Practice Management: Safety First

Creating a culture of safety requires more than by the book adherence to OSHA standards— and pays dividends in employee satisfaction and patient outcomes.
MedEsthetics September 2016

Medical practices place significant emphasis on patient safety and outcomes. But without equal attention to employee safety, patient care can suffer. Low morale, staffing shortages due to injury and the potential for costly fines are just some of the ways a lack of attention to workplace safety can undermine your aesthetic business. Following is an overview of the workplace safety regulatory requirements for medical practices as well as steps you can take to create a culture of safety in your facility.

The Letter of the Law

When people think of workplace safety, OSHA often comes to mind. The Occupational Safety and Health Act of 1970 (OSHA) established standards for all U.S. businesses—including unique regulations for healthcare providers.

OSHA standards dictate that all general industry businesses (which includes healthcare) must follow the “General Duty Clause” that states that each employer will furnish each of his employees a place of employment free from recognized hazards that could cause physical harm or death. Some of the key risks that must be mitigated include non-ergonomic equipment or practices, workplace violence and communicable disease.

OSHA requires employers to provide an OSHA compliance manual to all employees as well as ongoing staff training, notes Christopher E. Poole, MBA, an associate of Medical Management Associates. For healthcare facilities, the manual must include an Exposure Control Plan (ECP), including Blood Borne Pathogens (BBP); Hazard Communication (HAZCOM) on hazardous chemicals used or stored in the facility; as well as a Tuberculosis (TB) policy that sets forth guidelines to prevent unreasonable exposure. In addition, employers must keep records of workplace injuries and illnesses.

“Failure to maintain OSHA compliance, either willingly or unwillingly, can result in violations, fines, and even jail time depending on the breach,” says Poole. “The manual covers examples of safety and health compliance and regulatory requirements that should be reviewed and implemented. New employees must undergo OSHA compliance training within 10 days of hire and annually after that. Businesses need to document the training sessions and retain those records for five years.”

Healthcare facilities also have a personal protective equipment (PPE) requirement. “The employer is required to evaluate the workplace and its processes to determine what type of personal protective equipment is needed to protect employees,” says Keith Brown, safety and health consultant at the University of South Florida, SafetyFlorida Consultation Program. These may include eye protection for laser treatments and face masks to prevent exposure to bloodborne pathogens.

BBP regulations also require establishing and maintaining a needle-stick (or sharps) log, in addition to Illness and Injury reporting logs. “If anyone is stuck with a contaminated needle, that incident would need to be tracked through the sharps log,” says Brown.

Medical practices must also adhere to physical facility standards. These cover safety concerns such as egress (proper number of exits), fire suppression equipment and carbon monoxide detectors.

What if you lease the facility? Still, the practice owner “is responsible for the safety of personnel under the General Duty Clause,” says Marc A. Bianco, COO/EVP of technical services at United Alliance Services, a company that provides OSHA and workplace safety consulting and training. “So whether or not you own the building, if you are aware of a hazard in the building and don’t take action, you could be cited by OSHA.”

In the event that OSHA does make a call on your practice, be prepared and be informed. “Other than in cases of imminent danger and fatal accidents, inspections are most commonly triggered by employee complaints,” says Poole. If your practice is inspected, he encourages owners to be cooperative and friendly, but do not hesitate to ask questions.

“If the inspection is due to a complaint, the OSHA officer must read the complaint before a walk-through of the facility,” says Poole. “Although the officers can go anywhere they like in the practice and can interview employees, the practice should only show them the area(s) that relate to the complaint. Do not volunteer any information. A closing conference will be conducted to discuss findings and propose steps to remedy the situation.”

Businesses typically have the opportunity—particularly on the first offense—to take corrective action if a violation is found. If corrective action is not taken, penalties can increase significantly.

Intersection of Patient and Worker Safety

OSHA requirements are often viewed as pertaining primarily to manufacturing facilities and construction sites, because these jobs are perceived as high risk. This changed for many in the healthcare field when 2007-2009 statistics from OSHA, the Centers for Disease Control and Prevention, and the Institutes of Medicine revealed that healthcare workers experience some of the highest rates of nonfatal occupational illness and injury—exceeding those in the construction and manufacturing industries.

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