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How do I get my OSHA program started?

It has been said that the greatest obstacle to achievement is getting started. That’s especially true when it comes to subjects like OSHA compliance. It would be hard to believe that any hospital owner or manager would not want to have their practice in compliance with the rules; however, many believe this is so complicated a task that they don’t even try. So for those of you who have just been assigned the task of getting your practice’s program in place and for those who have just put it off until now, we offer these suggestions for getting started.

1. Decide if you want to do it yourself or you want to hire someone to do it for you.

Many practice owners and administrators believe the best way to come into compliance with OSHA rules is to hire a professional to do it for them. Many consultants specialize in this service and by far, it’s the easiest way to go. Prices start at about $2,400.00 depending on the company and the extent of the program. This fee usually does not cover travel expenses for the consultant.  Most practices should budget about $3500 to cover the cost of the program and the expenses involved.

If you choose this route, remember it’s buyer beware! Make sure you understand exactly what you get for your money. Some companies only specialize in the requirements for hazardous chemicals or medical waste, while others will customize their services to what you want or need. Check out these suggestions for some guidelines to use when evaluating prospective consultants.

2. Learn the requirements.

Regardless of whether you want to implement the plan yourself or hire someone to do it for you, you should have a working knowledge of the requirements. Actual copies of every OSHA standard, directive or interpretation can be found on OSHA’s web site at www.osha.gov. The same material is available for purchase from the US Government Printing Office (202/512-1800) on CD-ROM and in printed form.

A better solution for most practices is to purchase a veterinary-specific compliance kit or newsletter subscription. These tools will "decipher" the regulations into terms and procedures the average practice can understand and implement. Subscriptions run about $35 and the compliance manuals range in price from around $75 to well over $300.

Remember, these compliance kits are simply an interpretation of the rules by the author. OSHA does not "approve" or "certify" any person or publication in this regard. (Check out our newest veterinary-specific compliance manual!)

3. Make an implementation plan

Once you have a basic idea about what is expected, take the time to write out a list of changes or procedures that need attention - this is called an implementation plan. Concentrate on one subject at a time and work your way through the plan. It’s OK to make adjustments and even rearrange the order of events on the plan when the need arises. Even if you are not completely finished with the implementation plan before you are inspected by OSHA, having a written plan will often be the critical factor that OSHA uses to determine whether you showed intent and progress toward compliance with the rules or whether you did nothing!

4. Create a Hospital Safety Manual

The best way to organize a hospital safety program is to put it all in one place. By compiling all of the safety-related information in the practice into one resource, it gives the impression of a comprehensive program instead of a "hit-or-miss" one. Use a three ring binder conspicuously labeled "Hospital Safety Manual." Use tabbed dividers to create sections like General Rules, Fire Prevention & Response, Anesthesia, Radiation, Accident Prevention, Infection Control, Chemicals and Violence Prevention. Of course, you can add others when the situation warrants.

Since the HSM is the primary means of communication on safety matters between the leadership and the staff, make sure that you only include things that directly instruct or educate the employee. Don’t "clutter" the manual by including compliance instructions and similar materials designed for the manager. By including the hospital’s written directions on staff safety in the HSM, they become the official policies of the practice and as such are enforced by the leadership. You can also include extracts of journal articles and related "educational materials" to further inform the staff on particular hazards and to reinforce the practice’s safety policies.

Keep the HSM in a convenient location - usually in a "neutral" area like the break room, treatment area or lab. Avoid keeping it in the doctor’s or manager’s office because there may be some "situational intimidation" that would prevent a new or concerned worker from reviewing it. Make sure every staff member knows where the HSM is located and that they have a right to review it whenever necessary.

5. Take it one step at a time.

Start with the most hazardous jobs and establish a procedure that must be followed when exposure to the hazard can occur. The plan should always be in writing and reflect what is actually done. It does no good to have the perfect plan but nobody does it that way! Ensure the staff has been trained on the expectations and ENFORCE the plan. You may get some grumbling from a few staff members at first, but as soon as the new method becomes a habit, they will usually accept it.

When developing any plan, pay particular attention to the safety equipment that is required. Make sure that your equipment is appropriate for protecting the user and that it fits properly. A great example is the radiation protection gloves in most practices. Although they may be appropriate for the radiation present, if the staff members can’t use them because they are too big, too small or simply not flexible enough, they are not considered adequate.

6. Train - Train - Train.

Once you have researched the issue, evaluated your procedures and come up with a written plan, the only thing thatís left is to train the staff on the new or revised procedures. Setting up an effective training program doesn't have to be complicated or expensive. Simply set aside some time on a regular basis for the staff to review information relevant to their jobs and make sure it happens. Click here for some tips  on effective staff training programs.

7. Reevaluate and adjust.

Don’t be afraid to make changes. Nothing ever works out exactly as planned and you must be flexible. Ask the staff for input during the development phase; you may find that they have concerns you never realized. As you implement the various components of the plan, you'll learn ways get your message through easier. Don’t be afraid to try new ideas or methods; if they work you’re finished, if they don’t then you've learned what not to do next time!

Although it seems like implementing a safety program at the hospital is a overwhelming task, breaking it down into stages certainly makes it easier and more understandable. Just don’t lose sight of the objectives because it takes a little longer than you expect.

 

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The information on these pages is excerpted from
The Complete Veterinary Practice Regulatory Compliance Manual (5th Edition)
Copyright 2003 Philip J. Seibert, Jr., CVT  All Rights Reserved
No part of this publication may be reproduced for distribution without prior permission from the publisher.

 

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This page was last updated on 01/24/14.

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