For each of these standards, the OSHA checklist for healthcare facilities should include the following types of content:
◈ A description of that standard’s training requirements, and questions that gauge whether the facility is in compliance with these standards. Training requirements address how often training must be provided, who must provide the training, and what the training must consist of.
◈ A description of that standard’s recordkeeping requirements. Many healthcare standards contain requirements as to how long training records must be kept, and as to where records must be kept. Some healthcare standards require the employer to create a safety plan or program. For example, the Emergency Action Plan Standard requires employers of more than ten employees to keep a copy of an emergency action plan onsite, and readily accessible to employees. The OSHA checklist for healthcare facilities should capture these requirements.
◈ Medical records. Healthcare standards often require employers to maintain medical records. For example, the bloodborne pathogens standard requires employers to maintain records on individuals who have contracted Hepatitis B at work. The standards describe what must be contained in these records, and whether any of the information should be regarded as confidential. The OSHA checklist for healthcare facilities should include questions addressing employer compliance with retention and content of medical records.
◈ Sources of hazards. The checklist for any given safety standard should contain a list of sources of hazards the standard is designed to minimize. For example, the bloodborne pathogens standard checklist should describe the hazards – contaminated sharps, open wounds, accidental re-use of needles – that the standard applies to. In addition, the checklist for each standard should cover what measures the employer is taking to mitigate hazards. Mitigation of hazards first consists of elimination of the hazard. If that is not possible, employers should then attempt to substitute for the hazard. Substitution consists of, for example, replacing a cleaning agent known to be carcinogenic with one approved by the Environmental Protection Agency (EPA).
◈ Description of engineering controls, work practice (administrative) controls, and personal protective equipment. If a hazard cannot be eliminated or substituted, an employer must attempt to use engineering controls, which are attempts to isolate employees from a hazard. Engineering controls are methods that are built into the design of a plant, equipment or process to minimize the hazard. Engineering controls are a very reliable way to control worker exposures as long as the controls are designed, used, and maintained properly. The basic types of