As you know if you’ve read our previous post on regulatory agencies for the histology lab, OSHA is the Occupational Safety and Health Administration. They are a division of the Department of Labor and they are responsible for making sure that your workplace is safe. They aren’t just concerned with laboratories however. OSHA is responsible for all of the workplaces in the country, throughout a variety of industries, which means they can’t come and inspect every single workplace. Generally, if your lab is undergoing an OSHA inspection there was something to alert them to the need for an inspection. First priority is given to workplaces with immediate danger. These are unannounced and can occur as soon as a day after a complaint of immediate danger is given. This is so they can be proactive and prevent the second priority they investigate, which is work fatalities and large scale workplace accidents. These are reactive, which makes them second priority to the proactive prevention of accidents by investigation of immediate danger. Third, they will respond to other employee or patient complaints, that are not immediate danger. If you’re in a lab within a hospital, you may also be inspected as part of the hospital as a whole, under regular inspections they do of high hazard workplaces, which hospitals fall under.
If an OSHA inspector shows up at your lab, what do you do? Verify that they are in fact an OSHA inspector by asking to see their identification. You can also make a call to your local or national OSHA office to verify the inspector should be there that day. Take the inspector to your supervisor, or any relevant administrators who need to be aware that they are here. Depending on your position in the lab, you may not be involved in the opening conference, in which the inspector lets the people in charge know why they are there and what the scope of their investigation is. If you are the supervisor, and you are involved in this discussion, it is okay to (politely!) ask questions about who they need to talk to, what documents they need etc. so you can provide the information that is needed and fully understand the situation.
The inspector is going to do a walkthrough, a visual tour of the lab, which should be done with an escort from your facility present. This person may want to take notes, and document what the inspector takes photos of, even taking their own photos, so you have documentation of the tour as well. They may also want to do staff interviews, which is where you may become involved in an inspection if you’re not at the supervisory level. Answer their questions honestly, and tell the truth if you don’t know the answer to something. They may ask about safety procedures, whether employees have been trained on the procedures, they may ask to see employee records. They shouldn’t be discussing potential fines or collecting any money during this visit, however. We mentioned verifying their identity; the cases where there have been imposter inspectors, they are generally there to try and get money from you.
What are some common violations that they’re looking for?
Bloodborne pathogens is a big OSHA standard that is applicable to the histology lab. They will look at your exposure policies, your PPE usage, your equipment like fume hoods, hand hygiene, sharp safety, etc related to bloodborne pathogens.
Chemical hygiene and hazard communication are the most commonly cited violations. This includes things like your labeling, chemical inventory, your safety data sheets, storage, and spill handling.
Respiratory protection: Your staff needs medical evaluations to certify that they are able to safely wear any respiratory protection gear, even n-95s.
Emergency action plans: How do you report fires or other emergencies? Do you have an evacuation plan and meeting place? You can’t name every disaster, so you need an all hazards approach plan.
Fire safety: Fire hazards have their own standards. If you provide fire extinguishing equipment, you need to provide training.
Electrical safety: Are there frayed cords, trip hazards, extension cords? Is there clear access to your electrical panels?
General duty clause: This is a kind of catch all clause which says that the place of employment is free from recognized hazards likely to cause injury or death.
To learn more, check out An OSHA Inspection in the Histology Lab, the webinar by Dan the Safety Man, free to Enhanced Education Members in the on-demand library.