OSHA, MSDS, and other letters you should know

OSHA Occupational Safety and Health Administration Occupational Safety and Health Administration Can be stiff penalties for non- compliance (up to $70,000) Can be stiff penalties for non- compliance (up to $70,000) OSHA Program OSHA Program Has 4 basic parts: Has 4 basic parts: Mandatory administrative tasks and posting of required notices. Mandatory administrative tasks and posting of required notices. Evaluation of hazards and selection of appropriate and useable protection equipment. Evaluation of hazards and selection of appropriate and useable protection equipment. Development and enforcement of written plans for managing hazardous materials or dangerous tasks. Development and enforcement of written plans for managing hazardous materials or dangerous tasks. Documented, appropriate training of employees on the hazards associated with their job. Documented, appropriate training of employees on the hazards associated with their job.

OSHA and veterinary medicine Compressed air cylinders Compressed air cylinders Should be stored in a dry, cool place, away from potential heat sources. Should be stored in a dry, cool place, away from potential heat sources. Must be secured in an upright position by holder, bracket, chain or strap. Must be secured in an upright position by holder, bracket, chain or strap. Sign should identify where these cylinders are kept. Sign should identify where these cylinders are kept.

o84 o84

Food and Beverages Consumption of food and beverages must be limited to areas free of toxic and biologically harmful substances. Consumption of food and beverages must be limited to areas free of toxic and biologically harmful substances. Staff lunches, drinks, condiments and snacks must be stored in an area free from biological or chemical hazards. Staff lunches, drinks, condiments and snacks must be stored in an area free from biological or chemical hazards.

Housekeeping and Maintenance Need to establish a good cleaning routine so that hospital will stay clean even during busy times. Need to establish a good cleaning routine so that hospital will stay clean even during busy times. Should be free from physical and health hazards Should be free from physical and health hazards Should include tasks to be performed: Should include tasks to be performed: Daily Daily Weekly Weekly Monthly Monthly Semi-annually Semi-annually

Administrative OSHA Policies “It’s the law” poster must be prominently displayed. “It’s the law” poster must be prominently displayed. If OSHA lets you know of an inspection, then you must notify employees of the date and time that they may meet the compliance officer. If OSHA lets you know of an inspection, then you must notify employees of the date and time that they may meet the compliance officer. Copies of citations for violations must be posted for at least 3 days or until violation is corrected. Copies of citations for violations must be posted for at least 3 days or until violation is corrected. Businesses with more than 11 employees must maintain a log of related injuries and illnesses and an injury and illnesses incident report. Businesses with more than 11 employees must maintain a log of related injuries and illnesses and an injury and illnesses incident report. Appropriate warning signs should be displayed. Appropriate warning signs should be displayed. Written plans for preventing fire, handling chemicals, and prevention injury are required for all workplaces with more than 10 employees. Written plans for preventing fire, handling chemicals, and prevention injury are required for all workplaces with more than 10 employees.

Employer’s Rights Rights: Rights: Enforce workplace rules Enforce workplace rules Be present during an inspection or investigation. Be present during an inspection or investigation. Require a warrant for inspection. Require a warrant for inspection. Request postponement of inspection. Request postponement of inspection. Expect that no trade secrets will be divulged Expect that no trade secrets will be divulged Consult an attorney Consult an attorney See any complaints See any complaints Have employees interviewed at a time that does not interfere with staff member’s job Have employees interviewed at a time that does not interfere with staff member’s job Right to appeal findings Right to appeal findings

Employer’s Responsibilities Responsibilities Responsibilities Provide a hazard free workplace Provide a hazard free workplace Set and enforce safety rules Set and enforce safety rules Provide Personal Protective Equipment (PPE) with proper instructions Provide Personal Protective Equipment (PPE) with proper instructions Provide training on any potential workplace hazards Provide training on any potential workplace hazards

Staff’s Rights Work in a hazard free workplace Work in a hazard free workplace Be informed of their rights under OSH Act Be informed of their rights under OSH Act Be informed of known hazards Be informed of known hazards Be provided with training and instruction on how to use PPE Be provided with training and instruction on how to use PPE View and have copies of OSHA standards View and have copies of OSHA standards Access personal medical records that may be maintained as a part of business Access personal medical records that may be maintained as a part of business Be present during safety testing Be present during safety testing Present complaints to employer or OSHA when hazard is suspected. Present complaints to employer or OSHA when hazard is suspected. Speak with compliance officer privately during inspection. Speak with compliance officer privately during inspection.

Staff Responsibilities Read the OSHA poster Read the OSHA poster Comply with standards Comply with standards Follow rules and regulations Follow rules and regulations Wear PPE while working Wear PPE while working Report hazardous conditions Report hazardous conditions Report any job-related injury or illness to employer and seek treatment Report any job-related injury or illness to employer and seek treatment Cooperate with OSHA compliance officers Cooperate with OSHA compliance officers

OSHA Inspections Know who is allowed to admit inspectors. Know who is allowed to admit inspectors. On-site inspection must be triggered by at least one of the following: On-site inspection must be triggered by at least one of the following: Written complaint and OSHA must believe that a safety or health danger exists. Written complaint and OSHA must believe that a safety or health danger exists. Complaint must allege that physical harm has occurred and that hazards still exists. Complaint must allege that physical harm has occurred and that hazards still exists. Must allege imminent danger Must allege imminent danger Employer failed to provide adequate response to a compliant Employer failed to provide adequate response to a compliant Business has history of failure-to-abate citations during last 3 years. Business has history of failure-to-abate citations during last 3 years. Discrimination issues for filing complaints about OSHA standards Discrimination issues for filing complaints about OSHA standards

How to Survive Inspection Be polite and cooperative Be polite and cooperative Verify credentials Verify credentials Request that inspection take place at a more convenient time Request that inspection take place at a more convenient time Make time for inspection Make time for inspection Take notes and pay attention during inspection Take notes and pay attention during inspection Have employees “stand-by” during inspection Have employees “stand-by” during inspection Show officer only what he or she asks to see Show officer only what he or she asks to see Have copies of hospital policies readily available Have copies of hospital policies readily available Correct any violations immediately Correct any violations immediately

Anesthetic Gases Practices are expected to properly store, label and use chemicals safely. Practices are expected to properly store, label and use chemicals safely. Should help to keep employee exposure under allowed limits. Should help to keep employee exposure under allowed limits. Should: Should: Have periodic monitoring of equipment and exposure levels. Have periodic monitoring of equipment and exposure levels. Have proper ventilation. Have proper ventilation. Have proper scavenging systems. Have proper scavenging systems. Train staff appropriately. Train staff appropriately.

Masking and Tank Induction Make sure masks and tanks have tight-fitting seals and are connected to scavenging systems. Make sure masks and tanks have tight-fitting seals and are connected to scavenging systems. Use proper fitting masks for patients Use proper fitting masks for patients Only use masking procedures when medically indicated Only use masking procedures when medically indicated Remember to turn on oxygen, place mask, then turn on gas, reverse order to remove mask. Remember to turn on oxygen, place mask, then turn on gas, reverse order to remove mask.

Simple Anesthetic Exposure Badges Used to help test exposure to anesthetic gases. Used to help test exposure to anesthetic gases. Can be obtained from several labs. Can be obtained from several labs. Should be worn by a typical employee on typical workload day. Should be worn by a typical employee on typical workload day. OSHA recommends testing every 6-12 months. OSHA recommends testing every 6-12 months.

Waste Anesthetic Gas Scavengers Active Scavengers Active Scavengers Fan in a box that creates vacuum Fan in a box that creates vacuum Cost from $400-$1000 Cost from $400-$1000 Will need maintenance and replacement Will need maintenance and replacement Manual activation, must be turned on Manual activation, must be turned on Passive Exhaust Passive Exhaust Channels gases through a tube from patients diaphragm Channels gases through a tube from patients diaphragm Limited distance Limited distance Absorption Absorption Charcoal absorption canisters Charcoal absorption canisters Should be monitored and changed Should be monitored and changed

Animal Handling and Husbandry Animal related injury number one injury in a vet clinics Animal related injury number one injury in a vet clinics Potential of zoonotic diseases Potential of zoonotic diseases Training is a must with new employees!! Training is a must with new employees!!

Bathing, Grooming and Insecticides Wear appropriate PPE. Wear appropriate PPE. Make sure that wet areas or dangerous areas are identified. Make sure that wet areas or dangerous areas are identified. All chemicals should be stored and labeled properly. All chemicals should be stored and labeled properly. Anything changed from one container to another should be properly labeled. Anything changed from one container to another should be properly labeled.

Common Zoonotic Disease Factors Be diligent with protection when handling known disease carriers. Be diligent with protection when handling known disease carriers. Always wear PPE when unsure of a disease status. Always wear PPE when unsure of a disease status. Common diseases include: Common diseases include: Bacterial infections Bacterial infections Ringworm Ringworm Parasites Parasites Mange Mange Leptospirosis Leptospirosis Toxoplasmosis Toxoplasmosis Cryptospiridiosis Cryptospiridiosis Plaque Plaque Lyme Disease Lyme Disease Brucellosis Brucellosis Cat Scratch Disease (Bartonella henselae) Cat Scratch Disease (Bartonella henselae) Rabies Rabies

HIV/ AIDs Risk Always use precautions when dealing with other team members bodily fluids. Always use precautions when dealing with other team members bodily fluids. Person with HIV or AIDs may be more susceptible to other zoonotic diseases. Person with HIV or AIDs may be more susceptible to other zoonotic diseases. Can an employer ask HIV status? Can an employer ask HIV status?

Noise Hazards Generally the kennel area. Generally the kennel area. If prolonged exposure, may be harmful. If prolonged exposure, may be harmful. Should be identified by a sign and ear protection should be provided. Should be identified by a sign and ear protection should be provided. Sound Panels may be used to help reduce noise. Sound Panels may be used to help reduce noise.

Rabies Vaccine for Employees OSHA does not require the vaccine but it is highly recommended. OSHA does not require the vaccine but it is highly recommended. Most vet schools require the vaccine as a pre- emptive strike against exposure. Most vet schools require the vaccine as a pre- emptive strike against exposure. Should be considered by all employees that have significant contact with animals. Should be considered by all employees that have significant contact with animals.

Personal Hygiene Regular Hand washing is strongly encouraged Regular Hand washing is strongly encouraged Before eating, drinking Before eating, drinking Before smoking Before smoking Before leaving Before leaving Before and after using restroom Before and after using restroom After handling specimens After handling specimens After handling animals After handling animals

How to perform a thorough Hand Washing Wet both forearms with warm water Wet both forearms with warm water Apply a generous amount of disinfecting soap in the palm of one hand Apply a generous amount of disinfecting soap in the palm of one hand Using a vigorous motion, scrub each side of the hand, between the fingers and at least halfway up the arm Using a vigorous motion, scrub each side of the hand, between the fingers and at least halfway up the arm If there is debris under the fingernails, use a hard pick or stiff brush to remove matierial while soap is still on the hands If there is debris under the fingernails, use a hard pick or stiff brush to remove matierial while soap is still on the hands Rinse both hands thoroughly with warm or tepid water Rinse both hands thoroughly with warm or tepid water Dry both hands and arms with a towel or air dryer Dry both hands and arms with a towel or air dryer

Physical Injuries Bites Bites Scratches Scratches Use appropriate PPE Use appropriate PPE Have adequate training to avoid situations Have adequate training to avoid situations Prevention is key! Prevention is key!

Chemicals Five Specific requirements that veterinary clinic must follow: Five Specific requirements that veterinary clinic must follow: 1. Practice must have a written chemical plan. 1. Practice must have a written chemical plan. 2. A complete list of all hazardous chemicals must be maintained. 2. A complete list of all hazardous chemicals must be maintained. 3. The practice must maintain a library of material safety data sheets. 3. The practice must maintain a library of material safety data sheets. 4. All containers of hazardous chemicals must be properly labeled. 4. All containers of hazardous chemicals must be properly labeled. 5. The practice must train all staff members on the dangers and safety aspects of the chemicals. 5. The practice must train all staff members on the dangers and safety aspects of the chemicals.

Ethylene Oxide Form of sterilization procedure. Form of sterilization procedure. Not used as commonly today. Not used as commonly today. MUST be used with a ventilation system. MUST be used with a ventilation system. Link with cancer. Link with cancer. Fines associated with trying to shortcut the process. Fines associated with trying to shortcut the process. OSHA requires monitoring to take place. Will use bade devices to detect exposure levels. OSHA requires monitoring to take place. Will use bade devices to detect exposure levels. Detailed written plan also required. Detailed written plan also required. Make sure to follow manufacturer instructions. Make sure to follow manufacturer instructions. Make sure to follow proper storage and training recommendations. Make sure to follow proper storage and training recommendations.

Ethylene Oxide Continued Emergency Plans Emergency Plans If exposed, adequate fresh air is the treatment of choice. If exposed, adequate fresh air is the treatment of choice. If irritation persists, consult physician. If irritation persists, consult physician. If in contact with liquid form, removal all contaminated clothing and wash skin surfaces for 15 minutes. If in contact with liquid form, removal all contaminated clothing and wash skin surfaces for 15 minutes. If in contact with eyes, use eyewash for at least 15 minutes and consult an ophthalmologist. If in contact with eyes, use eyewash for at least 15 minutes and consult an ophthalmologist.

Bulk Chemicals If more than 20 gallons, should consult with fire department about storage. If more than 20 gallons, should consult with fire department about storage. Should make sure areas with large amount of chemicals are properly identified. Should make sure areas with large amount of chemicals are properly identified. Should have plans in place if emergency occurs for avoiding areas with bulk chemicals. Should have plans in place if emergency occurs for avoiding areas with bulk chemicals.

Chemical Safety Training Conduct training as soon after the person is hired as possible. Conduct training as soon after the person is hired as possible. Prepare workbook or handout for training. Prepare workbook or handout for training. Include worker’s rights. Include worker’s rights. Provide hospital policy copies. Provide hospital policy copies. Stress importance of PPE. Stress importance of PPE.

Determining Chemical’s Hazard Health Hazard: chemical for which there is evidence that acute or chronic health effects may occur in exposed employees. Falls into following categories: Health Hazard: chemical for which there is evidence that acute or chronic health effects may occur in exposed employees. Falls into following categories: Carcinogen Carcinogen Toxic Toxic Irritant Irritant Sensitizer Sensitizer Any agent which damages the lungs, skin, eyes or mucous membranes. Any agent which damages the lungs, skin, eyes or mucous membranes. Physical Hazard: chemical that is: Physical Hazard: chemical that is: Combustible liquid Combustible liquid Compressed gas Compressed gas Explosive Explosive Flammable Flammable Organic peroxide Organic peroxide Oxidizer Oxidizer Pyrophoric Pyrophoric Unstable Unstable Water-reactive Water-reactive

Hazardous chemical Labels All chemicals should be properly labeled All chemicals should be properly labeled Should always label secondary containers Should always label secondary containers No special labels are required, but should be uniform throughout practice. No special labels are required, but should be uniform throughout practice. If can’t physically label, use a color code system. If can’t physically label, use a color code system. If is a prescription, no additional information is needed than is what is found on a customary prescription label. If is a prescription, no additional information is needed than is what is found on a customary prescription label.

Formalin/Formaldehyde Make sure properly identified and stored. Make sure properly identified and stored. Keep least amount on hand as possible. Keep least amount on hand as possible. Wear Appropriate PPE. Wear Appropriate PPE.

Material Safety Data Sheets Produced by the chemical manufacturer. Produced by the chemical manufacturer. Should be kept together in one location. Should be kept together in one location. Should be indexed in a systematic way. Should be indexed in a systematic way. Call distributor or manufacturer if need a MSDS. Call distributor or manufacturer if need a MSDS.

Exemptions Hazardous waste- by EPA not OSHA Hazardous waste- by EPA not OSHA Tobacco products Tobacco products Wood or wood products Wood or wood products Articles (what is product of hazardous materials) Articles (what is product of hazardous materials) Food, drugs, cosmetics or alcoholic beverages that are packaged to be sold to consumers and that are not opened in the hospital. Food, drugs, cosmetics or alcoholic beverages that are packaged to be sold to consumers and that are not opened in the hospital. Foods, drugs, cosmetics intended for personal consumption by the employee while in the workplace. Foods, drugs, cosmetics intended for personal consumption by the employee while in the workplace. Any common cleaner that is is used in way as is used by average consumer. Any common cleaner that is is used in way as is used by average consumer. Any drug sold in final solid form to client for immediate consumption by patient. Any drug sold in final solid form to client for immediate consumption by patient.

Written Chemical Plan Should be reviewed and revised often. Should be reviewed and revised often. Should include hazardous material and what PPE is recommended for use while using this chemical. Should include hazardous material and what PPE is recommended for use while using this chemical. Should describe training offered to employees on a chemical. Should describe training offered to employees on a chemical. Should outline MSDS system. Should outline MSDS system.

Eye wash devices Mounted and eyewash bottles. Mounted and eyewash bottles. Mounted stations should not be on faucet used for bathing animals because of exposure to other chemicals. Mounted stations should not be on faucet used for bathing animals because of exposure to other chemicals. Device should not be locked. Device should not be locked. Hand held bottles are designed for foreign bodies and not chemicals. Hand held bottles are designed for foreign bodies and not chemicals. Employees should be trained as to location and operation. Employees should be trained as to location and operation.

Electricity Hazards include electrical shock and physical hazards. Hazards include electrical shock and physical hazards. May not have ground for electrical plugs. May not have ground for electrical plugs. May use extension cords, etc. May use extension cords, etc. Inspect if circuit breakers trip often. Inspect if circuit breakers trip often. Check for damage or burnt cords and outlets routinely. Check for damage or burnt cords and outlets routinely. OSHA requires adequate and reliable lighting for all exits OSHA requires adequate and reliable lighting for all exits

Ergonomics Repetitive movements. Repetitive movements. Have computers and office equipment comfortable and able to prevent injury. Have computers and office equipment comfortable and able to prevent injury. OSHA requires adequate and reliable lighting for all exits. OSHA requires adequate and reliable lighting for all exits.

One- Hand Recapping of Needles Step 1 - Place the cap for the needle on a hard surface like the countertop. Do not hold the cap with your hand. Step 1 - Place the cap for the needle on a hard surface like the countertop. Do not hold the cap with your hand. Step 2 - Hold the syringe by the barrel in your fingertips with the needle pointing away from you. Step 2 - Hold the syringe by the barrel in your fingertips with the needle pointing away from you. Step 3 - Place your fingertips on the counter and "slide" your hand along the counter until the needle is inside of the cap. Step 3 - Place your fingertips on the counter and "slide" your hand along the counter until the needle is inside of the cap.

Step 4 - "Pick up" the cap with the needle. You may now use your other hand to completely seat the cap on the hub. Step 4 - "Pick up" the cap with the needle. You may now use your other hand to completely seat the cap on the hub.