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Rheumatology Practice Management December 2015 Vol 3 No 6 - OSHA Compliance
Karen Gregory, RN

Would the first impression a patient has of your practice send a safety message? You see, first impressions do count! The way your office appears will hopefully send the message of a well-organized, efficient, safety- centered practice.

As a challenge, the next time you enter your office, walk in the front door and visualize the space as a patient, potential new employee, or even an Occupational Safety and Health Administration (OSHA) inspector. Now, ask yourself the following questions:

  • Is the waiting area clean and organized?
  • Are there silk plants that have dust on them?
  • Is the carpet in good condition?
  • How old are the magazines?
  • Are the clinical areas filled with items that are not in use?
  • Are the counters free of clutter so the surface can be easily dis­infected?
  • Are sharps containers overfilled?
  • Is the sterilization area clean and well-organized?

Perhaps you can see where this is going, but there are some compliance basics that go along with the appearance and overall well-being of your physical location. When defining compliance, we look at it from 2 different perspectives—(1) employee safety, and (2) patient safety.

Implementing Employee Safety Standards

Employee safety standards are often referred to as OSHA standards. The following are some examples of safeguards that must be in place to ensure that employees are provided a safe work environment:

  • Training is essential for employees to understand the safety measures in place in their work environment. Annual training is a best practice, but blood-borne pathogen training is also required by law on an annual basis
  • Written plans on exposure control and hazardous communication must be available at all times to employees. Each employee should know where to locate the written plan, as well as where to locate safety data sheets for all of the chemicals with which they work
  • The appropriate documentation of hepatitis B vaccination or the declination of the vaccinations
  • Personal protective equipment must be provided by the employer at no cost to the employee. Employers must also provide laundering of reusable protective equipment, and employees should not take contaminated equipment home for cleaning
  • The availability and use of engineering controls are mandated by the Needlestick Safety and Prevention Act of 2001. Examples of engineering controls include sharps containers, safety scalpels, safety needles, and safety intravenous access devices
  • A written cleaning schedule outlining the surfaces to be disinfected, the frequency of disinfecting, and the product to be used. When walking through the practice, the following items should be checked as well:
  • Ground-fault circuit interrupter outlets in restrooms and outlets where there is the potential for the splashing or splattering of water
  • Clearance of ≥3 feet around the breaker box, and all breakers should have appropriate labeling
  • Visual checks on a monthly basis for fire extinguishers and annual maintenance by an outside source to ensure proper functioning if needed
  • Sharps containers are in the direct areas of use
  • When transporting contaminated reusable sharps, ensure that employees are placing the sharps in a container that is leak-proof on the sides and the bottom, is closable, and is labeled.

Implementing Patient Safety Standards

Patient safety is provided in part by following established standards for infection control. The Centers for Disease Control and Prevention has issued multiple guidelines to address specific areas, such as handwashing, disinfection, and sterilization. By following the established guidelines, the overall risk for acquiring infection through the delivery of patient care can be reduced. Each practice should have an infection control plan that is thoroughly implemented.

The key items to review in your practice include:

  • A clearly identified process for the cleaning of instruments that is focused on the reduction of the actual handling of soiled instruments (ie, the use of an ultrasonic cleaner instead of scrubbing by hand). The use of heavy-duty utility gloves during this process should be expected for all employees
  • The proper monitoring of the sterilization process, which includes the use of internal and external indicators in every package and performance of spore testing on a weekly basis for each sterilizer that is in use
  • Attention to the sterilization cycle focusing on appropriate loading of the unit and the removal of instrument packages at the end of the dry cycle. Packages should be dry when removed from the sterilizer. If packages are continually wet, there may be an issue with the appropriate use of the equipment, overloading of the chamber, or an issue with the drying element
  • Single-use devices must be discarded, not disinfected or sterilized, after use. Following the manufacturer’s directions is imperative from a risk-management perspective. Single-dose medications must be discarded after patient use, even if solution is remaining
  • Is handwashing a top priority for all personnel? Research has proved that this is a challenge in all healthcare environments, yet it is the one thing that will consistently reduce the likelihood of the spread of infection
  • Can you identify one person in the practice who is the point person for the oversight of the infection control program?

So, how did you do? If there are opportunities for improvement, start now to ensure that your practice reflects a strong culture of patient and employee safety.

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Last modified: February 19, 2016
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