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OSHA Requirements for Private Medical and Dental Practices

Do we perform consultation requests for privately-owned medical and dental clinics? Absolutely.

Daniela Sloan, Ph.D.

Daniela Sloan, Ph.D.
Safety and Health Consultant

Typically, these requests are from clinics needing help with OSHA requirements.

The clinics generally fall into two categories: 1) established clinics that have been operational for some period of time and 2) new clinics that are in the process of opening their doors to patients. New clinics usually lack an OSHA-related safety plan, other than the OSHA poster hanging on the wall. And though established clinics have large safety plans and most or all of OSHA’s required programs, unfortunately these programs are more oriented towards patient-safety instead of employee-safety.

My experience with medical and dental clinics is that the common denominator is in their desire to learn and comply with OSHA requirements. So what can clinics do to become compliant?

In general, OSHA’s-mandated programs and standards applicable to medical and dental clinics include:

  • Bloodborne Pathogens –due to employee exposure to blood and body fluids
  • Hazard Communication –because of the presence of hazardous chemicals in the workplace

Note: There are a series of changes coming up due to the Global Harmonized System (GHS) requirements. These changes involve MSDS format, labeling and new pictograms on labels. The nearest milestone with regards to GHS is the training of all employees by December 1, 2013 about new GHS requirements.

  • Ionizing Radiation – only for facilities with an X-ray machine on-site
  • Personal Protective Equipment – tied to the previous 3 sections

Note: A hazard assessment of the facility needs to be conducted in order to select adequate PPE and a certification of this assessment needs to be signed and dated.

  • Emergency Action Plan – to provide safe exit routes for employees

Note: Facilities with 10 or fewer employees do not need a written plan; they can communicate the emergency action procedures and assembly location verbally.

  • Electrical – due to the variety of medical and lab equipment
  • OSHA poster –explaining workers’ rights and contact info for OSHA

Developing written safety programs for these areas is not only required but they must be facility-specific, meaning that even if a comprehensive template plan is printed (from a site like our own Safety Writer), the plan is not OSHA-compliant until it is site or facility-specific. If the clinic has multiple locations, each location must have its own safety programs. For example, if location A has X-ray machines but location B does not, a written ionizing radiation plan should not be found within the written safety plan for location B. To make the plans facility-specific, the clinic’s full and complete information must be within the plan, including name and contact info for the responsible for the plan, a diagram of the facility, evacuation site and location for employee assembly, plan review dates, etc. The plans have to be reviewed yearly and the date and name of the person conducting the review should be documented.

Exception: Medical and dental clinics are exempt from keeping the OSHA 300/300A/301 logs.

If your medical or dental facility—new or well-established—needs assistance with developing a site-specific written safety plan, visit www.usfsafetyflorida.com to access SafetyWriter. Thousands of small businesses throughout the country use this free service, which makes developing a customized safety plan easy and convenient.

If you would like information or assistance with how to become and maintain OSHA compliant, contact us to request a free and confidential on-site safety and health consultation. Our consultants are located throughout the state and have worked with numerous medical clinics. They will guide you into establishing a safety and health culture that protects not only your patients but your employees as well. That is peace of mind. For more information, visit www.usfsafetyflorida.com.