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About the AuthorSheila Dunn, DA, MT (ASCP), holds a doctoral degree in clinical laboratory science from the Catholic

University of America in Washington, DC. She has helped thousands of outpatient medical facilities comply

with federal regulations such as CLIA and OSHA through her presentations at a nationwide seminar series.

She has written more than 150 articles about regulatory issues and healthcare delivery systems and serves

as an advisor to numerous companies.

13K

©2005–2013 HCPro, Inc. All rights reserved, including right of reproduction. The author(s) and their agent(s) have made every reasonable effort in the preparation of this publication to ensure the accuracy of the information. However, the information in this book is sold without warranty, either expressed or implied. The authors, the editors, their agents, and the publishers will not be liable for any damages caused or alleged to be caused directly, indirectly, incidentally, or consequentially by the information in this publication. This publication cannot and does not provide specific information for a user’s exact situation. Users of this publication should exercise their own judgment and, where appropriate, seek the assistance of legal counsel regarding their particular situation.

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Danvers, MA 01923Tel: 800/650-6787Fax: 800/639-8511

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OSHAPROGRAMMANUALfor Medical Facilities

OSHA Program Manual for Medical Facilities is published by HCPro, Inc.

Copyright © 2013 HCPro, Inc.

All rights reserved. Printed in the United States of America. 5 4 3 2 1

ISBN: 978-1-60146-743-0

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HCPro, Inc., provides information resources for the healthcare industry.

HCPro, Inc., is not affiliated in any way with The Joint Commission, which owns the JCAHO and Joint Commission trademarks.

Sheila Dunn, DA, MT (ASCP), AuthorJay Kumar, Senior Managing EditorMarge McFarlane, PhD, CHSP, CHFM, HEM, MEP, CHEP, ReviewerMike Mirabello, Senior Graphic ArtistMatt Sharpe, Senior Manager of ProductionElizabeth Petersen, Vice President

Advice given is general. Readers should consult professional counsel for specific legal, ethical, or clinical questions.

Arrangements can be made for quantity discounts. For more information, contact:

HCPro, Inc.75 Sylvan Street, Suite A-101Danvers, MA 01923Telephone: 800-650-6787 or 781-639-1872Fax: 800-639-8511E-mail: [email protected]

Visit HCPro online at: www.hcpro.com and www.hcmarketplace.com

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OSHA PROGRAM MANUAL

Contents

Front Pocket OSHA Poster 3165: IT’S THE LAW! Laminated Eyewash Station Sign 4 Sample Biohazard Self-Adhesive Labels CD-ROM (MS Word for Windows 2000) with Master Record Forms (Tab 11) from this Manual

for Customization.

ix

IntroductionImportant Information About the Use of This Program ............................. i

How to Customize This Program ................................................................ ii

What Is Included in This Program ............................................................... vi

TAB 1: What Is OSHA?A Quick Look at OSHA .................................................................................. 1-1

States with OSHA-Approved Plans ......................................................................................1-1OSHA Consultative Services Division ..................................................................................1-2OSHA’s Jurisdiction ..............................................................................................................1-2OSHA’s General Duty Clause ..............................................................................................1-2

Employee or Employer? ............................................................................... 1-3Employers’ Responsibility Under OSHA ...............................................................................1-4

Overview of OSHA Standards ...................................................................... 1-5

OSHA Inspections ......................................................................................... 1-5Employee Complaints ..........................................................................................................1-6If an On-site OSHA Inspection Occurs .................................................................................1-6During the Inspection ...........................................................................................................1-7What OSHA Inspectors May Ask Employees .......................................................................1-8The Typical OSHA Inspection ...............................................................................................1-8The Closing Conference .......................................................................................................1-9

OSHA Sanctions ............................................................................................ 1-10

Whistleblower Protection ............................................................................. 1-12

Students and Volunteers .............................................................................. 1-14

Page

Contents

x

TAB 2: OSHA Program AdministrationInjury and Illness Prevention Plan Flowchart ............................................. Reverse Side of TOC

Injury and Illness Prevention Plan ............................................................... 2-1Management Leadership and Employee Involvement .........................................................2-1Key Contacts for the OSHA Program Manual ......................................................................2-1Location of the OSHA Manual Program ...............................................................................2-2

Duties of the OSHA Safety Officer ............................................................... 2-2Accident/Incident Investigation & Reporting Procedure ........................... 2-4

Definition of an Accident and/or Incident ..............................................................................2-4When to Investigate an Accident and/or Incident .................................................................2-4How to Document an Accident and/or Incident ....................................................................2-4Recording Accidents or Injuries for OSHA............................................................................2-4Correcting Unsafe or At-Risk Conditions ..............................................................................2-5

Recordkeeping Requirements ..................................................................... 2-5Workplace Hazard Analysis ......................................................................... 2-7Practical Ideas for Involving Employees .................................................... 2-8Organizing OSHA Compliance Duties ......................................................... 2-9

Weekly Facility Review Checklist .........................................................................................2-10Monthly Facility Review Checklist ........................................................................................2-11Annual Facility Review Checklist ..........................................................................................2-12Annual OSHA Safety Program Review ................................................................................2-15

TAB 3: General Facility SafetyKeeping Employees Safe ............................................................................. 3-1

Important Phone Numbers & Contacts.................................................................................3-1Emergency Phone List .........................................................................................................3-2

Fire Safety ...................................................................................................... 3-3Automatic Sprinkler Systems ...............................................................................................3-3Fire Alarms ...........................................................................................................................3-3Fire Procedures: Immediate Actions ....................................................................................3-3Building Evacuation ..............................................................................................................3-4Fire Extinguishers .................................................................................................................3-4

Purchase the Right Extinguisher ..................................................................................3-5How Many Fire Extinguishers to Have & Where to Put Them .....................................3-6To Use a Fire Extinguisher: Think “PASS” ...................................................................3-7When to Extinguish Fires with a Portable Fire Extinguisher ........................................3-7When NOT to Extinguish Fires and to Evacuate ..........................................................3-7Fire Extinguisher Inspections .......................................................................................3-7Fire Extinguisher Maintenance .....................................................................................3-8

Fire Risks During Surgery ....................................................................................................3-8

Fire Extinguisher Supplement ..................................................................... SupplementFire Drills ..............................................................................................................................3-9

Contents

xi

Electrical Safety ............................................................................................ 3-9Physical Characteristics of a Safe Medical Facility ................................... 3-10

Automated External Defibrillators .........................................................................................3-10Air Quality .............................................................................................................................3-10

Mold .............................................................................................................................3-11Mold Remediation ................................................................................................3-12

Aisles ....................................................................................................................................3-13Emergency Lighting ..............................................................................................................3-14Employee Dress Code .........................................................................................................3-14Exits, Means of Egress .........................................................................................................3-14Exit Doors .............................................................................................................................3-15Exit Signs .............................................................................................................................3-15Floors ...................................................................................................................................3-16Lighting .................................................................................................................................3-16Noise ....................................................................................................................................3-16Portable Space Heaters .......................................................................................................3-17Restricted Access Areas .......................................................................................................3-17Sinks .....................................................................................................................................3-17Storage .................................................................................................................................3-17

Systems Failure ............................................................................................. 3-18Evacuation Plan ............................................................................................ 3-18

Evacuation Procedures ........................................................................................................3-19Methods for Carrying Patients During an Evacuation ..................................................3-20

Evacuation Floor Plan ..........................................................................................................3-21Example Evacuation Floor Plan ...........................................................................................3-22

Emergency Preparedness Supplies ............................................................ 3-23Emergency Action Procedures .................................................................... 3-23

Bioterrorism: Suspicious Letters or Packages ......................................................................3-24What Is a “Suspicious Package”? ................................................................................3-24

Bomb Threat .........................................................................................................................3-25If You Discover a Bomb or a Suspicious Item ..............................................................3-26Explosion ......................................................................................................................3-26

Civil Disturbance ..................................................................................................................3-26Earthquake ...........................................................................................................................3-27

If a Tremor Occurs when You Are Inside ......................................................................3-27After the Tremor Is Over ...............................................................................................3-27

Severe Weather ...................................................................................................................3-28Flood ............................................................................................................................3-28Hurricane ......................................................................................................................3-28Severe Thunderstorm or Tornado Warning ..................................................................3-28Tornado Safety Tips .....................................................................................................3-29Severe Thunderstorm or Tornado Watch .....................................................................3-29Toxic External Atmosphere ...........................................................................................3-29

Violence ................................................................................................................................3-30Violence Prevention Plan Introduction .................................................................................3-30Overview of Violence Prevention Plan Components ............................................................3-31

Violence Prevention Plan; Part 1 .................................................................................3-31

Contents

xii

Violence Prevention Plan; Part 2 .................................................................................3-38More Sources for Prevention of Workplace Violence ...........................................................3-39

First Aid .......................................................................................................... 3-40Crash Kit/Cart Components ......................................................................... 3-43Drug-Free Workplace Program .................................................................... 3-43Service Animals ............................................................................................. 3-48Holiday Decorations ..................................................................................... 3-50

Sample Checklist: Spot Check Your Facility’s Holiday Decorations .....................................3-50

Safe Decorations and Displays Policy ........................................................ 3-52Slip, Trip, and Fall Prevention ...................................................................... 3-54

Contaminants on the Floor ...................................................................................................3-54Poor Drainage: Pipes and Drains .........................................................................................3-54Indoor Walking Surface Irregularities ...................................................................................3-54Outdoor Walking Surface Irregularities ................................................................................3-55Weather Conditions: Ice and Snow ......................................................................................3-55Inadequate Lighting ..............................................................................................................3-55Stairs and Handrails .............................................................................................................3-55Stepstools and Ladders........................................................................................................3-56Tripping Hazards: Clutter, Including Loose Cords, Hoses, Wires, Medical Tubing ..............3-56Improper Use of Floor Mats and Runners ............................................................................3-56Healthcare Facility Slip, Trip, and Fall Hazard Checklist ......................................................3-57

TAB 4: Ergonomics in the Medical WorkplaceA Quick Look at Ergonomics ....................................................................... 4-1Common Musculoskeletal Disorders .......................................................... 4-2

Back Injuries .........................................................................................................................4-3Techniques to Reduce Injury ........................................................................................4-4

Fatigue .................................................................................................................................4-5Repetitive Stress Injuries/Wrist Injuries ................................................................................4-6

Wrist and Hand Exercises ............................................................................................4-6Eye Strain .............................................................................................................................4-8

Why Prevent CVS? ......................................................................................................4-8Symptoms of CVS ........................................................................................................4-8Other Suggestions for Relieving Eye Strain .................................................................4-9

Selecting Equipment ..................................................................................... 4-10

TAB 5: Bloodborne Pathogens Exposure Control PlanExposure Control Plan Introduction ........................................................... 5-1Overview of Bloodborne Pathogens Standard Components .................... 5-2A Quick Look at Occupational Exposure .................................................... 5-3Industries Subject to the Bloodborne Pathogens Standard ..................... 5-3

Contents

xix

Interactive Safety Training Exercises ...................................................................................10-2General Safety .............................................................................................................10-3Fire Safety ....................................................................................................................10-3Bloodborne Pathogens Safety .....................................................................................10-3Chemical Safety ...........................................................................................................10-3TB Safety .....................................................................................................................10-4

Annual Employee Retraining ....................................................................... 10-5Bloodborne Pathogens Annual Training Contents................................................................10-6Respiratory Protection Annual Training Contents.................................................................10-6Hazard Communication Annual Training Contents...............................................................10-7

New Employee Orientation ........................................................................... 10-7New Employee OSHA Orientation Checklist (Form 26) .......................................................10-8

Sample Tests with Answer Keys .................................................................. 10-10OSHA Annual Retraining: Sample Essay Test Questions (Form 28) ...................................10-11OSHA Annual Retraining: Sample Essay Test—Answer Key ...............................................10-12OSHA Annual Retraining: Sample Multiple Choice Test Questions (Form 29) .....................10-13OSHA Annual Retraining: Sample Multiple Choice Test—Answer Key ................................10-15OSHA Annual Retraining: Sample True/False Test Questions (Form 30) ............................10-16OSHA Annual Retraining: Sample True/False Test—Answer Key .......................................10-17

Documenting Employee Training ................................................................ 10-17Annual Safety Training Record (Form 27) ................................................... 10-18

TAB 11: Master Record FormsGeneral Equipment and Facility Records

Safety Report .......................................................................................................................Form 1Autoclave Log .......................................................................................................................Form 2Eyewash Station Weekly Check Log....................................................................................Form 2-AAnnual OSHA Program (Exposure Control Plan) Review ....................................................Form 3Weekly Facility Review Checklist .........................................................................................Form 4-AMonthly Facility Review Checklist ........................................................................................Form 4-BAnnual Facility Review Checklist ..........................................................................................Form 5Fire Drill Evaluation Form .....................................................................................................Form 5-AEmployee Fire Drill Participation Sign-up Sheet ..................................................................Form 5-BRisk Assessment for Workplace Violence ............................................................................Form 6Housekeeping Schedule ......................................................................................................Form 7Emergency Telephone List ...................................................................................................Form 7-AHealthcare Facility Slip, Trip, and Fall Hazard Checklist ......................................................Form 7-B

Bloodborne Pathogens RecordsBloodborne Pathogens Exposure Determination List #1......................................................Form 8Bloodborne Pathogens Exposure Determination List #2......................................................Form 9Bloodborne Pathogens PPE Compliance Checklist .............................................................Form 9-AFailure to Use PPE ...............................................................................................................Form 9-A-1Bloodborne Pathogens Compliance Checklist: ECP, Training, and Records .......................Form 9-BSafety Needle/Syringe Evaluation ........................................................................................Form 10Phlebotomy Device Evaluation.............................................................................................Form 11Generic Safety Device Evaluation ........................................................................................Form 12

Contents

xx

Sharps Disposal Container Locations ..................................................................................Form 12-ASharps Evaluation Results ...................................................................................................Form 13Exposure Prevention Checklist ............................................................................................Form 13-A

Bloodborne Pathogens Employee Medical RecordsAccident Report/Sharps Injury ..............................................................................................Form 14Sharps Injury Log .................................................................................................................Form 14-AHBV Vaccination Declination Form ......................................................................................Form 15HBV Employee Vaccination Form ........................................................................................Form 16Post-exposure Checklist .......................................................................................................Form 17Post-exposure Medical Evaluation Declination Form ...........................................................Form 18Source Patient Testing Consent Form ..................................................................................Form 18-A

Hazard Communication Records Hazardous Substances List ..................................................................................................Form 19

TB/Infection Control Records TB Risk Assessment Results Form ......................................................................................Form 20TST Record ..........................................................................................................................Form 21TST Declination Form ..........................................................................................................Form 22TB Exposure Log ..................................................................................................................Form 23Influenza Vaccine Log ..........................................................................................................Form 24Influenza Vaccine Declination Form (Seasonal and H1N1) .................................................Form 25-AChecklist for Infection Prevention for Outpatient Settings ....................................................Form 25-B List of Infection Prevention Contact Persons and Roles/Responsibilities ................................Form 25-C

Training RecordsNew Employee OSHA Orientation Checklist ........................................................................Form 26Annual Employee Training Record .......................................................................................Form 27OSHA Annual Retraining (Sample Essay Test) ....................................................................Form 28 OSHA Annual Retraining (Sample Multiple Choice Test) .....................................................Form 29OSHA Annual Retraining (Sample True/False Test) .............................................................Form 30Respiratory Protection Training Record ...............................................................................Form 31Qualitative Respirator Fit Test Report ..................................................................................Form 31-AChecklist for Decreasing Surgical Fire Risks .......................................................................Form 32

TAB 12: OSHA Regulations & Key ContactsOSHA Regulations

Bloodborne Pathogens Standard .........................................................................................12-1Amended Bloodborne Pathogens Standard (Sharps Safety) ...............................................12-13Hazard Communication Standard ........................................................................................12-14Exit Routes, Emergency Action Plans, and Fire Prevention Plans.......................................12-29Ionizing Radiation .................................................................................................................12-33Table of Other OSHA Standards for Outpatient Medical Facilities .......................................12-41

Additional OSHA ResourcesHealthcare Worker Vaccination Recommendations (Revised 2011) ....................................12-42Suggested Work Restrictions for Employees .......................................................................12-44

Key ContactsState OSHA Consultative Services Directory .......................................................................12-48Directory of States with Approved OSHA Plans ...................................................................12-51

Acronyms used in the OSHA Program Manual .......................................... 12-53

TAB 2: OSHA PROGRAM ADMINISTRATION

Contents

Injury & Illness Prevention Plan Flowchart ..................................... Reverse Side of TOC

Injury & Illness Prevention Plan ...................................................................... 2-1Management Leadership and Employee Involvement............................................................2-1Key Contacts for the OSHA Safety Program ..........................................................................2-1Location of the OSHA Manual Program ..................................................................................2-2

Duties of the OSHA Safety Officer .................................................................. 2-2Accident/Incident Investigation & Reporting Procedure .............................. 2-4

Definition of an Accident and/or Incident ................................................................................2-4When to Investigate an Accident and/or Incident....................................................................2-4How to Document an Accident and/or Incident .......................................................................2-4Recording Accidents or Injuries for OSHA ..............................................................................2-4Correcting Unsafe or At-Risk Conditions ................................................................................2-5

Recordkeeping Requirements ........................................................................ 2-5Workplace Hazard Analysis ............................................................................. 2-7Practical Ideas for Involving Employees ........................................................ 2-8Organizing OSHA Compliance Duties ............................................................ 2-9

Weekly Facility Review Checklist ...........................................................................................2-10Monthly Facility Review Checklist ...........................................................................................2-11Annual Facility Review Checklist ............................................................................................2-12Annual OSHA Safety Program Review ...................................................................................2-15

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OSHA Program Manual for Medical Facilities

for doing this–the best part is that they don’t cost a penny. Try some or all of them to reduce your real or perceived liability:

During staff meetings, encourage employees to bring up any concerns about their safety on the job. Listen to their responses and encourage discussion.

When an employee states a concern, show interest and ask for more details. Regardless of whether that concern is high on your priority list or not, address it and resolve either to fix the problem or allay the employee’s fears.

Bring this OSHA Program Manual for to staff meetings to reinforce the fact that your practice has a tangible program that contains policies to ensure staff safety.

Take five minutes at these same meetings to do a safety-related demonstration, such as showing how to remove exam gloves without splashing your colleagues, how to clean up a biohazardous spill, how to locate and read an MSDS (SDS), etc. These short exercises reinforce the commitment to safety. One approach is to have different employees demonstrate a safety topic to their peers each month.

Practice evacuation drills for fire, violent behavior, and other emergencies that could potentially occur. After the drill, critique the staff’s performance and amend the emergency plan, if necessary.

Finally, the ultimate goal of an OSHA Safety Officer should be zero non-compliance and minimal exposure incidents. Make sure that employees know exactly what safety measures to take. Employees should know that using appropriate work practices and wearing appropriate protective gear is not optional. Employees should expect consistent enforcement of safety policies and know what happens if there is non-compliance. Disciplinary actions should be fair and consistent: Follow an unheeded verbal warning with a written warning. If no corrective action follows, take further disciplinary action and/or termination.

Organizing OSHA Compliance DutiesTo help organize a busy OSHA Safety Officer’s efforts to get a facility in compliance and keep it there, HCPro, Inc., offers four useful tools:

1. A Weekly Facility Review Checklist (highly recommended).

2. A Monthly Facility Review Checklist (highly recommended).

3. An Annual Facility Review Checklist (highly recommended to assist in the annual assessment of the facility safety program).

4. An Annual OSHA Program Manual Review Form (mandatory and includes the Exposure Control Plan, the Hazard Communications Plan and the Respiratory Protection Plan).

These forms are located on the following pages, as well as behind Tab 11: Master Record Forms. These forms document and organize compliance duties.

If it is determined that revisions need to be made, the OSHA Safety Officer ensures im-plementation of the recommendations and makes changes to the OSHA Program Manual. For this purpose, use the Annual OSHA Program Manual Review Form located on the following pages and behind Tab 11: Master Record Forms (Form 3).

2-10


WEEKLY FACILITY REVIEW CHECKLIST

Mark Yes (Y), No (N), or Not Applicable (NA) for the following OSHA requirements. If you answered “No” to any question, explain on the reverse of this form.

Facility

_____ Are all secondary containers, such as spray bottles and chemical bottles, properly labeled and readable?

_____ Are all sharps containers filled below the “fill” line (or 2/3 full) and positioned firmly so that they cannot be casually knocked over?

_____ Are biohazard waste bags/storage bins in the proper locations (in every area where blood or OPIM is encountered) and functioning properly?

_____ Is the biohazard storage area clean and orderly?

_____ Is the autoclave working properly? Are weekly biological indicator test records complete? (Reference Form 2.)

_____ Are scavenging systems for waste anesthetic gas (hoses, bags, masks, and connections) inspected for cracks and leaks?

_____ Is the eyewash station functioning properly? (Run water for several minutes and disinfect eyepieces; see Tab 8 for details.)

_____ Are exit signs visible and illuminated where required?

Administration_____ Have hepatitis B vaccinations been made available to unvaccinated new hires with

occupational exposure to bloodborne pathogens after training and within 10 working days of initial assignment?

_____ Have tuberculin skin tests (TST) been made available to new hires before exposures to patients with TB or within 10 working days of initial assignment?

_____ Is the exam/treatment room set-up and clean-up procedure consistently followed? (Reference Form 7.)

Date: ______________ OSHA Safety Officer: ______________________________________

2-11


MONTHLY FACILITY REVIEW CHECKLIST

Mark Yes (Y), No (N), or Not Applicable (NA) for the following OSHA requirements. If you answered “No” to any question, explain on the reverse of this form.

Facility

_____ Are compressed gas cylinders securely fastened in an upright condition? Are empty or unused gas cylinders capped and properly labeled?

_____ Are exit doors free of blockage, clearly marked and unlocked?

_____ Are fire extinguishers fully charged, accessible, and in their designated places?

_____ Are all floors and carpets dry and free of tripping hazards?

_____ Are stored items not stacked higher than 5 feet (unless a stepstool is available), stable, and located more than 3 feet from any heat source?

_____ Are PPE (gowns, face shields, gloves, shoe covers, etc.) and respirators (N95s) in the proper location, available in the correct sizes and amounts, and functioning properly?

_____ Are hand cleansers available and in the proper locations?

_____ Are all chemicals labeled legibly so contents and hazards are clearly identified?

_____ Are chemical and biohazard spill kits available and within their expiration date?

_____ Are all first aid kit/crash cart components within their expiration dates?

Administration

_____ Have all new employees completed a “New Employee OSHA Orientation” checklist? (Reference Form 26.)

_____ Is the MSDS binder and the Master Hazardous Substances List up to date, reflecting any new chemicals brought into use this month? (Reference Form 19, MSDS Binder.)

_____ Do the Exposure Determination Lists #1 and #2 reflect new employees with occupational exposure? Have employees who left the facility been removed? Have employees whose job duties changed been added/deleted? (Reference Form 8, 9.)

_____ Has a new clinical procedure been implemented which requires face, body, or hand protection? If so, has the PPE table (Tab 5) been updated?

Date: ______________ OSHA Safety Officer: ______________________________________

2-12


ANNUAL FACILITY REVIEW CHECKLIST

Mark Yes (Y), No (N), or Not Applicable (NA) for the following OSHA requirements. If you answered “No” to any question, explain in the space provided below or on the reverse of this form.

General Facility Safety_____ The OSHA poster, “It’s the Law” (or state equivalent poster) is visible to all

employees. _____ Exit doors are free of blockage, clearly marked, and unlocked. _____ Exit signs are properly lit and backup lights/batteries are functioning. _____ If your facility has 10 or more employees, a written evacuation plan/route is posted. _____ Medical equipment cords have grounded 3-pronged plugs. _____ Extension cords are being used properly (not as permanent wiring). _____ Electrical cords are managed to prevent tripping hazards (not placed under rugs or

across doorways). _____ Electrical cords are in good condition (no frays, defects, etc.). _____ The fire alarm is in proper working order. _____ An appropriate number of fire extinguishers are present/accessible. _____ The fire extinguishers have been inspected and tagged within the last 12 months and

are fully charged. _____ Panic buttons, or public address systems, are in working order. _____ The worksite is maintained in a clean and sanitary condition. _____ Restricted areas (lab, decontamination room, etc.) are designated with signage.

Break Room_____ The break area is free of contamination from blood and other potentially infectious

materials (OPIM). _____ Employees discard PPE before entering the break area. _____ The break area is free from hazardous chemicals.

Check-in/Reception_____ An up-to-date emergency contact list is posted or present. (Reference Form 7-A.)

_____ The reception area is free of contamination from blood and OPIMs. _____ Employees discard PPE before entering the reception area. _____ The reception area is free from hazardous chemicals.

Administration Area_____ All employees have undergone OSHA annual retraining on bloodborne pathogens,

hazard communication, and TB in the last 12 months and this training is documented. (Reference Form 27.)

_____ All new employees received initial OSHA training (if not previously trained) or completed a New Employee Orientation Checklist (if previously trained) and this training is documented. (Reference Form 26.)

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_____ Employees are trained on the proper precautions, and how to properly don and use, the PPE necessary for their job duties. (Reference Forms 26, 27)

_____ All employees participated in at least one fire drill this year. (Reference Forms 5-A, 5-B)

_____ Employees have been trained on how to respond in the event of a fire (R.A.C.E. or A.R.A.C.E.). (Reference Forms 26, 27)

_____ Employees have been properly trained on how to use a fire extinguisher (P.A.S.S.)? (Reference Forms 26, 27)

_____ All OSHA training records from the last three (3) years are available? (Reference Forms 26, 27)

_____ Exposure Determination Lists #1 and #2 document all employees with risk for exposure. (Reference Forms 8, 9)

_____ The facility has documented all needlesticks and other sharps injuries which occurred this year using the Accident/Sharps Injury Log? (Reference Form 14 )

_____ All employee accidents, near-misses, injuries and complaints (check Safety Report and Accident/Sharps Injury Logs) were examined for trends. The need to change engineering controls, policies or procedures was evaluated. (Reference Forms 1, 14)

_____ In areas where trends were noted above or safer sharps have not yet been implemented frontline employees have evaluated new safety devices for possible future implementation. Evaluations have been documented, and evaluation forms are retained. (Reference Forms 10, 11, 12, 13)

_____ Hepatitis B vaccination records (or declination forms) are available for all employees. (Reference Forms 15, 16)

_____ Employee post-exposure medical records (for all employees who sustained a needle-stick or other BBP or chemical exposure) are complete and located in a confidential area. Records are available from the last 30 years. (Reference Forms 14, 17, 18, 18-A)

_____ Engineering controls are functioning effectively (protective shields have not been removed or broken, and all parts are functioning as intended).

_____ The Hazardous Substances List contains all hazardous chemicals in the facility (check for new chemicals recently brought into use). (Reference Form 19)

_____ MSDS binder(s) are in the proper location (accessible to employees). _____ MSDS are present for all hazardous chemicals in the facility, including fire

extinguishing chemicals. (Reference MSDS (SDS) binder)

_____ TB skin test (TST) records are on file for all employees. (Reference Forms 22, 23)

_____ The annual TB risk assessment has been performed. (Reference Form 21)

_____ The contents (type and number of items) of the first aid kit have been reviewed and are considered adequate for emergencies anticipated in the facility.

Storage Area_____ Hazardous chemicals are stored properly (e.g., combustibles away from outlets, large

volumes of flammables in a flammable cabinet etc.) and are disposed of properly. _____ Chemicals are labeled legibly with contents and hazards clearly identified. Labels

match the identity on the corresponding MSDS. (Reference Form 19, MSDS (SDS) binder)

_____ Appropriate PPE (gloves, respirators, goggles/face-shields, aprons) is available/accessible for handling hazardous chemicals. (Reference MSDS (SDS) binder)

_____ All items are stored at least 18 inches from the ceiling.

(Annual Facility Review Checklist, page 2 of 3)

2-14


Exam Rooms/Clinical Areas_____ All eyewash stations are in proper working order. _____ Universal Precautions are used when handling all blood and Other Potentially

Infectious Materials (OPIMs). _____ Handwashing facilities (sinks with soap or alcohol gels) are available in all areas

where biohazards and patients are encountered. _____ The biohazard symbol/label is used to indicate the potential presence of BBPs for

all blood & OPIMs. _____ Contaminated items and regulated waste are placed into approved biohazard bags

and containers displaying the biohazard symbol. _____ Biohazard waste bags/storage bins are located in every area where blood or OPIM

are encountered and functioning properly (i.e. they seal). _____ PPE (gloves, gowns, masks, goggles/face shields) is in the proper location. It is

available in the correct sizes and amounts, and functions properly. _____ Sharps containers are in the proper locations and positioned firmly so that they

cannot be knocked over. _____ Sharps containers are replaced as soon as they reach the “fill line” and not filled

past 2/3 full. _____ The most effective engineering controls are available and functioning correctly?

(i.e. safety needles, sharps containers, fume hoods, splash shields) _____ Employees decontaminate and clean work surfaces as soon as contaminated and at

the end of every shift with an appropriate disinfectant?

Cleaning/Decontamination Room_____ PPE (gloves, gowns, masks, goggles/face shields) is in the proper location. It is

available in the correct sizes and amounts, and functions properly? _____ Is appropriate PPE (rubber or vinyl gloves, respirators, goggles/face shields, aprons)

available and accessible for handling hazardous chemicals in the workplace? _____ Employees decontaminate and clean work surfaces as soon as contaminated and at

the end of every shift with an appropriate disinfectant? _____ Chemicals are labeled legibly with contents and hazards clearly identified. Labels

match the identity on the corresponding MSDS. (Reference Form 19, MSDS binder)

_____ Hazardous chemicals are stored properly (e.g., combustibles away from outlets, large volumes of flammables in an explosion-proof flammable cabinet etc.) and are disposed of properly.

_____ Soaking basins or reservoirs used for decontamination of instruments have tight fitting covers to reduce evaporation of hazardous vapors?

Comments (explain any “No” answer): _____________________________________________________________________________________________________________________________________________________________________________________________________

Date: __________ OSHA Safety Officer*: __________________________________________

* Note: Also document this annual OSHA Program Manual review on Form 3.

(Annual Facility Review Checklist, page 3 of 3)

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ANNUAL OSHA SAFETY PROGRAM (INCLUDES EXPOSURE CONTROL PLAN,

HAZARD COMMUNICATION PROGRAM AND RESPIRATORY PROTECTION PLAN) REVIEW

Date Reviewed By Page # of Changes Summary of Revisions*

*Include evaluations of sharps containers, safety needles and protective equipment

TAB 4: ERGONOMICS IN THE MEDICAL WORKPLACE

Contents

A Quick Look at Ergonomics .......................................................................... 4-1Common Musculoskeletal Disorders ............................................................. 4-2

Back Injuries ...........................................................................................................................4-3Techniques to Reduce Injury ...........................................................................................4-4

Fatigue ....................................................................................................................................4-5Repetitive Stress Injuries/Wrist Injuries ..................................................................................4-6

Wrist and Hand Exercises ...............................................................................................4-6Eye Strain ...............................................................................................................................4-8

Why Prevent CVS? .........................................................................................................4-8Symptoms of CVS ...........................................................................................................4-8Other Suggestions for Relieving Eye Strain ....................................................................4-9

Selecting Equipment ........................................................................................ 4-10

Page

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ERGONOMICS IN THE MEDICAL WORKPLACE

A Quick Look at Ergonomics“Ergonomics” is the science of fitting the job to the worker. Workers who repeat the same motion throughout their workday, or perform their work in an awkward position, or need to use a great deal of force to perform their jobs (e.g., repeatedly lifting heavy objects), are most likely to develop musculoskeletal disorders (MSDs). Ergonomics is the process to design work to the worker to reduce injury and illness so that employees are more comfortable and therefore more productive.

Many different tasks are performed in a clinical setting:sitting and standing at different work-stations, computers, and benches using different instruments and equipment using different movements to perform tasksassisting with patient movement and transfer

All of these tasks put different demands on our bodies. Some of these demands may lead to strain or injury. Work-related musculoskeletal disorders account for 34% of all lost workday injuries and illnesses, accounting for $15 to $20 billion in workers’ compensation costs each year. Indirect costs may run as high as $45 to $60 billion.

Ergonomics examines the demands put on our bodies and focuses on the safest and most efficient way to perform a task. Ergonomics is dependent on the physical needs and demands of each individual employee such as height as well as arm and leg length. Physical size and shape is important in designing work areas and equipment. Ergonomics minimizes the amount of stress put on our bodies. Work areas should be customized in accordance to the individual employee whenever possible.

More importantly than saving employers money, ergonomics keeps employees safe and comfortable in their work environment. Practicing ergonomics can help prevent a serious injury that could be painful, debilitating or permanent.

The Occupational Safety and Health Administration (OSHA) currently has no specific standard for ergonomic hazards. Rather OSHA will use the General Duty Clause as a basis for employer citations. Before issuing any citation alleging ergonomic hazards, OSHA will consider the evidence and relevant factors for each case. The basic criteria OSHA will use in deciding whether to cite are those imposed by the General Duty Clause itself:whether there exists an ergonomic hazard,whether that hazard is recognized,

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whether the hazard is causing, or is likely to cause, serious physical harm to employees,

and whether a feasible means exists to reduce the hazard.

State OSHA plans may have adopted specific ergonomic guidelines from various industries. California OSHA (CalOSHA) requires a “repetitive motion injury prevention program” when at least two employees, performing the same job or work activity, develop repetitive motion injuries, but exempts employers with fewer than ten employees.

Many ergonomic-related injuries are avoidable and preventable. Some steps to take toward this goal are to:

Review injury and illness records to see where problems have occurred.Interview employees to identify tasks that may be contributing to workplace

musculoskeletal disorders. Get input from employees on suggested improvements.

Investigate ways to reduce repeated motions, forceful hand exertions, prolonged bending, or working above shoulder height.

Common Musculoskeletal DisordersThese ergonomic stressors are typically experienced by healthcare workers:

Stressor ExamplesForce Lifting more than 75 pounds at any one time; more than 55 pounds more than 10 times

per day; or more than 25 pounds below the knees, above the shoulders, or at arm’s length more than 25 times per day.

Repetition Repeating the same motions every few seconds or repeating a cycle of motions involving the affected body part more than twice per minute for more than two consecutive hours in a workday.

Awkward Postures

Repeatedly raising or working with the hands above the head or the elbows above the shoulders for more than two hours per day.Kneeling or squatting for more than two hours per day.

Working with the back, neck or wrists bent or twisted for more than two hours per day.

Vibration Using vibrating tools or equipment for more than two hours per day.

Contact Stress

Using the hand or knee as a hammer more than 10 times per hour for more than two hours total per day.

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Exposure to these stressors in the workplace can result in a variety of disorders, including muscle strains and tears, ligament sprains, joint and tendon inflammation, pinched nerves, and herniated spinal discs. These MSDs may develop gradually over time or may result from instantaneous events such as a single heavy lift.

To identify where and how job requirements exceed the physical capabilities of employees, OSHA suggests doing a worksite analysis. Such an analysis looks at the conditions of the job and the aspects of work activities that result in increased risk to employees.

Begin by reviewing illness and injury logs, compensation records, and reports of problems. Have discussions with affected employees, or just walk around your workplace to find tasks that warrant analysis. Another option is to use employee questionnaires or checklists to better identify problems.

OSHA suggests using algorithms to train staff about appropriate options or control methods for specified tasks. To create an algorithm, begin by listing the activity with a description explaining the type of equipment or handling methods used and when they are to be used. Provide “points to remember” to remind users about proper safety and effective use.

If your workplace has ergonomic stressors, consider developing controls to minimize them. The stressors most likely to exist in outpatient medical facilities are back injuries, fatigue, repetitive stress injuries/wrist injuries and eye strain.

Back Injuries

Back injuries are a common occurrence among healthcare workers, especially if patients are moved or lifted.

To avoid back injuries in the workplace:

1. Use proper techniques for lifts and transfers:

Bend at the hips and knees.Lift with your leg muscles, not your back or arm muscles.Avoid any twisting motion.Never lift a load higher than your waist.Keep the load close to your body.Ask for help when necessary.

2. Provide and use lifting devices when employees are expected to assist patients in ways that could result in ergonomic injuries. OSHA provides guidance on when mechanical means may be necessary (see flowchart next page).

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Techniques to Reduce Injury

When lifting a box:

Photo from CalOSHA. Photo from CalOSHA. Photo from CalOSHA.

Incorrect technique when lifting box.

Correct technique when lifting a box.

Ask for help with heavy lifts.

Deciding to use mechanical help when transferring patients:

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When assisting a patient:

Photo from CalOSHA. Photo from CalOSHA.

Incorrect technique, pulling patient onto exam table.

Correct way to assist patient onto exam table.

When working with medical records:

Incorrect to overreach when retrieving patient records.

Incorrect, record too large and cumbersome.


Correct, use a step stool to get to records easily.

Correct, split large records into smaller, more manageable volumes.


Fatigue

Because of the sedentary nature of computer tasks, employees often get fatigued. Sitting too long can cause neck and back pain. Circulation problems can occur in the legs.

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To avoid fatigue:

1. Take breaks for a few minutes each day, stretching and moving about the office. 2. Engage in exercises like these, right at the desk:

Deep breathingHead rotationsShoulder rollsStretchesElbow presses

Repetitive Stress Injuries/Wrist Injuries

Carpal Tunnel Syndrome (CTS) from prolonged computer use is becoming one of the most common employee medical problems. Claims for CTS have been increasing by 50% annually.

The following safety tips and guidelines can help prevent employees from developing injuries due to repetitive stress:

1. Adjust chairs to a comfortable height for computer work.2. Keep the height and angle of the keyboard at a comfortable level for wrists and

hands. Elbow height is best. 3. Keep wrists moderately straight and relaxed whenever possible.4. Use wrist pads across the bottom of the keyboard.5. Take a break to do some wrist and hand exercises (below) that will prevent CTS.

Wrist and Hand Exercises

There are many exercises that can be performed in your work area to increase the circulation in your muscles. Pain and stiffness comes from sitting still or working in one position for an extended period of time.

A. While standing straight extend both arms out in front of you. Extend your wrists and fingers acutely as if they were in a hand-stand position. Hold this position for 5 seconds.

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B. Next, keeping your arms extended in front of your body, flatten your wrists and relax your fingers so they “droop” towards the ground.

C. Keeping your arms extended in front of your body and your wrists straight make a fist and squeeze it tightly. Hold for 5 seconds.

D. Keeping your arms extended in front of your body and your fists tightly clenched, bend your wrists down towards the ground. Hold the position for 5 seconds.

E. Straighten both wrists and relax your fingers once again so they “droop” towards the ground.

F. Repeat steps A-E 10 times, then while standing relax your arms, wrists and hands, letting them fall to your sides.

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Eye Strain

Computer Vision Syndrome (CVS) is the most common repetitive stress injury brought about by video display terminal (VDT) work, despite the fact that it is not as well known as some other computer-related conditions such as carpal tunnel syndrome.

According to NIOSH, nearly 80% of those working at a computer for more than two hours a day suffer from the symptoms of CVS. But while less than one in four regular computer users suffer from carpal tunnel syndrome, three times as many experience CVS.

Why Prevent CVS

Workers with computer-related vision problems are usually less efficient on the job and experience higher error rates as the day goes on. The Journal of the American Optometric Association reports that just a small amount of visual interference, such as glare, causes a reduction in employee efficiency of 4% to 19%. Poor contrast, poor resolution, glare and reflections on the screen can all exacerbate CVS symptoms.

The following problems are characteristic of working in front of computer screens:

Problem: Reflections from surrounding light sources. Glare from lights reflecting off the screen lowers the contrast, thus forcing the eyes to work harder. Solutions: Typical office lighting is twice as bright as the optimal lighting conditions for computer work. Workstation lighting should be shaded to avoid reflections on the monitor. Use a glare reduction filter approved by the American Optometric Association.

Problem: Unclear or flickering images on VDT screen.Solutions: Select monitors with higher hertz, or frequency. These have a lower amount of perceptible flickering. A monitor with a higher pixel (at least 110 pixels per inch) has better resolution and readability.

Problem: Continuous, uninterrupted activity at a computer station. This causes the eyes’ focusing mechanisms to tire. Solutions: Proper eyeglass prescriptions. Take frequent breaks—at least 10 minutes every hour.

Problem: Focal distance is farther than normal reading distance. People normally hold reading materials 12 to 18 inches from their eyes. Eye doctors typically prescribe reading or “near vision” prescriptions for that range, but computer screens are usually situated 18 to 30 inches from the user (see Figure 4-1, next page).

Symptoms of CVS

Tired, burning, itching eyes.Dry eyes or watery eyes or both.Headaches.Double vision and after-images.Sensitivity to light.Pain in the eyes.Development of excessive blinking

or squinting.

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Solutions: Move screen closer. Get a special lens prescription to focus clearly at these distances for extended periods.

Problem: Screen height. For wearers of bifocals and trifocals, the prescription for close tasks is set into the lower portion of the lens, but VDTs are set relatively high, near eye level or higher. Solutions: Bifocal and trifocal wearers may require special lenses to function effectively at computers. Adjust computer screens 5 to 20 degrees below eye level for these users (see Figure 4-1, below).

Other Suggestions for Relieving Eye Strain

1. Consciously increase your blink rate while using the computer.2. Position the computer screen directly in front of you, slightly below eye level.

Routinely clean the screen to eliminate dust that can dim the display. 3. Arrange your workstation to keep your eyes at a natural focusing distance from

the screen, 18 to 30 inches (see Figure 4-1, below).4. Reduce intense color contrasts between the background and printed text.5. Get a larger computer monitor. 6. Arrange reference

material close to your monitor and at the same level to reduce the amount of refocusing.

7. Exercise your eyes by rolling them clockwise then counter clockwise. Blink frequently. “Palm” (massage) your eye area.

Figure 4-1

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Selecting Equipment

One of the largest factors to keep in mind when purchasing equipment is: “Is it adjustable?” Money thought to be saved up-front by purchasing cheaper items often creates additional expenses later on due to extra purchases needed to make non-adjustable equipment/furniture fit the next user.

Carts

Carts are helpful as they reduce physical stress when moving medications, cleaning supplies, equipment, and maintenance tools. Position items on the cart to keep the most frequently used and heavy items within easy reach between hip and shoulder height.

Carts should have full-bearing wheels of a material designed for the floor surface in your facility. Cart handles that are vertical, with some horizontal adjustability will allow all employees to push at elbow height and shoulder width. Carts should have locking wheels. Handles that can swing out of the way may be useful for saving space or reducing reach. Heavy carts should have brakes.

Balance loads and keep loads under cart weight restrictions. Ensure stack height does not block vision.

Low profile medication carts with easy-open side drawers are recommended to accommodate hand height of shorter users.

Chairs

Consider having vendors provide a trial period for all new chairs of at least one week. Have vendors provide a documented ergonomic assessment listing theanthropometric data (i.e. lower leg length, hip to knee length, seated width, upper torso height, and elbow height) while seated of the user and use these measurements to select a chair that will adjust to meet the users’ needs.

All chairs should meet following guidelines:

Have five replaceable casters.Be height adjustable with a single hand movement.Have a height adjustable back with lumbar support.Have an adjustable seat pan depth.Use breathable, cleanable fabric.Have moderate density foam cushioning with a waterfall front edge. (Seats with

low-density foam will break down quicker and require re–foaming or replacement sooner than a moderate to high-density foam cushion)

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If a chair is purchased with arms, consider adjustable arms (both horizontally & vertically) as well as the ability for the arms to be removed if necessary.

Consider specialty chairs for ultrasound technicians and others whose tasks require prolonged forward leaning postures.

Desks and Work Stations

Some considerations for desks and workstations are:

1. “Is it adjustable?” Workstations should have the ability to adjust up or down.2. “Does the job require work to be performed in a seated as well as a standing

position?” If so, seek a seated to standing workstation.

The acceptable range for work surface height in a seated position:

5 – 10 cm above elbow height for precision work (i.e. drawing up meds, pipetting).At elbow height for most writing tasks and general office work.No more than 5 cm below the elbows for coarse work (pre-cleaning instruments).

The acceptable range for work surface height in a standing position:

10 cm above elbow height for precision work.At elbow height for general office work.10 cm below elbow height for heavy work.

Footrests

Footrests should be used if the user’s feet do not touch the floor (flat footed) when seated at the workstation. Legs, if allowed to dangle unsupported from the front edge of the seat, will place static pressure on the thighs causing eventual discomfort. The opposite (knees too high) can also place static pressure on the leg muscles causing discomfort as well. Footrest should be large enough to support both feet at a height that allows the knees to be positioned approximately equal to 90 degrees while seated.

Keyboard Trays

Seek a vendor that offers a free change service if at a later date the keyboard tray needs to be changed due to a different user or setup.

Desirable characteristics for keyboard trays:

Height adjustable.Articulating (rotate 360 degrees).

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Allow for positive and negative tilt.Capable of being locked in place.Operate on ball bearing slides.Sized to support the keyboard and mouse as desired by the user.Large enough to accept a wrist rest.

Mobile Medical Equipment Use small cylinders with handles for medical gases (i.e. oxygen tanks) to reduce weight and allow for easier gripping. Secure oxygen tanks to transport devices. Use stands on wheels for medication pumps.

Push equipment, rather than pull, when possible. Keep arms close to the body and push with whole body and not just arms. Remove unnecessary objects to minimize weight.

Avoid obstacles that could cause abrupt stops. Place equipment on a rolling device if possible. Perform routine maintenance on all equipment. Take defective equipment out of service. Ensure that if transporting patients, additional equipment such as oxygen tanks and IV/medication poles are attached to wheelchairs or gurneys or moved by another person to avoid awkwardly pushing with one hand and holding freestanding equipment with the other hand.

Monitor Stands and Arms

Monitors need to be positioned in front of the user while typing. Ask the questions below before selecting a monitor-positioning device. Ensure the item adequately addresses all that apply.

At what height does the monitor need to be placed for the user?Does the user wear multi-prescription glasses (bi or tri focal or reading)?Where will the monitor be placed?Does it need to be moved frequently?Does the monitor need to hang over the back of the desk (space issue)?Are there multiple users using the computer?Does the monitor need to be swiveled/ rotated while on the stand?

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Monitor devices need to have the following features:

Support the weight and size of a large monitor (40 pounds).Allow for quick and easy adjustment.Secure with a clamp, or rest on the desk surface (avoid screw mounted and

wall mounted devices if damage left behind when repositioning is required is a concern).

Fixed monitor devices can be used but keep in mind that they may not adjust to the proper height for the next user.

Avoid monitor arms, rests or stands that require the insertion of spacers or additional pieces, which can be lost.

Personal Protective Equipment

Exam gloves, masks, eye protection and fluid resistant gowns should be offered in various sizes to fit the workers assigned tasks for which these types of PPE are required.

X-ray technicians and others who wear lead aprons for extended periods (the majority of their day) may experience prolonged stress on the shoulders and spine. In this situation consider lighter aprons, lead-free options, and PPE that is sized as opposed to “one size fits all”. The amount of strain reported by employees is greatly reduced when the lead apron fits closely to the employee’s body.

Sinks

Choose sinks that prevent excessive bending and reaching during cleaning tasks. Modify a deep sink when it’s needed for cleaning small items by placing an object, such as a plastic basin, in the bottom of the sink to raise the work surface.

Note: if this method is used when cleaning objects contaminated with bloodborne pathogens, the bin needs to be decontaminated with a hospital level disinfectant.

TAB 10: EMPLOYEE TRAINING

Contents

A Quick Look at the Employee Training Program ......................................... 10-1Training Format ................................................................................................ 10-1

Checklist for an Effective Safety Training Session .................................................................10-2Interactive Safety Training Exercises ......................................................................................10-2

General Safety ................................................................................................................10-3Fire Safety .......................................................................................................................10-3Bloodborne Pathogens Safety ........................................................................................10-3Chemical Safety ..............................................................................................................10-3TB Safety ........................................................................................................................10-4

Annual Employee Retraining .......................................................................... 10-5Bloodborne Pathogens Annual Training Contents ..................................................................10-6Respiratory Protection Annual Training Contents....................................................................10-6Hazard Communication Annual Training Contents .................................................................10-7

New Employee Orientation .............................................................................. 10-7New Employee OSHA Orientation Checklist (Form 26) ..........................................................10-8

Sample Tests with Answer Keys ..................................................................... 10-10OSHA Annual Retraining: Sample Essay Test Questions (Form 28) ......................................10-11OSHA Annual Retraining: Sample Essay Test—Answer Key .................................................10-12OSHA Annual Retraining: Sample Multiple Choice Test Questions (Form 29) .......................10-13OSHA Annual Retraining: Sample Multiple Choice Test—Answer Key ..................................10-15OSHA Annual Retraining: Sample True/False Test Questions (Form 30) ...............................10-16OSHA Annual Retraining: Sample True/False Test—Answer Key ..........................................10-17

Documenting Employee Training ................................................................... 10-17Annual Employee Training Record (Form 27) ............................................... 10-18

Page

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EMPLOYEE TRAINING

A Quick Look at the Employee Training ProgramThe OSHA Safety Officer is responsible for overseeing your facility’s employee training program, which involves annual retraining as well as new employee orientation. It is suggested, but not required, to conduct a brief, interactive session devoted to a safety issue at every staff meeting. A physician or other qualified medical professional (nurse, medical assistant, laboratory technologist, etc.) may provide the training, as long as he/she is competent in address-ing questions pertaining to OSHA compliance. An infection prevention background is helpful, especially for bloodborne pathogens and TB training. Training sessions are provided during work hours at no cost to the employee. Material appropriate in content and vocabulary to the educational level, literacy, and language background of employees is used, such as videos or lectures.

Training FormatEducational formats, such as live presentations, interactive or noninteractive computer programs, or videos, may be used to fulfill employee training requirements. However, a qualified person must be available to answer questions during a discussion period specifically for all types of bloodborne pathogens training. A telephone hotline may suffice in fulfilling this requirement, according to January 17, 2008, OSHA interpretation letters; however, voice mail, e-mail, paging systems, or other methods that don’t guarantee an immediate response are not compliant. For more details on the interactive requirement, search for “Clarification on trainer requirements and access to trainer under OSHA’s bloodborne pathogens standard” at www.osha.gov. The training must contain information that none of these formats can accomplish, such as:

Where the OSHA manual and MSDS (SDS) binder are located in the facilityWhere fire extinguishers, eyewash stations, and exit doors are located in

the facilityWhere personal protective equipment is located in the facility

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Checklist for an Effective Safety Training Session

Safety presentations, are a challenge to keep entertaining. Employees may not expect to be amused or involved.

The following eight tips help lead to a more effective presentation:

Plan the event – Set objectives, limit the focus of your talk, and project your belief in the subject matter.

Involve management – The training program will only achieve its objectives if management is committed to employee safety. Have a member of management in attendance to clarify policies.

Be creative – Use audio, visual, role plays and hands-on material to increase employees’ retention of the information. Use techniques that best communicate to your specific employees.

Demonstrate – Use props in cases where it’s more effective to demonstrate the use of an item than explain it.

Keep it moving – The most effective speakers move throughout the room. Create activities, which allow audience participation from the front row to the last.

Use employees as teachers – Let the audience relate the subject matter back to their own real world experiences. Listen to the examples offered and expand on them.

Help employees buy into the process – The best training information is worthless if employees do not see how it will benefit them. Use specific on-site accident examples to show the relevance of the program to their own safety.

Head off opposition – Use off-the-job examples if the group is resistant to someone telling them how to do their work. Off-the-job examples drive the point across in a much less threatening way.

Interactive Safety Training Exercises

A good safety program involves not only management commitment but employee involvement. Employees will retain more information and practice safety procedures if safety training is interesting and interactive. The following suggestions can be included in employees’ annual training or can serve to reinforce management’s commitment to this OSHA Program Manual at staff meetings.

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General Safety

Demonstrate the location and operation of the eyewash(s).Demonstrate the location of circuit breakers and describe procedures used in the

event of electrical shock injury.State the location of compressed gas cylinders and describe precautions

regarding their use.Describe hazards of radioactive materials and precautions regarding their use.

Fire Safety

State location of fire extinguisher(s) and demonstrate or describe their use.State location of fire alarms, if any.Identify location of evacuation routes from the building.Explain procedures to follow in the event of a fire (the RACE procedure).Participate in a mock fire drill.

Bloodborne Pathogens Safety

Describe the protocol for cleaning up a blood spill.Describe the protocol for disposal of sharps/used needles.Locate the Exposure Control Plan.Demonstrate aseptic removal of gloves.Describe when personal protective equipment is used/required.

Chemical Safety

Locate the MSDS (SDS) binder and look up a hazardous chemical with which you work, then:State the primary route of entry for this chemical (skin, lungs, eyes, etc.).Discuss the symptoms of overexposure to this chemical.Identify the protective equipment and ventilation that is required when

working with this chemical.Locate the protective equipment in the area. State where replacements are

located.State the emergency first aid procedures for the chemical.

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State the location of the chemical spill kit.Demonstrate how to clean up a chemical spill.Discuss the new GHS pictograms, labeling format and sections of the SDS.

TB Safety

Conduct a role play for exactly what action to take when a potential TB patient enters the facility. Discuss the effectiveness of current policies.

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Annual Employee Retraining OSHA requires annual training for employees covered under the Bloodborne Pathogens and Respiratory Protection standards. HCPro also strongly recommends annual retraining on the Hazard Communication Standard (“Right To Know” and now under the GHS update, “Right to Understand”).

It also makes sense to include miscellaneous safety procedures, such as workplace violence prevention and fire safety. At least once per year, all employees should be shown the location and proper use of fire extinguishers, fire alarms, and exit routes.

Training Topic Who Must Attend When to Train

Annual Retraining on Bloodborne Pathogens

Employees named on either Exposure Determination List.

• Before potential on-the-job exposure.

• Annually.

• Provide abbreviated training for affected employees whenever a new procedure is adopted that involves potential exposure to bloodborne pathogens.

Annual Retraining on Respiratory Protection

Employees required to wear a respirator.

• Before potential on-the-job exposure.

• Annually.

• When changes in the workplace or the type of respirator render previous training obsolete.

• When employee’s knowledge or use of the respirator indicates retraining is needed.

Annual Retraining* on Hazard Communication

New and current employees who are exposed to hazardous chemicals in the normal course of their duties.

• Before potential on-the-job exposure to hazardous chemicals.

• Annually.

• Employees who face exposure whenever a new hazardous chemical is introduced in the workplace.

• All employees on the GHS update regarding pictograms, new labeling requirements and SDS format.

* HCPro recommends employees complete HazCom training both initially and then annually. Although minimum legal requirements do not dictate annual retraining for employees, we strongly recommend annual training for those working with hazardous substances. Chemicals are always being added or eliminated from the workplace, so it makes sense to refresh your staff by training each year.

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Bloodborne Pathogens Annual Training Contents

Access to this OSHA Program Manual (and instructions for how to access in the future), which includes written policies for OSHA compliance. The OSHA Program Manual also includes an Exposure Control Plan for both the Bloodborne Pathogens Standard. Finally, the OSHA Program Manual includes copies of the following regulations: the Bloodborne Pathogens Standard and the Hazard Communication Standard.

An explanation of the signs and labels used in this workplace.A general explanation of the modes of transmission, epidemiology, and symptoms

of bloodborne diseases (HBV, HCV, HIV).An explanation of methods to recognize tasks that may involve exposure to blood

or other potentially infectious materials and the practices to prevent or reduce exposure. (This includes a discussion on the required use of safety sharps.)

A discussion of the limitations of the above practices to prevent or reduce exposure to bloodborne pathogens. (This includes a discussion on which sharps in the facility are not safety sharps and a reminder to bring the use of any non-safety sharps to the OSHA Safety Officer for inclusion with the annual sharps review process.)

Information on the types, proper use, location, removal, decontamination, and disposal of personal protective equipment (PPE). A reminder that PPE MUST be worn for each task where there is reasonably anticipated exposure to blood or body fluids.

Information about the free hepatitis B vaccine, including its efficacy, safety, and benefits.

An explanation of what constitutes an exposure incident and the procedure to follow if an exposure event occurs.

Information about the type of post-exposure follow-up provided by this facility. An opportunity for employees to ask questions of the person conducting the

training session.

Respiratory Protection Annual Training Contents

Where the written respiratory protection plan is located and how to access it.An explanation of the requirements of the plan including identification of the

program administrator, respirator selection, medical evaluations, and fit testing.An explanation why the respirator is necessary and how improper fit, usage, or

maintenance can compromise the protective effect of the respirator.An explanation on the limitations and capabilities of the respirator.How to use the respirator effectively in emergency situations, including situations

in which the respirator malfunctions.

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How to inspect, put on and remove, use, and check the seals of the respirator.What the procedures are for maintenance and storage of the respirator.How to recognize medical signs and symptoms that may limit or prevent the

effective use of respirators. Hazard Communication Annual Training Contents

Where the Hazard Communication program, including MSDS (SDS), is located and how to access the program.

How to protect employees from the hazardous substances they work with (including precautions to take and protective clothing and equipment to use).

Proper labeling of hazardous chemicals.How to read and interpret MSDS (SDS) and labels.How to recognize if they have been exposed (such as visual appearance,

dizziness, or smell, etc.)How to clean up a chemical spill.What to do if exposure occurs.How to report an accident or exposure.

New Employee OrientationIn addition to annual retraining, employees must be trained initially about OSHA regula-tions as they pertain specifically to the workplace. Use the New Employee OSHA Orientation Checklist on the next page for this purpose, and behind Tab 11: Master Record Forms (Form 26).

It’s important not to assume that even employees with a clinical background will know how to protect themselves from hazards in your workplace because general safety knowledge may not transfer to a current work situation.

In addition to annual retraining, employees must be trained initially about OSHA regulations as they pertain specifically to the workplace:

Training Topic Who Must Attend When to Train

New Employee Orientation: All OSHA Safety Issues

New employees and employees who have

transferred from another location or department.

Within 10 days of commencing work.

10-8


NEW EMPLOYEE OSHA ORIENTATION CHECKLIST

(1 of 2 pages)

Note: A master copy of this form (2 pages) can be found behind Tab 11: Master Record Forms (Form 26).

Employee Name: _________________________________Date: _________________

Please mark “Y” to denote employee understanding, “N” if more information is needed, or “NA” if the item is not applicable to the employee’s responsibilities.

OSHA Bloodborne Pathogens StandardThe new employee knows:_____ Where the OSHA Program Manual is located._____ How bloodborne pathogens are transmitted (needlesticks, cuts, splashes,

sprays). _____ The signs and of the symptoms of HBV, HCV and HIV infection._____ Which body fluids encountered in this practice are potentially infectious._____ When, where and how to wash hands._____ Where eyewashes are located and how to use them._____ How to properly handle and dispose of sharps._____ Where sharps containers are located._____ What is considered biohazardous waste and where containers are located._____ When and how to close sharps containers and biohazardous waste containers

and transport them to the storage area._____ That restricted access areas indicated by biohazard labeling should only be

entered by trained and authorized personnel._____ How to properly package and store laboratory specimens._____ How to clean up biohazardous spills. _____ Where utility gloves are located and when to use them._____ How and when to wear the proper PPE to protect against potentially infectious

body fluids. _____ What to do with soiled, reusable PPE (care, maintenance, cleaning)._____ When to change exam gloves. Knows to wash hands after removing gloves._____ How to remove gloves safely._____ Where, when and how to use disinfectant cleansers based on the

Housekeeping Schedule located in Tab 8: Decontamination._____ How to operate the autoclave (including spore strip testing)._____ What constitutes an on-the-job exposure and what to do if an exposure occurs._____ That the hepatitis B vaccine is safe and available free of charge in this

workplace._____ That a titer will be performed after the hepatitis B vaccination series to verify its

efficacy.

10-9


(New Employee OSHA Orientation Checklist, page 2 of 2)

Hazard CommunicationThe new employee knows:_____ What hazardous chemicals exist in the practice (review master list)._____ How to work safely with the above chemicals._____ Where Material Safety Data Sheets (MSDS)/Safety Data Sheets (SDS) are

located and how to read them_____ How to recognize signs of chemical exposure and what to do if exposure

occurs._____ How and where to sterilize or disinfect instruments and equipment.

Other: _____________________________________________________________________.

TB/Respiratory ProtectionThe new employee knows:_____ How TB is transmitted and policies for identifying potential TB patients._____ The practice’s relative risk of encountering patients with TB (refer to TB Risk

Assessment Result Form)._____ What to do if an active TB patient enters the practice._____ That initial TB skin testing (TST) must be performed._____ Influenza vaccination and protection protocols.

Other: _____________________________________________________________________.

EmergenciesThe new employee knows:_____ Location of written emergency procedures and emergency telephone numbers._____ Exit routes and evacuation procedures._____ Where fire extinguishers are located and what to do in the event of a fire._____ Protocols for reporting workplace violence

Other: _____________________________________________________________________.

10-10


Sample Tests with Answer Keys

The following pages contain sample essay, multiple choice, and True/False questions that could be used for annual retraining. Answer keys are also provided.

10-11


OSHA ANNUAL RETRAININGSample Essay Test Questions

Note: A master copy of this test can be found behind Tab 11: Master Record Forms (Form 28).

1. Name two OSHA regulations that impact medical practices:

__________________________________________________________________________________________________________________________

2. What does OSHA stand for?

O____________________________ S____________________________H____________________________ A____________________________

3. List 3 bloodborne pathogens:

_______________________________________________________________________________________________________________________________________________________________________________________

4. Check all infectious body fluids for which OSHA requires universal/standard precautions:

___ Urine___ Pleural fluid___ Vomit___ Saliva ___ Blood___ Feces___ Semen___ Vaginal secretions___ Tears___ Amniotic fluid

5. Name 3 ways employees can be infected by bloodborne pathogens on the job:

__________________________________________________________________________________________________________________________________________________________________________________________

10-12


OSHA ANNUAL RETRAININGSample Essay Test - Answer Key

1. Two regulations that impact medical practices are:1. Bloodborne Pathogens2. Hazard Communication

2. OSHA stands for the: Occupational Safety and Health Administration

3. Three bloodborne pathogens are:1. Hepatitis B2. Hepatitis C3. HIV

4. Potentially infectious substances include the following:- Pleural fluid - Blood- Semen - Vaginal secretions - Amniotic fluid- Saliva (in dental procedures only)- Any body fluid visibly contaminated with blood

5. Ways employees can be infected on the job are:- Splashes or sprays to non-intact skin or pre-existing skin lesion- Needlesticks- Sharps injuries from broken glass, scalpels, slides, etc.- Mucous membrane contact through sprays, splashes, rubbing into eyes, nose,

mouth, etc.

10-13


OSHA ANNUAL RETRAININGSample Multiple Choice Test Questions


Circle the most appropriate response.

1. Which OSHA regulation does not impact medical practices?

a. OSH Act General Duty Clauseb. CLIAc. Hazard Communication d. Bloodborne Pathogens

2. Name one way employees can be infected with bloodborne pathogens on the job:

a. Handling urine specimens.b. Being exposed to patients who are coughing.c. Working with glutaraldehyde.d. Collecting blood samples from patients.

3. OSHA’s standard protects America’s healthcare workers against this most common bloodborne pathogen:

a. HIVb. Hepatitis Cc. Tuberculosisd. Syphilis

4. Which of the following is most likely to cause an actual infection after a needlestick with an infected patient, i.e., transmission occurs most easily?

a. HIVb. Hepatitis Bc. Hepatitis Cd. Hepatitis A

5. When performing a procedure where blood is likely to splash or spray, one must wear:

a. Gloves, gown, goggles.b. Gloves, gown, mask.c. Gloves, gown, full face shield.d. Gloves, lab coat, mask, goggles.

10-14


6. Universal/Standard Precautions implies that:

a. Healthcare workers should treat the blood and body fluids of all patients as if they are infected with HIV or hepatitis.

b. Healthcare workers should be cautious with all patients’ blood and body fluids.c. All patients’ blood and body fluid must be disposed of in red bags.d. None of the above.

7. Which of the following procedures are considered high risk for tuberculosis?

g. Drawing blood.h. Urine testing.i. Aerosolized administration of medication.j. Suture removal.

8. Which of the following does not require an MSDS (SDS)?

a. Clorox bleach used in 1:10 dilution to clean surfaces.b. High-level disinfectants (Cidex, Metricide, etc.) used to soak instruments.c. Household products containing hazard warning labels that are used differently

than at home.d. Household products with hazardous warning labels that are used exactly as they

are used at home and with the same frequency.

9. Which of the following is not true about eyewashes?

a. Employees must be able to reach eyewashes in 10 seconds.b. A squeeze-bottle mounted over a sink is ideal.c. The eyewash must be able to flush the eyes with tepid water for at least 15

minutes.d. An eyewash must have a visible sign.e. All of the above are true.

10. Which of the following is true about biohazardous waste containers?

a. Containers must be leakproof.b. Containers must contain the biohazard symbol.c. Containers must be located at the point of waste generation.d. All are true.e. None are true.

10-15


OSHA ANNUAL RETRAININGSample Multiple Choice Test - Answer Key

1. b

2. d

3. b

4. b

5. c

6. a

7. c

8. d

9. b

10. d

10-16


OSHA ANNUAL RETRAINING Sample True/False Test Questions


Mark True or False

___ 1. Sample antibiotics in pill form that are given to patients require a MSDS/SDS.___ 2. An employee can be dismissed from their job for not following the safety

policies in the OSHA Program Manual. ___ 3. An employee must wear gloves when working with blood or other potentially

infectious body fluids.___ 4. It is an OSHA violation to put regular trash in biohazardous red bags.___ 5. It is an OSHA violation to put biohazardous trash in regular wastebaskets or

cans.___ 6. Needlesticks don’t need to be reported unless the patient is known to have

HIV or hepatitis.___ 7. Solutions of bleach must be made up fresh daily.___ 8. An employee can be infected with HIV by a splash or spray of patient blood

to his eyes, nose or lips.___ 9. An employee can be infected with HIV by a splash or spray of patient blood

to his intact skin.___ 10. A patient who is likely to have active TB has had a productive cough for at

least three weeks.

10-17


OSHA Sample True/False Test - Answer Key

1. F

2. T

3. T

4. F

5. T

6. F

7. T

8. T

9. F

10. T

Documenting Employee Training Document annual employee retraining on the Annual Training Record (page 10-18). Document new employee safety training on the New Employee OSHA Orientation Checklist (page 10-8), also behind Tab 11: Master Record Forms (Form 26).

Retain all training records for at least three years.

10-18


ANNUAL EMPLOYEE TRAINING RECORDNote: A master copy of this form can be found behind Tab 11: Master Record Forms (Form 27)

Type of Training*: ____________________________ Date: ___________________

Subjects Covered**: ______________________________________________________________________________________________________________________

Trainer: __________________________ Title/Qualifications: _________________

I have read and understood the safety procedures outlined in our Exposure Control Plan and Hazard Communication Plan. After the training session, I was given the opportunity to ask questions to clarify the material. I will, to the best of my abilities, make every effort to practice these safety policies in order to reduce health risks to my coworkers, our patients and myself.

Date Employee Name/Job Title (Please print) Employee Signature

*Video, Seminar, etc. If employee attended a seminar, attach seminar description to this form. ** Bloodborne Pathogens, HazCom, TB, fire safety, etc.


Form 29

OSHA ANNUAL RETRAININGSample Multiple Choice Test Questions

(1 of 2 pages)

Circle the most appropriate response.

1. Which OSHA regulation does not impact medical practices?

a. OSH Act General Duty Clauseb. CLIAc. Hazard Communication d. Bloodborne Pathogens

2. Name one way employees can be infected with bloodborne pathogens on the job:

a. Handling urine specimens.b. Being exposed to patients who are coughing.c. Working with glutaraldehyde.d. Collecting blood samples from patients.

3. OSHA’s standard protects America’s healthcare workers against this most common bloodborne pathogen:

a. HIVb. Hepatitis Cc. Tuberculosisd. Syphilis

4. Which of the following is most likely to cause an actual infection after a needlestick with an infected patient, i.e., transmission occurs most easily?

a. HIVb. Hepatitis Bc. Hepatitis Cd. Hepatitis A

5. When performing a procedure where blood is likely to splash or spray, one must wear:

a. Gloves, gown, goggles.b. Gloves, gown, mask.c. Gloves, gown, full face shield.d. Gloves, lab coat, mask, goggles.


Form 29

(OSHA Annual Retraining – Sample Multiple Choice, page 2 of 2)

6. Universal/Standard Precautions implies that:

a. Healthcare workers should treat the blood and body fluids of all patients as if they are infected with HIV or hepatitis.

b. Healthcare workers should be cautious with all patients’ blood and body fluids.c. All patients’ blood and body fluid must be disposed of in red bags.d. None of the above.

7. Which of the following procedures are considered high risk for tuberculosis?

a. Drawing blood.b Urine testing.c. Aerosolized administration of medication.d. Suture removal.

8. Which of the following does not require an MSDS (SDS)?

a. Clorox bleach used in 1:10 dilution to clean surfaces.b. High-level disinfectants (Cidex, Metricide, etc.) used to soak instruments.c. Household products containing hazard warning labels that are used differently

than at home.d. Household products with hazardous warning labels that are used exactly as they

are used at home and with the same frequency.

9. Which of the following is not true about eyewashes?

a. Employees must be able to reach eyewashes in 10 seconds.b. A squeeze-bottle mounted over a sink is ideal.c. The eyewash must be able to flush the eyes with tepid water for at least 15

minutes.d. An eyewash must have a visible sign.e. All of the above are true.

10. Which of the following is true about biohazardous waste containers?

a. Containers must be leakproof.b. Containers must contain the biohazard symbol.c. Containers must be located at the point of waste generation.d. All are true.e. None are true.


Form 30

OSHA ANNUAL RETRAINING Sample True/False Test Questions

Mark TRUE or False

___ 1. Sample antibiotics in pill form that are given to patients require a MSDS (SDS).

___ 2. An employee can be dismissed from their job for not following the safety policies in the OSHA Safety Program.

___ 3. An employee is required to wear gloves when working with blood or other potentially infectious body fluids.

___ 4. It is an OSHA violation to put regular trash in biohazardous red bags.

___ 5. It is an OSHA violation to put biohazardous trash in regular wastebaskets or cans.

___ 6. Needlesticks don’t need to be reported unless the patient is known to have HIV or hepatitis.

___ 7. Solutions of bleach must be made up fresh daily.

___ 8. An employee can be infected with HIV by a splash or spray of patient blood to his eyes, nose or lips.

___ 9. An employee can be infected with HIV by a splash or spray of patient blood to his intact skin.

___ 10. A patient who is likely to have active TB has had a productive cough for at least three weeks.

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