No one wants to hear that the Occupational Safety and Health Administration (OSHA) is coming on-site for an inspection. These visits can be nerve-wracking and potentially disruptive as inspectors assess worker safety conditions and look for potential violations that could result in significant penalties or fines.
However, a healthcare organization can have a positive OSHA inspection experience if prepared for the encounter. With solid pre-work and a consistent commitment to OSHA compliance, your organization can come through the event stronger and safer.
Here are some strategies that can set you up for success.
Know What to Expect
OSHA does not typically provide advance notice that an inspection is imminent. Either way, an inspector may evaluate worker safety throughout your facility or zero in on specific areas, such as fit testing for N95 respirators or how your organization manages contaminated sharps waste.
During the visit, the inspector will engage in a variety of activities, including reviewing any OSHA-required document or paperwork, observing key processes, interviewing staff who work in affected areas, taking photographs, and obtaining air samples. Your staff should be prepared to supply the inspector with whatever materials they request. Failure to comply can have negative consequences.
What Safety Policies and Documents Should Be Available For an OSHA Inspection?
One of the most effective ways to prepare for an OSHA visit is to ensure your safety policies are up to date.
- What is a Bloodborne Pathogens Exposure Control Plan? An exposure control plan should describe the risks workers face from exposure to bloodborne pathogens. It should outline prevention strategies and response procedures in the event a worker comes in contact with blood or body fluids or contaminated waste.
- What is a Hazard Communication Program? This should include a master list of hazardous chemicals your facility uses and a description of how your organization informs staff about the dangers of these chemicals. Proper labeling is a key topic, including how labels comply with the Globally Harmonized System (GHS), an internationally agreed-upon set of labels for health, physical, and environmental hazards.
- What is a Respiratory Protection Program? This should describe how your organization protects workers against airborne contaminants and its use of N95 respirators. To be compliant, you must provide medical clearance for employees wearing an N95 whenever they are required, fit testing, as well as annual training.
- What are OSHA 300 Logs? These are records related to serious workplace-related employee injuries or illnesses.
- What are training records? OSHA requires thorough training on potential workplace hazards and how to reduce risk. You should have documentation that shows which staff completed training and when. It should also describe the nature of that training.
- What are Safety Data Sheets (SDSs)? An SDS communicates comprehensive information about a chemical, including any protective measures and safety precautions that should be followed when handling, storing or transporting the material. Staff should be able to easily and readily access an SDS that pertains to a hazardous chemical in their work environment.
Note that OSHA requires organizations to review some policies annually and document the review process, including the time and date of the review.
Make Sure Staff Are Prepared to Answer an Inspector’s Questions
Since an OSHA inspector may spend time observing and talking privately with individual staff about their work environment, it is important that employees are trained on OSHA requirements and feel prepared to provide clear answers to any questions.
Conduct Periodic Walk-Throughs
Regularly walk through your facilities to look for OSHA compliance issues and fix any identified shortfalls.
An Outside Expert Can Help
Ensuring OSHA readiness can be challenging, but the good news is that your organization does not have to tackle compliance on its own. By working with Stericycle, you can feel confident that your policies and training are comprehensive and current. Our online OSHA trainings are accessible 24/7 and are updated as required. Our OSHA Safety Plan Builder available through mystericycle.com provides detailed templates that you can use to create a range of required written plans and programs. We even have in-house experts that can facilitate on-site training and conduct mock OSHA inspections.
Learn more about how Stericycle can help strengthen your OSHA compliance efforts.