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Attend ASCA 2013 for the Latest in Regulatory Compliance


Join your colleagues for an Occupational Safety and Health Administration Survey readiness seminar at ASCA’s annual meeting in Boston next year. BY BEVERLY KIRCHNER, RN, CASC


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n April 2011, the Occupational Safety and Health Administration (OSHA) announced plans to survey ASCs in Flor- ida, Georgia, Alabama and Mississippi to ensure compliance with the federal Needlestick Safety and Prevention Act that was adopted in 2000. OSHA began these surveys in April 2011 and has now completed surveys in all of those states. OSHA has also indicated that it might extend those surveys into other states as well. As you prepare your ASC for an OSHA survey, keep the following basic elements in mind.


Survey Readiness An OSHA surveyor will ask to see a variety of documents throughout the survey. Your ASC’s safety plan will likely be a key document. Your safety plan should contain the following ele-


ments: purpose of plan; mission; em- ployee competency; safety policies; ASC risk for exposure to unsafe work- ing conditions; handling of hazardous material and spills; sharps safety and use of sharps safety devices; required OSHA training such as bloodborne pathogen exposure; personal protec- tive equipment; lifting; responsibili- ties of the safety officer and leader- ship team; employee responsibilities; expected outcomes; internal and ex- ternal disasters and life safety equip- ment. Because each ASC has a unique environment, other elements should be included in your plan as well. In addition to the safety plan, an ASC should have a plan for managing ex- posure to bloodborne pathogens. The policies and procedures that an OSHA surveyor might ask to review


20 ASC FOCUS NOVEMBER/DECEMBER 2012


during the survey include bloodborne safety tracking and exposure follow-up; hazardous waste handling and disposal; sharps safety; spills; exposure to chemi- cals; transportation of hazardous equip- ment and instruments; traffic pattern; eye wash stations; personal protective equipment; eating and drinking in ap- propriate areas; use of safety devices; immunization records of employees, physicians and allied health staff; fire drills; your ASC’s evacuation plan for fire and other disasters; smoke evacu- ation and trace gas testing. Ensuring that these policies are up to date and survey-ready is an essential element in an OSHA survey. Employee education is another key element in these surveys. Make sure that all of your ASC’s employees un- dergo OSHA training annually and that there is documentation in every employee’s file indicating that they have completed that education and re- lated competency testing.


Survey Process OSHA surveys are unannounced. Prepare your staff on the proper pro- tocol to follow when a surveyor ar- rives at your center. Who does the employee notify when a surveyor ar- rives at your facility? Who in lead- ership should greet the surveyor and escort him or her to an office or con- ference room where proper introduc- tions and an opening conference can take place? During the opening con- ference, the surveyor should discuss what he or she plans to review and observe in your facility. Helping the survey process run


smoothly will be in the best inter- est of your ASC. Assign someone to obtain all of the documents that the surveyor has identified for review. Determine who will be responsible for accompanying the surveyor on a tour of the center. Make sure the per- son assigned to tour with the surveyor has the knowledge needed to answer


For more information, visit www.ascassociation.org/ASCA2013.


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