Regulations you need to know: OSHA (Part 2) (Proceedings)


Since most OSHA inspections are the result of an employee (or former employee) complaint or a reported injury or illness, very often the inspection will focus on a specific area of concern within the workplace. Just as medical professionals specialize, the inspector's expertise in occupational health or general safety rules will also play a role in what portions of a hospital safety program are evaluated.

Since most OSHA inspections are the result of an employee (or former employee) complaint or a reported injury or illness, very often the inspection will focus on a specific area of concern within the workplace. Just as medical professionals specialize, the inspector's expertise in occupational health or general safety rules will also play a role in what portions of a hospital safety program are evaluated. With that in mind, we'll discuss the elements of an entire hospital safety program. Remember, this is not an overnight project. There are few definitively right or wrong answers. The important objective is to document the policies and practices that are in effect now. Changes and revisions will come with time. When you have completed a section's policy statements and training materials, add it to the Hospital Safety Manual binder. This will demonstrate a comprehensive program.

Hazards for the Entire Staff

        Food and Beverages

The potential for illness from ingestion of pathogens or harmful chemicals is definitely present in most veterinary hospitals. Although some veterinarians jokingly imply that immunity only comes from exposure, OSHA takes eating and drinking in hazardous areas seriously. Several years ago, a veterinarian was fined for allowing employees to eat lunch on the treatment table. Although not specifically mentioned in OSHA standards, the treatment table is a potential contamination source. Consumption of food and beverages must be limited to areas free of toxic and biologically harmful substances.

This rule also applies to preparation of foods and beverages. Many hospitals have a staff coffee pot and utensil area co-located with the lab. Sometimes the cabinets above a coffee or food area will contain hazardous chemicals or supplies. This is generally an unacceptable situation.

Hospital refrigerators are another area of concern. Staff lunches, drinks, condiments and snacks must be stored in an area free from biological or chemical hazards. Vaccines, drugs and laboratory samples are all potential contamination sources. It is acceptable to store patient food in a refrigerator with human food.

General Housekeeping and Maintenance

OSHA requires all workplaces to be maintained in a manner free from physical and health hazards. Hospitals should continuously look for unsafe or hazardous conditions by implementing daily "walk-through" inspections.

        Fire & Emergencies

Prior planning for emergencies is essential to workplace safety. Pre-designated duties, routes of egress, notification procedures and personnel accountability are essential elements of an emergency action plan. Fire prevention plans must include a list of the major workplace fire hazards and control methods, the names or job titles of persons responsible for the maintenance of emergency equipment or fuel sources, housekeeping procedures to prevent fire emergencies, training of the staff in fire prevention and the scheduled maintenance of emergency equipment.

Emergency telephone numbers, including fire, police, ambulance (or Emergency Medical Service), and emergency maintenance personnel should be assembled and prominently displayed near each telephone. Don't assume that everyone knows to dial 9-1-1 for an emergency. Since a few seconds could make the difference in an emergency, write down clear instructions and a "script" for the person to read.

All workplaces must have appropriate fire extinguishers available. In general, most veterinary hospitals would be safe to have dry chemical type extinguishers, but check with your local fire marshal to be sure. Normally, the fire extinguishers must be placed strategically throughout the hospital, and less than 75 feet apart.

There must be a program to ensure that fire extinguishers are inspected annually by a qualified technician. A record of the inspection must be maintained. Monthly, a designated individual from the hospital must visually checked each extinguisher to ensure it still properly "charged," and that it hasn't been removed or damaged. This monthly check should be annotated on the reverse side of the inspection tag.

Emergency exits and egress (escape) routes must be identified, properly marked and maintained free from obstructions. If an exit is not clearly visible, the route to the nearest exit must be properly marked. Exit doors must not be locked or fastened in such a way as to prevent free escape from the inside of the building. Normally, this means that exit doors should open outward and be equipped with a push-type latching device ("panic bar"). In no circumstances should a deadbolt or lock requiring a key to exit from the inside be installed on an exit door.

For work areas that are located in basements or other "isolated" places, it is usually required to have two means of egress so arranged as to minimize the possibility that both may be blocked by a fire or other emergency. Exit doors must be marked with a sign bearing the word "EXIT" in plainly legible letters not less than 6 inches high and 3/4 inches wide. Where the direction of travel to reach the nearest exit is not immediately apparent, a sign reading "EXIT" with an arrow indicating the direction must be posted. Exits, signs and egress routes must not be decorated or "hidden" so as to detract from their visibility.

First Aid

Hospitals should make advance arrangements with the community hospital or physician for the treatment of emergencies. First-aid kits for humans are not mandated unless there is no hospital, infirmary or clinic in proximity to the workplace. Procedures to summon Emergency Medical Service (EMS) personnel in the event of a serious accident should be established, and emergency phone numbers should be posted near all telephones.


One of the most common (and most often overlooked) hazards in today's veterinary practice is electricity. In recent years, workplaces have been inundated with new labor-saving and service-enhancing technologies - most of which require electricity to operate.

Hazards from the equipment include electric shocks and maybe even physical trauma from moving parts, but the real danger comes when the buildings electrical service is not adequate to handle the demand. We improvise with extension cords, power taps, outlet multipliers and surge protectors! These things are usually OK for temporary applications such as a work light, saw or drill for a specific job, but they were not designed for constant use. Nobody sets out to intentionally overload electrical cords or outlets, but it happens. Over time we add "just one more" thing to the circuit until something becomes the proverbial straw that broke the camels back. Fortunately, these types of problems are easy to fix.


OSHA's concern for employee safety does not stop at the doors to the practice. According to a recent survey by OSHA, motor vehicle crashes are the leading cause of death for American workers. Because of this, there are many standards in effect that deal with the safety of practice vehicles and machinery.

     • First and foremost, make sure every employee who operates a vehicle while on duty has a valid driver's license in your state. Even if the employee uses his or her own vehicle, if the are on an "official" errand for the practice, then the practice is probably liable for any accidents they have - even before their own insurance carrier!

     • Ensure that all lights, signals, wipers and the horn works properly.

     • Make sure the tires are inflated to the proper pressure and have adequate tread remaining.

     • Check to be sure that both the regular and parking brakes operate normally.

     • If the operator's view to the rear is obstructed by the load or the vehicle design, then an audible (sound) back-up alarm must be installed.

     • Finally, make sure the vehicle's seat belts work properly and are in good repair. Make sure there is a hospital policy that requires the use of seat belts and compliance with posted speed limits!

     • Is there a tractor in use at your practice right now? If so, then you should be aware that OSHA has specific standards for these type of vehicles also. These rules are not unlike the ones for industrial forklifts or heavy construction equipment.

     • Make sure every person who operates the equipment has been properly trained to do it safely. They must know the functions of all the buttons, dials, lights, gauges and levers. As always, you should have a record of all employee training, and this is no exception.

     • The tractor must be equipped with a roll-over protective structure (ROPS) , even if it's used exclusively on level ground. More commonly known as a "roll bar" the ROPS is to protect the operator from being crushed by the tractor if it should roll over.

     • There must be an operable auto-type seat belt for the operator as well as a written hospital policy requiring its use.

     • As you could imagine, there is a requirement for operable brakes and brake lights.

     • If the operator's view to the rear is obstructed, then there must be an audible back-up alarm.


We have all heard the spectacular news stories of disgruntled former employees going on a shooting rampage in retaliation for whatever perceived injustice they have suffered. This is the image that we most associate with workplace violence. The truth is that most incidents of violence against workers doesn't make the news because it is more common than we like to believe. On the average, two American workers are assaulted, murdered or raped while on duty every minute of every day!

In any business, including that of a veterinary hospital, violence typically happens due to one of these four reasons:

     • Robbery or intentional assault (stalking);

     • Customers or clients under extreme duress who "lash out;"

     • Workers who have a dispute with supervisors, coworkers or just "the establishment;" and

     • Unhealthy personal relationships (jealous or estranged domestic partners).

As the veterinary profession adapts to meet the needs of a changing society, we are gradually increasing our risk of a violent act happening in the practice. Perhaps the greatest example of this is today's veterinary emergency clinic. The emergency clinic is open throughout the night and often in dangerous neighborhoods. They are typically staffed with a skeleton crew that is preoccupied with internal cases to be very aware of external threats.

But it's not just emergency clinics that are at risk. The traditional veterinary practice shares many of these same concerns. Although violence in the veterinary profession is not as common as in other industries or fields, it does happen. The accurate prediction and preventing of workplace violence is not exact, but already we see emerging trends. Perhaps the most promising news is that increased awareness and preparation seem to be the best prevention strategies.

Chemical Hazards

The Hazard Communication Standard (HCS) or "Right-to-Know Law" mandates that every business which handles, stores, or uses potentially dangerous chemicals develop a written plan for these procedures. These rules apply to all chemicals on the premises, regardless of whether they are currently used in the process or not. There are some exceptions:

     • "Any consumer defined in the Consumer Product Safety Act (15 USC 2051 et seq.)...where the employer can demonstrate it is used in the workplace in the same manner as normal consumer use...,"

     • "Any drug...when it is in solid final form for direct administration to the patient (i.e. tablets or pills),"

     • "Food, drugs, or cosmetics intended for personal consumption by employees while in the workplace."

     • "Any food or food product..."

     • "Articles...which do not release or otherwise result in exposure to, a hazardous chemical, under normal conditions of use."

     • Here are the basic rules:

     • Develop a Hazard Communication Plan including a list of all hazardous products;

     • Obtain a Material Safety Data Sheet from your distributor for those items on your list;

     • Ensure that all containers of hazardous materials, including secondary containers such as table wash bottles, are labeled with the chemical name and the appropriate warning; and

     • Train workers on the safety aspects of handling the chemicals.

     • Special Chemicals - Ethylene Oxide and Formaldehyde:

     • Designation of an appropriate location for storage and use of the agent.

     • An acceptable receptacle or device for performing the procedure. Rubber trash cans and thermal coolers are NOT acceptable.

     • Initial monitoring of exposure levels. This is accomplished with badges, similar to the ones used for radiation monitoring. Short term exposure limits (STEL) of 5 parts per million (ppm) and an 8 hour time weighted average (TWA) of 1 ppm are the maximum PELs in the workplace.

     • Detailed emergency procedures for accidents involving release of EtO or Formalin gas into the workplace (e.g., accidental breakage of an ampule, etc.) This includes emergency warning procedures, evacuation protocols and the availability of appropriate respirators for clean-up operations.

     • Appropriate employee training covering the provisions of the OSHA standard, the methods used for monitoring, the physical and health hazards of EtO or formaldehyde, measures for protection, and the details of the hospital's written hazard communication plan.


Just like any other program or procedure, a good hospital safety program doesn't have to be complicated. It should be practical and understandable. If the staff doesn't remember the rules, then training is lacking or the program is too complicated. Only by understanding the requirements and applying the safeguards that are necessary to protect the worker, patient and practice owner can the practice continue with the primary mission of healthy pets. It is the leadership's responsibility to set and enforce the safety rules of the practice and the employee's responsibility to learn and follow those rules.

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Adam Christman
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