OSHA For Healthcare
29 USC 651-678
Occupational Safety and Health Act of
1970
Provides the authority for the US Department
of Labor to develop and enforce standards
regarding the health and safety of the
workplace.
OSHA “General Duty Clause”
29 USC 654
SEC. 5. DUTIES
(a) Each employer –
(1)shall furnish to each of his employees employment and a place of
employment which are free from recognized hazards that are causing or
are likely to cause death or serious physical harm to his employees;
(2)shall comply with occupational safety and health standards
promulgated under this Act.
“General Duty Clause”
(b)Each employee shall comply with occupational safety and health
standards and all rules, regulations, and orders issued pursuant to this Act
which are applicable to his own actions and conduct.
OSHA Regulations
Regulations are located in Title 29 of the Code of
Federal Regulations (29 CFR)
Some key regulations in 29 CRF are:
 29 CFR 1903 – Inspections, Posting Requirements,
and Citations
 29 CFR 1904 – Recordkeeping and Reporting
 29 CFR 1910 – General Industry
 29 CFR 1926 - Construction
OSHA Posting Requirements
Required Postings
 Information about OSHA and basic
employee rights under the act.
–

A poster is available for the
Department of Labor for this purpose.
An annual summary of
occupational illness and injuries
from the previous year
OSHA Recordkeeping
Each establishment must maintain records of
occupational injuries and illnesses. TOP
Required Forms:
OSHA 300 – Annual log and summary
OSHA 300A – Calendar year summary
Must be posted from February 1 until April 30
OSHA 301 – Additional details on the injuries
recorded on the OSHA 300 log
OSHA Recordkeeping
The length of time records must be maintained
varies.
 The OSHA “300” records must be maintained for a
five year period.
 Other records may have to be maintained for much
longer periods of time.
–
i.e. Employee exposure records must be maintained for the
length of employment plus 30 years
OSHA Recordability
Injuries must be evaluated to determine whether or not
they are recordable under the OSHA regulations.
Worker’s Compensation Injuries and OSHA
recordability do not always align so be sure to evaluate
every injury to be sure it is properly classified.
OSHA Injury Reporting
Certain injuries require direct reporting to OSHA and
The Rules are changing!
Starting January 1, 2015
 An employer is required to report a fatality, inpatient hospitalization, amputation, or loss of an eye
if the event is reported to employer or employer’s
agent(s).
OSHA Injury Reporting


Employers are required to report a fatality within 8
hours of the death, for all fatalities occurring within
30 days of the incident.
Employers are required to report each in-patient
hospitalization within 24 hours of the
hospitalization, for all hospitalizations occurring
within 24 hours of the work-related incident.
OSHA Injury Reporting


Employers required to report each amputation
within 24 hours of the amputation, for all
amputations occurring within 24 hours of the workrelated incident.
Employers required to report each loss of an eye
within 24 hours of the loss of an eye, for all losses
of an eye occurring within 24 hours of the workrelated incident.
OSHA 29 CFR 1910 Overview
29 CFR contains numerous subparts which have
specific requirements for reducing risk to workers.
Many of these regulations have application in the
healthcare setting.
Note: 29 CFR 1926 contains regulations related to
construction which may apply during renovation and
construction at healthcare facilities.
OSHA 29 CFR 1910 Subpart Z
Toxic and Hazardous Substances
1910.1200 - Hazard Communication TOP
Recently updated to incorporate the
Globally Harmonized System
– Formal hazard communication plan
– Inventory of hazardous chemicals
– Ensure training, labeling, and SDS maintenance
– Training at the time of initial assignment, when a
new hazard is introduced into the worksite, and
when transferred to a new department
OSHA 29 CFR 1910 Subpart Z
Toxic and Hazardous Substances
1910.1030 - Bloodborne pathogens. TOP
–
–
–
–
–
Formal Exposure control plan
Categorize exposure potential
Hepatitis B Vaccine
Engineering controls
PPE
OSHA eTool:
https://www.osha.gov/SLTC/etools/hospital/hazards/bbp/bbp.ht
ml
OSHA 29 CFR 1910 Subpart Z
Toxic and Hazardous Substances
1910.1001 - Asbestos.
– Asbestos-containing materials (ACM) are materials that
contain at least 1% asbestos
– All construction projects performed where asbestos may
be disturbed should be monitored
– Building owner must determine the presence, amount,
location, and type of asbestos in the facility, and can be
held accountable for subcontractor activities
OSHA 29 CFR 1910 Subpart Z
Toxic and Hazardous Substances
1910.1025 – Lead
– Buildings constructed prior to 1980 may have lead in the
paint or pipes. Radiology and nuclear medicine areas
also have lead present.
– Develop a proactive lead management program.
OSHA 29 CFR 1910 Subpart Z
Toxic and Hazardous Substances
1910.1047 - Ethylene oxide.
– Assess all areas where EtO may be used and determine
potential for exposure. This usually means air sampling.
– Use engineering controls and work practices to eliminate
or reduce employee exposure at or below the permissible
exposure limits (PEL)
– Medical surveillance program
OSHA 29 CFR 1910 Subpart Z
Toxic and Hazardous Substances
1910.1048 - Formaldehyde.
– Determine potential exposure in areas where chemicals
containing 0.1% or greater formaldehyde are used.
– Conduct exposure monitoring
– Engineering and workplace controls should be
maintained to keep employee exposure as low as
possible.
– An eyewash unit and drench shower shall be provide
where formaldehyde is used
OSHA 29 CFR 1910 Subpart Z
Toxic and Hazardous Substances
1910.1052 - Methylene Chloride.
1910.1096 - Ionizing Radiation
1910.1450 - Occupational Exposure To Hazardous
Chemicals In Laboratories
Chemical Hygiene Plan
Pharmacy eTool
OSHA 29 CFR 1910 Subpart Z
Toxic and Hazardous Substances
Other chemicals that may need to be considered:
–
Xylene (PEL=100ppm, TLV=100ppm)
–
Glutaraldehyde (PEL=N/A, TLV=0.05ppm ceiling)
–
OPA (o-phthalaldehyde) may pose similar occupational hazards to
those of glutaraldehyde
–
Anesthetic Gases
OSHA 29 CFR 1910 Subpart Z
Toxic and Hazardous Substances
Other chemicals that may need to be considered:
–
Methyl Methacrylate (PEL=100ppm, TLV=50ppm)
–
Mercury (PEL=0.1 mg/m3, TLV=0.025 mg/m3)
–
Hazardous Drugs: See OSHA Technical Manual Section VI:
Chapter 2 regarding a Hazardous Drug Safety and Health Plan
OSHA 29 CFR 1910 Subpart K
Medical and First Aid
1910.151 Medical Services And First Aid. TOP
"Where the eyes or body of any person may be exposed to
injurious corrosive materials, suitable facilities for quick
drenching or flushing of the eyes and body shall be provided
within the work area for immediate emergency use.“
–
–
Proper installation
Maintenance
OSHA 29 CFR 1910 Subpart I
Personal Protective Equipment TOP
1910.134 - Respiratory Protection.
– Formal Respiratory Protection Program
– Must include procedures for selection and use, medical
evaluation, fit testing, use, cleaning, training.
– Medical evaluation
– Fit testing
– The respiratory protection program should be evaluated
as often as necessary to ensure effectiveness
OSHA 29 CFR 1910 Subpart I
Personal Protective Equipment
1910.133 - Eye and face protection
1910.136 - Foot protection.
1910.137 - Electrical protective devices
1910.138 - Hand Protection
OSHA 29 CFR 1910 Subpart G
Occupational noise exposure.

1910.95 - Occupational Noise Exposure.
–
–
If noise exposures are 85dBA for an eight hour time
weighted average this standard applies. This may
occur in certain mechanical areas or during lawn
care. Some clinical areas may approach these levels
as well.
Hearing Conservation Program
Audiometric testing
Noise control
OSHA 29 CFR 1910 Subpart J
General Environmental Controls
1910.146 - Permit-required Confined Spaces

Confined Space
– Large enough and so configured so that an employee can
enter and perform work.
– Has limited or restricted means of entry or exit.
– Is not designed for continuous occupancy.
OSHA 29 CFR 1910 Subpart J
General Environmental Controls

Permit Required Confined Space
– Hazardous atmosphere (or potential to contain a
hazardous atmosphere)
– Contains a material that may engulf an entrant
– Has an internal configuration such that an entrant may
become trapped by inwardly converging walls or a floor
that slopes downward and tapers to a smaller crosssection.
– Any other recognized serious safety or health hazard
(e.g., electrical).
OSHA 29 CFR 1910 Subpart J
General Environmental Controls
1910.147 - The control of hazardous energy (lockout/tagout)
– Establish a formal program servicing or maintenance on
machinery or equipment where the unexpected
energizing, startup or release of stored energy could
occur and cause injury
– Lockout and tagout devices shall be provided by the
employer for isolating, securing, or blocking of machines
or equipment from energy sources
OSHA 29 CFR 1910 Subpart N
Materials Handling and Storage
1910.183 – Helicopters
1910.178 - Powered Industrial Trucks
– Formal program must be established for training and
permitting operators
– Classroom and practical training must be provided.
Refresher training every three years.
– Regular equipment inspection
OSHA 29 CFR 1910 Subpart O and P
1910 Subpart O - Machinery and Machine Guarding
1910.212 - General Requirements For All Machines
1910.213 - Woodworking Machinery Requirements
1910.215 - Abrasive Wheel Machinery
1910 Subpart P - Hand and Portable Powered Tools and
Other Hand-Held Equipment
1910.242 - Hand and portable powered tools and equipment,
general
1910.243 - Guarding of portable powered tools
OSHA 29 CFR 1910 Subpart S
Electrical TOP








1910.304 - Wiring Design And Protection.
1910.305 - Wiring Methods, Components, And Equipment
For General Use.
1910.306 - Specific Purpose Equipment And Installations.
1910.307 - Hazardous (Classified) Locations.
1910.332 - Training
1910.333 - Selection And Use Of Work Practices
1910.334 - Use Of Equipment.
1910.335 - Safeguards For Personnel Protection.
Risk Assessment
Some Helpful Links
GHS Pictograms: https://www.osha.gov/Publications/OSHA3491QuickCardPictogram.pdf
Chemical Hygiene Plan: https://www.osha.gov/Publications/laboratory/OSHAfactsheetlaboratory-safety-chemical-hygiene-plan.pdf
Hazardous Drugs: https://www.osha.gov/dts/osta/otm/otm_vi/otm_vi_2.html#3
OSHA eTool Index: https://www.osha.gov/dts/osta/oshasoft/