Education is key part of OSHA regulations
[This is the first part of a multi-part series on compliance with the Occupational Safety and Health Administration (OSHA). In this month’s issue, we focus on education and training. In future issues, we’ll discuss sharps safety, personal protective equipment (PPE), employee safety, and hazardous materials, plus more.]
While the Occupational and Safety Administration (OSHA) and other agencies have multiple regulations for ambulatory surgery providers, regulatory compliance isn’t the only reason to know these regulations, said Beverly Kirchner, BSN, RN, CNOR, CASC, president of Genesee Associates, a Dallas-based national ambulatory surgery center development, consulting, and management company.
“If we don’t keep our staffs safe, we can’t keep our patients safe,” she said. Kirchner spoke at the recent annual meeting of the Ambulatory Surgery Center Association (ASCA).
Keep in mind that if an employee falls out of compliance with an OSHA regulation, the employer generally pays the fine, but if a contract employee breaks the rule, the employee will be fined. If you have a physician who, for example, puts his coffee cup on his anesthesia cart every morning, and he has been educated and the education has been documented, “you have to show they’ve been educated and oriented, or you are subject for the fine,” Kirchner said. Fines can be thousands of dollars, even for small infractions, she says.
One of the key elements to a successful safety program is employee participation, Kirchner said. “Who better to point out hazards in your facility than employees who work there?” she said.
When the OSHA survey begins, notify the medical director immediately, Kirchner said. Also, the chairman of your board should be on “standby,” she said. Prepare for the survey to last 6-8 hours.
Any employee, including physicians and allied health staff, should be prepared to name the person responsible for safety and health, she said.
Keep in mind that most OSHA surveyors work in industry, not healthcare, Kirchner pointed out. For that reason, when you’re asked a question, “Clarify what they’re really asking you” before you respond, she suggested. Pull requested data, but “don’t give them anything more than what they ask for,” she said.
OSHA makes it the employers’ responsibility to ensure all employees’ job assignments are appropriate to the skills and education level of the employee, Kirchner said. Employers are responsible for ensure the employees are certified, competent, or qualified for the job the employee is assigned to perform, she said. “So when you write job descriptions and do education and set up jobs, in the job description give the exact level of education that job requires and the skill sets,” Kirchner said.
In general, a multi-specialty facility will need more training than a single-specialty surgery center, she says. Also, members of the business office don’t need the same training as the clinical staff, she said.
The person creating the education and conducting the training should have undergone training himself or herself, Kirchner said. Document that their training goes above and beyond other staff, she said.
Set up your training so there are no interruptions, Kirchner said. Also, OSHA will want to examine how you evaluate your training each year, she said. Develop objectives for each training class, and have staff members evaluate whether you met those objectives and how you could better meet them, Kirchner said.
OSHA surveyors look at job descriptions and education to see if they match what employees are doing, Kirchner said. When you’re developing goals and objectives for each year, include hazards. For example, recovery and preop nurses might think they can drink in those areas if they have covered containers. “Whether OSHA accepts that depends on whom you talk to,” Kirchner said. When a patient coughs, the spray may land on the lid and be ingested by the staff person, she pointed out. “They will fine you, in the preop and postop areas,” she said.
Include education on the dangers of formalin, Kirchner suggested. “I have walked in and seen them storing that by an autoclave,” she said.
Surveyors will ask physicians and allied health staff about fire safety and other areas, she said, so they need “mini-orientations.” They should include the fire plan, evacuation plan, and disaster planning.
Review your safety plan with staff at least annually and any time you make changes, Kirchner said. [For a copy of Kirchner’s OSHA Compliance Checklist, see the online issue of SDS. If you need assistance, contact customer service at [email protected] or (800) 688-2421.]
Resource
Occupational Safety and Health Administration’s Injury and Illness Prevention Programs White Paper — January 2012. Web:
This is the first part of a multi-part series on compliance with the Occupational Safety and Health Administration (OSHA). In this months issue, we focus on education and training. In future issues, well discuss sharps safety, personal protective equipment (PPE), employee safety, and hazardous materials, plus more.You have reached your article limit for the month. Subscribe now to access this article plus other member-only content.
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