This year one of the goals I set for myself was to tackle OSHA. I wanted to make sure that we were up to snuff on compliance and that my staff knew how to keep themselves safe. Of course the mere mention of "the 'o' word" sent chills down the spines of each and every member of my staff and, if I'm honest, I had my own internal reservations about what a monumental task this was going to be.
I am pleased to announce that most of the formalities of establishing an OSHA compliant practice are almost done and now the task of enforcing the rules sets in. Because OSHA compliance is such a dreaded task for so many owners and managers I thought I would share my journey with each of you. It will either give you courage and hope that achieving this goal can be done or it will solidify (the typically shared feeling) that I was nuts for taking on this regulatory monster.
The first step was to determine what OSHA compliance meant for our practice. It varies from industry to industry and so I had some sorting of information to do. I needed to determine what was required for veterinary practices and what we lacked. We needed all the major stuff: an emergency evacuation plan, MSDS binders, secondary labels for our containers, and a staff training program that covered everything from personal safety, to ergonomics, to chemical hazards. That's a lot!
I had to prioritize what I felt like was most immediately needed for the staff and given that I'm in Texas and it's tornado season, I opted for an emergency evacuation plan to start with. This task was relatively simple. I need to put, in writing, a step by step protocol for the staff to follow in the event of an emergency. I covered fires/explosions, using a fire extinguisher and severe storms/tornadoes. I included who the person(s) in charge were and where the rendezvous point was. Then, at our next staff meeting I handed each staff member their own copy, went over it with them to determine if anyone had questions and posted a copy in a prominent place in our break room.
Emergency Evacuation Plan...check.
Gathering MSDS's was easier than I thought it would be. Our distributor provided me with a CD with all the MSDS's for products that I purchase from them. The ones that I was missing I simply found online. Then it was only a matter of making copies for each of the three main areas of the hospital, putting them in an easy to identify binder, explaining to the staff what MSDS's were to be used for and where they could locate them.
At lunch a few days later I was reading AAHA's publication, Trends Magazine. The cover read "Taming the Regulatory Beast". Ah ha! As quickly as my fingers would move I flipped to that page and got out my pink highlighter. The article discussed the basic do's and don'ts of having an inspector in your practice, what your rights and responsibilities are and so on. Near the end of the article some resources were listed to help owners and managers get started. My poor owner found a wish list on his desk within the hour for 3 items that I wanted from AAHA. The first was Philip Seibert's Manager's Guide to Veterinary Workplace Safety. This 41 page resource was The Bible of OSHA compliance as far as I was concerned. Second I wanted Mr. Seibert's training program for the whole veterinary team. I got the DVD and six workbooks. My plan was to have all current staff watch the DVD and take the test at the back of the book. All new staff would be required to watch the DVD and pass the test as part of their training as well. Lastly, I wanted the packet of secondary labels complete with a poster. Why reinvent the wheel? I just need to place those on all my secondary containers make sure they are appropriately labeled for warnings as they pertained to the chemical in the bottle.
Now I was getting somewhere.
Christmas (at least it felt like Christmas) came a few days later. I opened the box from UPS addressed to me and I did a little dance! I immediately looked at the schedule and assigned two different training sessions, dividing the staff up so that we still had coverage of the hospital and those in training could focus on the material. The DVD is a more up-to-date version of the "Right to Know" video that you are probably familiar with. Surprisingly the staff didn't make a single complaint...at least not to my face. They all passed their tests and those are filed in their personal files. Part of my staff safety training program was established. Now I needed to tackle the OSHA Bible and write my Safety Training Plan.
Phil Seibert is the go-to resource on OSHA compliance specifically for veterinary practices. His easy to understand guide spells everything out and even gives a comprehensive list of what needs to go in your safety training manual. It only took me two days to get it done. The next step is going to be presenting it to the staff, ensuring that they read it and then have them sign a training checklist that states they understand all of the policies and procedures in the manual. This will also be filed in their personal folders.
Now my training program is in place and the enforcement part begins. Keeping the staff on their toes regarding safe practices will no doubt be an exhausting task at first, but I hope that in time it will become routine. Two added benefits to having a safety program in place: I have a leg to stand on. I can deliver the same training to everyone, every time and it's in writing. So if there is a disciplinary issue with regard to safety I can back up my verbal requests with a written document that the employee signed off on as having received and understood. Secondly, I can show a good faith effort to an OSHA inspector that our practice is absolutely striving for safety and compliance.
Stay tuned...I will post new blogs with my progress once the staff receives the manual and the new practices and expectations set in.