For most practices, three written safety plans are required in order to be in compliance with OSHA safety regulations: exposure control, hazard communication, and emergency action plans.
OSHA requires your plans be reviewed “periodically,” and updated when changes are made. For practical purposes, an annual review will do the trick. If you don’t already have a set schedule, the beginning of the year is a great time to review them; and look for items that need updating to maintain compliance.
As always, documenting the review is essential.
Following are the three required written plans, and related checklists of things that need to be reviewed or accomplished regularly.
Exposure Control Plan
If any personnel assigned certain tasks change, another person must be assigned the task.
Conduct a review of the exposure determination.
Conduct a review of the practice’s engineering controls, with a particular emphasis on new products that could mitigate sharps risks.
This is also a logical time to update your job hazard assessment.
Hazard Communication Plan
Again, if any personnel assigned certain tasks change, another person must be assigned the task.
Most important is ensuring the SDS sheets for any new products with identified hazards are placed in proper order in the SDS book.
SDS sheets for products no longer used should be removed, and placed in the “Retired SDS” book. SDS sheets should be kept for 30 years.
Your hazardous chemical inventory list must be updated.
Emergency Action Plan
Again, any changes in assigned personnel must be accounted for.
Changes in evacuation procedures, rally point, emergency facilities, and emergency contact numbers must be accounted for.
Ensure your evacuation map is current with regard to layout and design; locations of fire extinguishers, eyewash stations, first aid equipment, exits, etc.
Don’t Forget Staff Training.
Bloodborne Pathogens training—and any other safety training indicated as necessary by your job hazard assessment—needs to be completed annually.
At least the most recent three years of training records must be kept for every employee.
New employees must complete safety training BEFORE beginning to work in your practice (unless the employee can provide written documentation that he or she completed the necessary safety training called for in the job hazard assessment for his/her position). Recently, a North Texas practice was fined over $5,900. Approximately half the fine was levied because some of the practice’s employees had not received the proper safety training before they began work in the practice.