Inspectors want to see labels on dangerous materials and proof that you trained employees to handle them-and they want it in writing.
When OSHA inspectors come calling, they'll probably want to evaluate your Hazard Communication Program and review the required written plan. This plan lists your hospital's policies and procedures to ensure employees remain safe when they are handling potentially dangerous chemicals. Most practices already have the elements of the plan in place, so you likely just need to capture the details on paper.
Keep in mind that your plan doesn't have to be elaborate, just informative. Still, you do need to say who's responsible for implementing each step in the safety plan and for keeping your plan up to date. Some other key elements to include:
Remember: You must offer every staff member the training you promise in your plan before you let him or her perform the job. And this plan must be in writing or, in the eyes of OSHA, it doesn't exist.
Complaints are always trickling into OSHA about sleazy salespeople trying to convince business owners that they need to pay for OSHA publications, posters, fact sheets, and more. Don't be swindled—OSHA's arsenal of information is available free of charge at osha.gov/pls/publications/pubindex.list.
Philip Seibert
Philip Seibert, CVT, is an author, speaker, and consultant with Veterinary Practice Consultants in Calhoun, Tenn. Send questions or comments to ve@advanstar.com.