed after hours on the computer? Help them avoid eyestrain with these simple tips: * Look away from the monitor for 30 seconds, every 15 or 20 minutes. Look at or scan things at least 20 feet away to allow the eyes to...

The National Safety Council (NSC) reminds us that week 2 of June National Safety Week is Ergonomics Week. Here is a list of the Council’s daily ergonomics tips to share with your co-workers: * Monday: Keep your joints and muscles relaxed...

Occasionally a physician’s office may feel, due to their specialty or other reasons, that they are an exception to using safety needles in their practice. Here is an answer from OSHA: Q: Our orthopedic practice only gives steroid...

OSHA announced its intent to establish a Whistleblower Protection Advisory Committee that will advise and make recommendations to the assistant secretary of labor for occupational safety and health on ways to improve the efficiency, effectiveness...

After a decade long effort, OSHA has announced that the Hazard Communications Standard has been revised to align with the Globally Harmonized System of Classification and Labeling of Chemicals, commonly known as GHS. The adoption of GHS ushers in...

Q: My practice rents space to another practice with employees. They use none of our supplies and operate as a separate business. Is my practice responsible for OSHA training for their employees? A: If there is no employer-employee relationship,...

Q. How long does OSHA require us to keep a cleaning log for a bio-safety cabinet? A. OSHA does not require a log for environmental housekeeping, only that the cleaning schedule be posted. For logs involving infection prevention functions, the...

During recent OSHA inspections, violations involving fire extinguishers have become more common. OSHA routinely evaluates the presence, placement, use, maintenance and testing of fire extinguishers. These evaluations are in conjunction with your...

The following is an important reminder for your employees: Q: We are aware that specimens cannot be stored with food, but is it okay to store blood, urine, and other specimens in the same refrigerator and/or freezer with medications? A: No. You...

Q: Is the wearing of lab coats really necessary in the healthcare setting? Where is the OSHA regulation requiring lab coats to be worn in the healthcare laboratory? A: As with most OSHA regulations, enforcement of standards is subject to the...

Q: What does OSHA say about prohibiting candles in a doctors’ office? We have nurses who like to have them burning, but the smell from them is awful. So how can I get them out of the office? A: Medical practices are classified as business...

There is no rule of thumb about who cleans up a spill, and some facilities may have very explicit regulations about chemical spill cleanup. If your practice has no guidelines, here are some suggestions you can use to decide whether your staff...

Q: Do sharps disposal containers have to be in each individual exam room or can we have them in the nurses’station, for a private practice? A: Being in a private practice has no bearing on Bloodborne Pathogen standard compliance. You are...

Which is more effective: alcohol-based gels and hand rubs, or disinfectant alcohol-based wipes? Researchers at Special Pathogens Laboratory in Pittsburgh, PA, wanted to figure out just that. Their study found that alcohol-based wipes are more...

OSHA issues different types of citations, depending on the nature and severity of the violation. Penalties are proposed based on the type of violation. If you’re cited for OSHA violations following an inspection, penalties may vary...

Q: May we use the non-safety needles that come with pre-filled vaccine syringes provided by the pharmaceutical company without violating OSHA standards? A: No. Manufacturer-supplied pre-filled syringes without safety needles do not exempt...

If you have a lab at your office, you must provide protective clothing, and face and eye protection. You must equip your employees with protective items appropriate for the risks inherent in all tasks they perform. Store clean laboratory coats...

OSHA might be looking closely at more dental practices as a result of the announcement to study bloodborne pathogens compliance in dental practices. The Organization for Safety, Asepsis and Prevention (OSAP) will conduct the study. The purpose of...

Q: What is the recommendation for dealing with medical records contaminated with dried blood? A: First, determine whether there is a work practice shortcoming that is causing medical records to become contaminated with blood and then address it...

An OSHA whistleblower investigation has a dentist squirming in the regulatory exam chair, so to speak. It is also a reminder that workplace safety violations aren’t the only way that dental and medical practices can run afoul of OSHA....

Non-fatal occupational injuries among healthcare workers are too high, says OSHA; and nursing homes are the first places the agency is going to scrutinize. According to data released by the Bureau of Labor Statistics, the incidence rate for...

ASCs With more than half of the surgeries in the U.S. performed in ambulatory care settings, ambulatory surgery centers (ASC) and physician offices are under higher scrutiny from OSHA to protect healthcare workers from bloodborne pathogens...

There have been some recent inquiries about what healthcare occupations the OSHA Bloodborne Pathogens standard covers. As a reminder the Bloodborne Pathogen Standard does not list occupations that are automatically covered. Instead, the standard...

The goal of social distancing is to avoid contact with others as much as possible when contagion is a risk to avoid the spread of infection. Here are some suggestions for the workplace. “Social distancing” is defined as a technique used to...

With Halloween fast approaching, it’s time to remind staff about safety compliance with regard to the variety of holiday decorations that will be present through the end of the year. Well-timed handouts to staff can serve as reminders of...

Q: We had a discussion at one of our clinics about the practice of placing an “X” with chalk on the patient exam rooms to identify which rooms were checked for patients before exiting the building in the event of a fire. Is this a recommended...

The CDC recently released guidelines for preventing and controlling norovirus in healthcare settings. Norovirus has been increasing in both healthcare and non-healthcare settings for the past few years, but it is most common in healthcare...

Q: I am a dentist and currently use a lab coat laundry service. The cost, however, is quite high. I would like to consider doing it myself at home. Assuming that I am washing them separately, using hot water, bleach, etc., is there an OSHA...

Talking about violence in the workplace can be an uncomfortable process. But it is also unavoidable if you want to do all you can to eliminate the threat of violence from your practice. Why not approach employee reluctance to talk about violence...

Do your employees find it difficult to remember the order in which they should put on and take off PPE? The recommended order for donning items is not the same as for doffing PPE used for protection from bloodborne pathogens or in isolation...

Q: In home healthcare who is responsible for purchasing gloves-employer, employee, or patient? If the employer, can the employer put a limit on amount of gloves per month? A: If you are the employee of a home healthcare agency, as opposed to an...

Needlesticks have been ranked as eighth on the list of Top 10 Health Technology Hazards for 2011. The number of reports is staggering even with the emphasis on training and prevention during the past 20 years. Following are steps that employees...

Q: What disinfectant does OSHA recommend for protection from bloodborne pathogens? A: OSHA does not make specific product or brand recommendations, but directs healthcare providers to consult the EPA registered list of sterilants (List A),...

OSHA recently released its semiannual regulatory agenda items and some of them could directly affect compliance in healthcare facilities. Most of the healthcare-related items are still in the pre-rule stage meaning that approval, promulgation,...

Experts say that when a person goes into cardiac arrest, normal heart function may be restored up to 60 percent of the time if the victim is treated promptly with an automated external defibrillator (AED). AEDs are computerized electronic devices...

An OSHA whistleblower investigation has a dentist squirming in the regulatory exam chair, so to speak. It is also a reminder that workplace safety violations aren’t the only way that dental and medical practices can run afoul of OSHA....

Latex is a rubber product found in many manufactured goods, including: * Personal protective equipment (PPE), such as gloves, goggles, and aprons; * Medical equipment, such as catheters and intravenous tubes; * Baby products, such as bottle...

Wearing artificial nails in the lab is a bad idea. To allow gloves to fit properly and for good infection control, fingernails should be no longer than 0.25 inch beyond the end of the finger, according to the Centers for Disease Control and...

The following is a template for a Tornado Emergency Plan to implement in your office. Before a tornado: Review your escape plan (in your OSHA setup materials) to learn the route. Locate and/or designate the location of the closest tornado...

Q: How often must we replace MSDSs in our MSDS file? A: OSHA requires that employers have a current MSDS for hazardous substances in the workplace. An updated MSDS included with the product can get misplaced, so routinely request a new MSDS...

We frequently get questions about transporting blood and urine samples. The following will help you understand what is required. Q. Do the samples need to be in a biohazard bag when transported either by hand, on a cart, or via a tube system that...

Q: I am a phlebotomy instructor who always emphasizes adherence to wearing gloves when drawing blood. One of my students told me that he regularly donates blood and platelets at a blood bank that has a sign on the wall that states, “Gloves are...

Q: If a healthcare worker did not have titer drawn after the HBV vaccine was completed, how long afterward could we assume that he/she is a responder/non-responder? Many titers wane after years and are no longer detectable. How do we know the...

Q: Does OSHA require a monthly check of portable fire extinguishers? A: Yes. The OSHA standard for portable fire extinguishers 19 10.157 requires a monthly check. Each month check for: * proper location; * accessibility and visibility; * intact...

We recently had a few questions regarding how to handle a mercury spill. We hope that the following instructions will help you if you have that kind of spill in your practice. (1) Put on rubber, nitrile or latex gloves; (2) If there are any...

Offices or facilities that contain compressed gases require a high standard of care, along with a high standard of training to ensure employee compliance with safety rules. Basic Rules Although specific precautions for using compressed gases...

Cleanup procedures for chemical spills depend on the size of the spill and the risks. Make sure employees understand your cleanup rules. Even small spills of highly toxic or flammable substances can be hazardous. Large spills can cause serious...

Q: In our medical practice, when sharps containers are full they are taken to a storeroom to be picked up and removed on a weekly basis. Is there a regulation that states whether this room must be locked? A: There is no federal OSHA regulation...

Q: Does OSHA mandate that disposable gloves are required for blood draws? If so, where is the reference? A: Gloves are required for employees doing blood draws. The applicable section of the Bloodborne Pathogens standard is: 1910.1030(d)(3)(ix)...

Regarding OSHA inspections, we recently received the following question from a client; the answer may surprise you. Q: I’m taking over OSHA compliance for our medical practice and the previous safety officer is telling everyone that OSHA...

Do you know whether it is against OSHA regulations to have a sprayer on a soiled utility sink used for patient care equipment? Under OSHA, there is no specific prohibition against having a sprayer on a soiled utility sink. Section (d)(2)(xi) of...

Many have asked lately, the following question: What is your recommendation for dealing with medical records contaminated with dried blood? Under OSHA, you first want to determine whether there is a work practice shortcoming that is causing...

Some medical offices are of the opinion that the practice of using safety needles is a bother. What does OSHA say? The use of safety needles is not optional, and the employer is responsible to ensure their use or provide detailed documentation on...

Recently, many offices have inquired about the duration Material Safety Data Sheets (“MSDS”) need to be kept for products which are no longer used. Just as a reminder, you don’t need to keep MSDS files for products no longer in use....