Demystifying the Occupational Safety and Health Administration inspection process

Being prepared for an Occupational Safety and Health Administration (OSHA) inspection can save a facility money, as well as potentially protect employees from serious illness or injury. This article explains the OSHA inspection process, types of violations that may be cited and the appeals process for employers and employees. Actual citations given in four recent OSHA health care facility inspections are discussed and general recommendations to prepare for an OSHA site visit are given.

Safeguarding scientific evaluations by governmental agencies: case study of OSHA and the 1,3-butadiene classification

Using the example of the industry pressures on OSHA that preceded the Agency's downgrading the carcinogenic potential of butadiene from "human carcinogen" to "possibly carcinogenic to humans" in the face of scientific evidence, the author warns of the danger to public health of the infringement on governmental agencies' decision making by special-interest groups.

Organizational safety culture/climate and worker compliance with hazardous drug guidelines: lessons from the blood-borne pathogen experience

BACKGROUND

The health risks posed to health care workers (HCW) handling antineoplastic and other hazardous drugs (HDs) are well established. However, despite nearly 20 years of professional practice standards, compliance with safe handling procedures is poor.

METHOD

We present documentation of undercompliance with recommended safety procedures for HDs. Then, we examine a similar problem, HCW compliance with blood-borne pathogen universal precautions (UP) and its partial solution tied to the strength of a facility's safety culture. Lessons learned here may be applicable to the HD issue.

RESULTS

It is proposed that analyzing a facility's safety culture may enlarge our understanding of the barriers contributing to HD under-compliance and suggest strategies to improve it.

CONCLUSION

The Safety Culture paradigm offers many targets for intervention to enhance and promote worker compliance with safe HD handling practices thus mitigating internal exposure.

NFPA 70E: Performing the electrical flash hazard analysis

Arc flash hazards pose a serious risk to employee safety; proper safe work practices must be utilized. Electrical equipment > or = 50 volts must be deenergized and locked out/tagged out prior to servicing and maintenance unless doing so would increase hazards or is infeasible. Remember, convenience is not an acceptable reason for keeping equipment energized during servicing and maintenance. If electrical equipment must remain energized during Servicing and maintenance, NFPA 70E should be consulted to determine flash hazard boundaries as well as required PPE. Finally, circuit breakers and electrical disconnects must be marked to warn qualified employees of potential arc flash hazards.

Occupational medicine practice in the United States since the industrial revolution

OBJECTIVES

Occupational medicine lies at the interface between work and health. Not only do workplace hazards impact health, but our state of health influences our ability to get to work, to perform work, to tolerate work, and to gain a measure of satisfaction from the work we do. Comprehensive occupational medicine requires familiarity with the work that patients do; knowledge of the workplace itself and its hazards; appreciation of the social forces that shape work; and understanding of how chemical, physical, biologic, mechanical, and psychosocial agents influence health. Many practitioners who treat injured workers or provide disability assessments have no more formal training in occupational medicine than primary care physicians in general, which limits the quality, or at least the scope, of the care they give to workers.

METHODS

This history has been compiled from books, journals, letters and recollections. A subset of journal issues from each decade after 1910 has been systematically reviewed, making no attempt to read through every issue.

RESULTS

Industrial medicine as we recognize it began in the late-1800s, grew rapidly in the early and mid-1900s, and peaked toward the end of the 20th century, when American corporations began to outsource medical services, supporting the rise of free-standing industrial medicine facilities, chains of which now operate profitably throughout the country. Many of these facilities emphasize injury treatment, work hardening, and physical therapy rather than disease recognition and prevention. Occupational medicine is one of the very few medical specialties to be underserved. Board-certified specialists are relatively few, and when supply falls short of demand, the demand has tended to lower its sights.

CONCLUSIONS

Occupational medicine has always been influenced by economics, politics, and changing patterns of employment, and today these forces include managed care, weakened unions, outsourcing and contract labor, and a generally growing political and social conservatism, not to mention multinational corporations. The globalization of manufacture and economics facilitated by rapid population growth in poor nations assures an unending supply of cheap labor, allowing limited attention to hazard control, thereby impeding progress in occupational health and safety. Some corporations are meeting the challenge of protecting their international workforce. Many, probably most, have not yet achieved this.

OSHA--what is its role in dentistry and how do we provide training?

The mission of the Occupational Safety and Health Administration (OSHA) is to ensure the safety and health of America's workers. Although OSHA's focus is on safety, there is a natural overlap into the infection control arena. The work practice control, engineering control, and personal protective equipment regulations are examples of OSHA safety topics that have a direct impact on dental infection control. In a similar fashion, the regulations designed to protect the dental health care worker often translate into increased safety for the dental patient. To ensure their safety, OSHA requires workers to be appropriately trained. This article reviews the regulatory significance of OSHA, compares OSHA with other regulatory and advisory agencies, and discusses OSHA's training requirements. Principles for conducting training in the dental health care setting along with suggestions for assessing training also are presented.

Staying in compliance with the Bloodborne Pathogens Standard

Safety and health programs must be annually reviewed and followed. This article provides a systematic review of each component of the Bloodborne Pathogens Standard and suggestions on how to incorporate the information into staff training and routine practice.

Standards Improvement Project-Phase II. Final rule

The Occupational Safety and Health Administration (OSHA) through this final rule is continuing to remove and revise provisions of its standards that are outdated, duplicative, unnecessary, or inconsistent, or can be clarified or simplified by being written in plain language. The Agency completed Phase I of the Standards Improvement Project in June 1998. In this Phase II of the Standards Improvement Project, OSHA is again revising or removing a number of health provisions in its standards for general industry, shipyard employment, and construction. The Agency believes that the changes streamline and make more consistent the regulatory requirements in OSHA health and safety standards. In some cases, OSHA has made substantive revisions to requirements because they are outdated, duplicative, unnecessary, or inconsistent with more recently promulgated health standards. The Agency believes these revisions will reduce regulatory requirements for employers without reducing employee protection.

Make room for more sterile environments

Infection control measures for 2005 clarify existing guidelines.

Finding the right approach. What do you mean, this is a non-permit required confined space?

While not a big fan of the non-permit confined space designation, I have come to believe the approach can work if done properly. However, it is this author's opinion that the designation of a confined space as non-permit required in any work environment should be the exception rather than the rule. The up-front determination that a space is "non-permit-required" should necessarily consume more time and resources than assuming the space is "permit-required" because so fewer controls are in place. Most certainly, this decision must be based on the knowledge that no hazards are present or have the potential to develop, rather than on "convenience" or "resource limitations"; assumptions should never play a part in the decision. Attention to proper evaluation of confined spaces, documentation of actual conditions over time, and communication to those entering the spaces are all critical components of a safe confined space entry program, whether the space be permit-required or not.