Regulations you need to know: OSHA (Part 3) (Proceedings)


Regulations you need to know: OSHA (Part 3) (Proceedings)

Aug 01, 2010

Since most OSHA inspections are the result of an employee (or former employee) complaint or a reported injury or illness, very often the inspection will focus on a specific area of concern within the workplace. Just as medical professionals specialize, the inspector's expertise in occupational health or general safety rules will also play a role in what portions of a hospital safety program are evaluated. With that in mind, we'll discuss the elements of an entire hospital safety program. Remember, this is not an overnight project. There are few definitively right or wrong answers. The important objective is to document the policies and practices that are in effect now. Changes and revisions will come with time. When you have completed a section's policy statements and training materials, add it to the Hospital Safety Manual binder. This will demonstrate a comprehensive program.

Hazards for the Medical Staff

Animal Handling

Although handling animals in itself is not a dangerous job, the unpredictability of some animals or situations can turn a routine episode into a very dangerous event. There are many situations that OSHA doesn't address directly, but getting caught in a run with a vicious dog is definitely dangerous. The hospital director should make sure all people (including volunteers) who handle animals are properly trained in restraint procedures. There should be a mechanism for workers to summon assistance when they get into trouble. Could someone yelling for help from the kennels be heard in the front of the hospital above the chorus of barking dogs? What about weekends or off-hours when there may be only one person in the building?


OSHA standards require a hearing conservation program when workers are exposed to noise levels above 85 decibels (db) based on an eight hour time-weight average (TWA). As a general rule, the louder the noise, the shorter exposure is permitted.

Although it will vary from one breed to another, as well as one animal to another, noise level from a barking dog can reach 80 or 90 decibels. It doesn't take much of a chorus of barking dogs to exceed the threshold limit for a noise hazard area. In hospitals the author has consulted with, noise levels in the kennels typically ranged from 95 to 115 decibels measured at the center of the room. At the upper end of this range a person could work approximately 15 minutes in the area without hearing protection during an average 8 hour work day.

The hearing conservation program can take many forms, including medical evaluations and periodic audiograms for employees, safety equipment, reduction in noise levels by absorption or dissipation, training of employees, and posting of warning signs identifying noise hazard areas.

Noise hazard areas must be identified by means of a poster, placard or sign. The wording should reflect the degree of danger. Typically, a sign stating "Warning: Noise Hazard Area. Hearing protection required for prolonged exposure" is sufficient for most areas. Place the sign at all entrances to the areas, including exterior doors.


The NIOSH established limits for occupational exposure to waste anesthetic gasses is less than 2.0 parts per million (ppm) for all halogenated agents (methoxyflourane, halothane, isoflorane). Exposure to the nitrous oxide must also be maintained below 25 ppm. Most hospitals are unaware of the actual concentration levels of waste anesthetic gasses in the workplace, but with a comprehensive WAG management program, the risk of unnecessary exposure can be minimized. A comprehensive WAG management program should consist of the following elements:

     • Application of a well designed WAG scavenging system. This is the single most effective means of reducing exposures of WAGs in the workplace. A proper scavenging system will capture the excess gasses directly at the source and transport them to a safe exhaust port, usually outside the building. There are three general methods of WAG removal currently in use: active scavenging, passive exhaust and absorption. Each has a place, but rarely does one method fit all circumstances.
     • Routine maintenance and evaluation of anesthesia equipment. Anesthetic machines must be checked for leaks and serviced periodically. Although there is no "set" interval, the machine manufacturer's recommendations should be followed. At a minimum, daily "pre-use checks" for leaks in the hoses or connections should be performed, and examination or calibration by a qualified medical equipment repair technician should be completed every four months.
     • Developing or revising work practices that minimize leaks and non-scavenged operations. Detailed training for staff members who operate or clean anesthesia equipment is a must. Training should include all areas of anesthesia agent use, including storage of the liquid agents, refilling of the vaporizers, emergency procedures if a bottle is dropped and broken, as well as general operating instructions for the machine.
     • Training of the staff in proper principles of anesthesiology so that only the minimum amounts of anesthetic agents are used. Many hospitals use the "about that much" method of gas anesthesia and can significantly reduce the quantity of anesthetic agents used if flow rates were calculated prior to induction.
     • Adequate general ventilation in the work areas. Some procedures , like masking, defy collection of waste gasses. In those instances, make sure the ventilation in the room is good. Exhaust fans for evacuating room air to the outside are recommended. Be conscious of air handling systems that recirculate the air; exposure of others may be the result. Induction chambers can be connected to the scavenging system or absorption canisters to reduce the levels of escaping gasses.