OSHA Audits And Your Asc: What to Expect, How to Prepare, Help From the Auditors

In last month’s issue of the The AuxoMedical Examiner we addressed Occupation Safety and Health Administration (OSHA) workplace safety rules and safety programs. In that article it was noted that: More workers are injured in the healthcare and social assistance industry sector than any other private industry sector.

That said, it follows that healthcare providers, including ASCs, are likely to be the object of scrutiny by OSHA. As an operating entity in a high risk industry sector, it is quite possible that your ASC will be scheduled for an OSHA inspection (audit) to assure compliance with OSHA requirements.

But put that in context. OSHAs objective is not to be punitive. Rather it seeks to help employers and workers reduce on-the-job hazards to prevent injuries, illnesses and deaths.

Let’s take a look at what you may expect when the OSHA compliance safety and health officer (CO) shows up on your doorstep, typically without advance notice. Following that, we’ll look at how you may best position your ASC to not be a target for an OSHA inspection and the payoffs for being proactive.

OSHA Inspections

The objective of OSHA is to enforce strong, fair and effective safety and health requirements in the workplace. OSHA COs seek to assure compliance with OSHA requirements. The goal is to help employers and workers reduce on-the-job hazards to prevent injuries, illnesses and deaths.

With over 7 million U.S. workplaces covered by OSHA, the agency must prioritize the most hazardous workplaces as all cannot be inspected every year. The following are OSHA’s order of priority:

1. Imminent danger situations
2. Severe injuries and illnesses
3. Worker complaints
4. Referrals of hazards from other government agencies
5. Targeted inspections focused on high-hazard industries (Healthcare is top of the list!)
6.  Follow-up inspections to ensure violation compliance.
7. Inspections may be conducted via telephone or on-site depending on the severity of the complaint. If OSHA is satisfied with the employer’s telephone response, generally no on-site inspection will be conducted.

On-site inspections begin with preparation on the part of the OSHA COs to review the history of prior inspections as well as current operations and procedures and appropriate standards.

From there, you may expect the following:

• Presentation of credentials
• Opening Conference to explain reason for and scope of the inspection
• Walkaround the workplace inspecting for hazards
• Closing Conference to discuss OSHA inspector findings.

Employer Preparation

You have the right to have a Company Representative (CR) serve as your ASCs contact and accompany the OSHA compliance officer throughout the entire visit. It is best to have a preselected and trained CR who knows where all information is kept and is trained and competent to explain your safety policies, procedures and recordkeeping.

Here are some items to have prepared:

• Assignment of responsibilities, to include a “greeting team” to meet the CO
• Documented training logs
• Recordkeeping
• Equipment inspection records
• Safety and health policies
• Review of insurance and third party audits
• Hazard assessment and abatement
• Review of previous audits and citations.

Your CR should record the inspector’s actions and comments during the inspection on a prepared form. This information will be a written record of what transpired and be valuable if you contest the citation or penalty if there is one.

Items to record on this form include:

• The inspector’s name and office telephone number
• The documents that the inspector reviewed and copied
• The attendees at the opening and closing conferences
• The areas that were inspected
• The employees and union representatives who participated
• The dates and times when the inspector was on site
• OSHA implied records (those with no specific requirement for a written record, e.g. OSHA requires every employer to conduct frequent ladder inspections, with no written record requirement. The written record could be a log with initials and dates of inspection.

Be Proactive to Minimize Being Reactive

Once again, OSHA’s objective is not to be punitive. Rather it seeks to help employers and workers reduce on-the-job hazards to prevent injuries, illnesses and deaths.

In OSHA’s own words …

OSHA encourages all employers to adopt an Injury and Illness Prevention Program. Injury and Illness Prevention Programs, known by a variety of names, are universal interventions that can substantially reduce the number and severity of workplace injuries and alleviate the associated financial burdens on U.S. workplaces.

Most successful Injury and Illness Prevention Programs are based on a common set of key elements. These include: management leadership, worker participation, hazard identification, hazard prevention and control, education and training, and program evaluation and improvement.

In keeping with that ultimate aim, you are not on your own to initiate or maintain a workplace safety program … OSHA stands ready to help with its free On-site Consultation Program.

Taking advantage of this OSHA offer of assistance is a smart move whether or not you have a workplace safety program in place. If you don’t have one, here’s an opportunity to put one in place with OSHA guidance. Alternatively, if you have one in place, a fair question is how well is it maintained, enforced and responsive to changing conditions, threats and work processes?

The OSHA Consultant will bring you up to speed on knowing your requirements as an employer under the Occupational Safety and Health Act (OSHA). Not only is this service free, it is absolutely confidential.

The objectives are to identify workplace hazards, provide advice on compliance with OSHA standards, and assist in establishing injury and illness prevention programs. On-site Consultation services are separate from enforcement and do not result in penalties or citations. Click here for more info.

Workplace safety is all about protecting your ASC’s most valuable asset – your staff.

There is considerable evidence of proven returns on investment (ROIs) ranging from 100% to 450% or more … based on investments in workplace safety. Additionally, intangible ROIs are realized from a transformed workplace culture that can lead to higher productivity and quality, better workforce retention, reduced costs, and greater employee satisfaction.

These benefits are the dividends enjoyed by ASCs that develop a proactive process to identify and repair workplace hazards to protect workers from injury, illness and death.

View OSHA as an ally. “Partner” with them to ensure a workplace safety program that is well designed, implemented, and maintained to minimize worker exposure to injuries, illnesses and deaths.