OSHA Audits: as Simple as “Be Prepared”
About six years ago the medical industry began to see an upward trend in the frequency of OSHA audits. Now, OSHA enforcement is at historically high levels and OSHA’s unannounced onsite inspections are happening more often than ever. So what are facilities to do? The answer is simple: be prepared.
Step 1: Training is Everything
In a recent interview HIPAA lawyer Scot Ganow gave some insight on this. “Training programs are one of the easiest, cost-effective ways to reduce risk, yet I see so many organizations fail to implement them, implement them poorly, or if they do implement them, they do not maintain them and keep them current as part of an ongoing awareness program.”
Scot is right, many companies are simply not properly and fully training their employees. It’s not just about having access to compliance materials. Simply enrolling in a program is not enough. Employees need to keep their certifications up to date, Safety Data Sheets must be in order, and so on. Plus, there are often updates to regulations such as the recent Hazard Communication update or the upcoming ICD-10 transition. Facilities need to be sure they are aware of changes and updates and adjust their staff training accordingly. Periodic inservices to remind employees of regulations are always helpful as well.
Step 2: Have a System in Place
Do you have a plan for making sure each new employee is properly trained when they begin working at your facility? Is there an annual date where you review when everyone’s certifications expire so you can address the next round of training? In addition, ask yourself these questions:
- Do you have a method for getting up to date compliance information?
- Are you subscribed to related blogs or journals?
- Do employees know their roles when it comes to managing compliance at your facility?
- Have you assigned a compliance officer?
- Have you done a mock audit to see if you’re prepared?
Step 3: Prepare for Inspections
So OSHA arrives and decides they’re going to do an inspection. What happens now? It’s important to think about how your facility will respond to an unannounced OSHA inspection. Who should be involved in this process? What will happen? Some advanced planning can make for a much less frantic day.
Do some advanced planning. Just like you have an emergency action plan for a real emergency, it’s good to have an inspection plan as well. Designate someone who will be responsible for greeting the inspector and accompanying them during the inspection. Make sure you have notepads, pens and a camera on hand. This way, staff involved can take notes during the inspection and if an inspector takes photos, staff can do the same.
Have a document controller designated as well. This should be someone who knows where important documents are and has access to them. This person should only provide documents an inspector requests and should be the only person to present these requested materials. Never leave these documents in plain sight or in a place easily accessible by the wrong hands. Once documents are no longer in use they should be documented and put away in the proper place right away.
Train your staff to act appropriately during an inspection. Make sure they know to answer questions truthfully and specifically to the question that was asked. Encourage them to avoid speculating and if they are unsure to say they will find out. Remind them to be courteous and professional.
Have you had an unannounced OSHA inspection at your facility? Share your experience in the comments section below! Any helpful tips?
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