6 steps to creating an OSHA compliance program
Does your veterinary practice have a systematic approach to meeting OSHA guidelines, or do you have a stack of notebooks full of outdated information? If it's the latter, perhaps it's time to shape up.
Some practice owners believe that implementing an OSHA compliance plan is too complicated to even attempt. If you count yourself among them, consider hiring a consultant to do it for you. But be prepared to write a big check—most practices should budget about $4,000 to cover the cost of the program.
If you'd rather do it yourself, you need a plan. Here's one that will keep you and your team members safe—and keep regulators off your back.Step 1: Learn the requirements. You can find copies of every OSHA standard, directive, and interpretation at http://osha.gov. You can also purchase the same material from the U.S. Government Printing Office (866-512-1800) on CD-ROM or in print.
If you want the information condensed down for you, consider purchasing a veterinary-specific compliance kit or newsletter subscriptions. These tools will translate the material into terms average practice owners can understand and implement. Keep in mind that these kits are simply an interpretation of the rules—OSHA doesn't approve or certify any person or publication in this regard.
Step 2: Make an implementation plan. Once you have a basic idea of what's expected, write a list of changes or procedures that need attention—this is called an implementation plan. Concentrate on one subject at a time as you work through the plan. It's OK to make adjustments and rearrange the order of events on the plan when the need arises.
Even if you're not finished with the implementation plan before your practice is inspected by OSHA, having a written plan will often be a critical factor that the organization uses to determine whether you showed intent and progress.
Step 3: Create a hospital safety manual. By compiling all of your practice's safety-related information into one resource, you're creating a comprehensive program instead of a disorganized one. Use a three-ring binder and conspicuously label it "Hospital Safety Manual." Use tabbed dividers to create sections for easy reference (head to http://dvm360.com/safetymanual for a detailed list of what your manual should include).
By including your practice's written directions on team safety in the manual, you set official policies of the practice that are enforceable by management. In addition to these directions, consider including extracts of journal articles and related educational materials to reinforce the importance of safety in your practice.
Keep the manual in a convenient location, be it the break room, treatment area, or lab. Make sure every team member knows where the manual is located and that they should review it periodically.
Step 4: Address one hazard at a time. Start with the most hazardous jobs in your practice and establish a procedure for each. The plan must be in writing and detail how team members should perform these jobs.
Pay particular attention to safety equipment. For example, if radiation gloves are ill-sized for your team members, they'll be less likely to use them. In this case, OSHA would probably cite your practice for a lack of appropriate protective devices.
Step 5: Train your team. Once you've developed your plan, it's time to train your staff on the new or revised procedures. Set aside some time on a regular basis for team members to review information relevant to their jobs. Ensure that team members understand your expectations, then enforce the plan. You may hear some grumbling at first, but as soon as the new method becomes a habit, team members will adjust.
Step 6: Reevaluate and adjust. Nothing ever works out exactly as you've planned, so be flexible and don't be afraid to make changes as needed.
Developing a comprehensive OSHA program may seem like an overwhelming task, but but taking it one step at a time will make your life easier. Yes, it's time-consuming, but it's also worthwhile—after all, your team's safety is on the line.