The ABCs of Your Written OSHA Program - Employee Safety - DoctorsManagement The ABCs of Your Written OSHA Program - Employee Safety - DoctorsManagement


Implementing a written OSHA program is not rocket science. However, as a healthcare facility, your OSHA Safety Program has quite a few caveats compared to other, non-medical businesses.

What are the basics, or “ABCs,” of a written OSHA program for a medical practice? Let’s examine them.

A = Available to All Employees at All Times

Your OSHA program manual must be available to all practice employees at all times. For example, it can’t be locked in the manager’s office if the manager is away on vacation while employees are present. Employees must have access at all times. Your OSHA manual can, however, be available electronically on a computer drive to which every employee has access. It is wise to keep a paper backup in the event of a computer failure.

B = Based on Your Specific Situation

A written program for your medical facility must be based upon what is present in your workplace. If your practice performs x-rays, your manual must have a section on safety procedures to limit employee radiation exposure. If your practice does not perform x-rays and you purchase an off-the-shelf manual, be sure to remove the x-ray section from the manual.

Every medical practice is different and the exposure you and your employees face will vary and even change over time as you add new services. As your practice grows and changes, you must update your OSHA manual to reflect any additional hazards that present themselves as a result of new services or facilities you have added to your practice.

C = Coverage of All Required Topics

What topics does your practice’s OSHA written program need to cover?

As a medical practice, your OSHA manual must cover the following topics as they apply to your practice’s specific situation.
Bloodborne Pathogens
Exposure Determinations
Category 1 (all employees are at risk)
Category 2 (risk based on employee’s actual job function rather than their qualifications)
Category 3 (a category DM uses to help employees who are not at risk understand where they fit into the OSHA program)
Walking and working surfaces
Fire and electrical hazards
Emergency action
Potential terrorism
Workplace violence
Note that if you are in one of the 26 states or territories (see list below) that has its own OSHA program, you want to have that information included.

The following states have OSHA programs: AK, AZ, CA, CT, HI, IN, IA, KY, MD, MI, MN, NV, NC, NJ, NM, NY, OR, PR, SC, TN, UT, VA, VI, VT, WA, WY

If you have questions about this topic or any other issues around the business of medicine, contact us via email or call us at 800-635-4040.