OSHA Compliance Checklist for Medical Offices

A yearly self-review of the OSHA standards that apply to most physician, dental, and outpatient offices: bloodborne pathogens, hazard communication, PPE, exits and emergency plans, the workplace poster, and injury reporting. Each item shows the regulation it comes from.

RISK MANAGEMENT

Which OSHA Standards Apply to a Medical Office?

OSHA has no single “medical office standard.” A typical physician, dental, or therapy office falls under a handful of general industry rules, and the one that shapes most of a clinic's safety work is bloodborne pathogens. The checklist above groups them into the six areas most offices need to review once a year.

StandardWhat it means for a clinic
1910.1030Bloodborne pathogens: exposure control plan, hepatitis B vaccine, PPE, sharps, training, records
1910.1200Hazard communication: written program, chemical list, safety data sheets, labels, training
1910.132PPE: a certified hazard assessment and training
1910.36–.39Exit routes, emergency action plan, fire prevention plan
1903.2Posting the OSHA workplace poster
Part 1904Injury records and reporting severe injuries

Bloodborne Pathogens: The Core of Healthcare OSHA

If anyone in the office could reasonably contact blood or other potentially infectious materials, you need a written exposure control plan, reviewed and updated at least annually, and the review has to document that you considered safer medical devices (1910.1030(c)(1)(iv)). Hepatitis B vaccination must be made available within 10 working days of initial assignment, and training is due at assignment and every year after.

Build the plan itself with our exposure control plan template, and see the bloodborne pathogens training guide for what the annual session has to cover.

Do Medical Offices Have to Keep OSHA 300 Logs?

Often not. OSHA's recordkeeping rule lists industries that are partially exempt from keeping injury and illness logs, and the list includes offices of physicians, offices of dentists, offices of other health practitioners, and outpatient care centers. Employers with 10 or fewer employees are also partially exempt.

The exemption does not cover severe injuries

Every employer must report a work-related death within 8 hours, and an in-patient hospitalization, amputation, or loss of an eye within 24 hours (29 CFR 1904.39). The sharps injury log is tied to the 300 log, so an exempt office is not required to keep it, though many keep one anyway.

Running the Yearly Review

Walk the office, do not just read the binder

Open the sharps containers, read the labels on the disinfectant bottles, and try the exit doors. Most findings come from what is physically in the rooms, not what is written in the plan.