Comprehensive Written OSHA Compliance Plans

GHS Hazard Communication Plan

The most frequently cited standard in the health care industry continues to be the Hazard Communication Standard. On March 20, 2012, the Obama administration announced long-awaited regulations to improve labels on hazardous chemicals and make them conform to international guidelines developed by the United Nations. The GHS, or Globally Harmonized Hazard Communication System, has been developed to provide a single, harmonized system to classify chemicals, labels and safety data sheets (SDSs) worldwide.

The written GHS Program will include all the mandated GHS changes which were approved by OSHA in March of 2012 and will include detailed descriptions of the new labeling requirements; a clear explanation of the pictograms; and definitions of the newly assigned hazard symbols.

A copy of the revised (2012) standard and a glossary of SDS terms will be included. Don’t forget, HCR can also assist you in conducting your mandated hazardous chemical inventory and develop a workable SDS management program. Our staff can procure your SDSs and organize them in a workable format for ease in retrieval and staff utilization.

Employee Emergency Action and Fire Prevention Plan

In order to comply with the Employee Emergency Action Standard, OSHA requires a formal, site-specific, written Emergency Action and Fire Prevention Plan which encompasses such matters as employee evacuation, means of egress, and fire prevention for all employers who have more than ten employees occupying one physical location. All plans are written to be easily understood by all employees so that in the event of an emergency, employees could instruct customers and visitors on evacuation procedures. HCR can also provide framed emergency evacuation diagrams utilizing computer graphics which will identify all approved exits, escape routes, and the location of all fire extinguishers and eye wash stations. 

The Employee Emergency Action Plan will include:

1. Procedures for reporting a fire or other emergency

2. Procedures for emergency evacuation, including type of evacuation and exit route assignments

3. Procedures to be followed by employees who remain to operate critical plant operations before they evacuate

4. Procedures to account for all employees after evacuation

5. Procedures to be followed by employees performing rescue or medical duties

6. The name or job title of every employee who may be contacted by employees who need more information about the plan or an explanation of their duties under the plan

The Employee Fire Safety Plan will include:

1. A list of all major fire hazards, proper handling and storage procedures for hazardous materials, potential ignition sources and their control, and the type of fire protection equipment necessary to control each major hazard

2. Procedures to control accumulations of flammable and combustible waste materials

3. Procedures for regular maintenance of safeguards installed on heat-producing equipment to prevent the accidental ignition of combustible materials

4. The name or job title of employees responsible for maintaining equipment to prevent or control sources of ignition or fires

5. The name or job title of employees responsible for the control of fuel source hazards

Respiratory Protection Plan including Procedures for Fit Testing

The standard requires employers to establish and maintain a respiratory protection program to protect their respirator-wearing employees. The HCR written Respiratory Protection Plan sets forth guidelines for establishing and implementing a Respiratory Protection Program (RPP) to support employees’ protection from possible exposures to workplace respiratory hazards. The selection of specific respirators is based on the most current National Institute of Occupational Safety and Health (NIOSH) certification or other applicable regulatory agency recommendations or mandates based on potential known hazards or during emergencies when hazards may not be known.

Certified Workplace Hazards Assessment

OSHA requires, in paragraph (d) of the Personal Protective Equipment (PPE) Standard (§29 CFR 1910.132), that the employer conduct and certify in writing a workplace “hazard assessment” to identify hazards in the workplace and then provide the necessary PPE to protect employees from those hazards. We can conduct a site-specific, certified facility-wide hazard evaluation and assign appropriate PPE for each hazard found separately or as part of the above regulatory compliance assessment.

Bloodborne Pathogens Exposure Control Plan

The standard requires an up-to-date, site-specific Exposure Control Plan (ECP) which encompasses such matters as exposure determination, program responsibility, exposure prevention, HbV, HcV and HIV post-exposure follow-up, methods of compliance and all the other regulated provisions of the Bloodborne Pathogens Standard. The written ECP’s include all of the new CDC protocols for HIV, Hepatitis C and Hepatitis B post-exposures and a comprehensive Hepatitis B immunization program, post exposure follow-up forms and documentation for Hepatitis B vaccination. HCR’s written program will also include a protocol for evaluating engineered sharps injury protection devices and newly developed technologies which may reduce or eliminate the potential for workplace exposures to contaminated sharps and all the forms necessary for non-managerial employee involvement for the required annual documentation.

Occupational Exposure to Mycobacterium Tuberculosis

HCR’s site-specific Exposure Control Plan for the Occupational Transmission of M. tuberculosis is designed to assist you in evaluating your employee’s potential occupational exposure to TB and provide a comprehensive plan to minimize and manage that potential exposure. The TBECP provides your employees with a working document to help them quickly identify patients who present themselves for treatment with symptoms consistent with TB. Our written plan contains a format for a mandatory skin testing program in compliance with the latest CDC recommendations and post exposure follow up including employee removal procedures. It should be noted this manual is not currently mandated by OSHA but should be a part of all Compliance Manuals in areas where the TB rate is above the national rate.

Occupational Exposure to Methicillin-Resistent Staphylococcus Aureus

HCR’s site-specific written Exposure Control Plan for Methicillin-Resistent Staphylococcus aureus is designed to assist you in evaluating your employee’s potential occupational exposure to MRSA and provide a comprehensive plan to minimize and manage that potential exposure. Our MRSAECP provides your employees with a working document to help them quickly identify patients who present themselves for treatment with symptoms consistent with MRSA. It should be noted this manual is not currently mandated by OSHA, but should be a part of all Compliance Manuals.

Comprehensive Written OSHA Compliance Manual

Healthcare Compliance Resources offers on-site consultation nationwide and we are fully capable and competent to provide a turnkey OSHA compliance program for any size medical practice or facility. Our written compliance programs are not “fill-in-the-blanks”, “canned” programs that OSHA is suspect of, but rather, “custom-fitted”, specialized documents designed for each individual healthcare practice. Because of this, we require on-site visits and consults prior to writing most compliance programs for a client. If you need assistance in writing any of the above mentioned programs, please let us know and we will be delighted to send you a separate formal proposal.

OUR WRITTEN PLAN GUARANTEE

If you decide to have HCR complete any written OSHA Program, rest assured that it will be hand delivered and the contents of the program manual will be explained and thoroughly discussed with your identified OSHA Coordinator. In addition, we will train your OSHA Coordinator on any OSHA area they feel uncomfortable about and we will not leave your facility until you are comfortable with your responsibilities.