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OSHA training to all of their employ- ees on an annual basis and document- ing that the training took place, Trimas says. “This includes all of the compo- nents of OSHA, which is more than just bloodborne pathogens. Some people think that the only thing you have to provide is bloodborne pathogen train- ing, but you have to also provide train- ing, especially to the clinical folks, on biomedical waste management, per- sonal protective equipment (PPE) and incident reporting as well.” To ensure that your team receives its annual OSHA training, Trimas advises ASCs to perform the training at the same time every year. “What happens is you hire employees at different times of the year, so lapses are more likely to occur,” he says. “I think it is a good idea for organizations to provide the annual training the same time each year, even for someone who may have started mid- way through the year. Even though it’s now early for them to receive training again, go ahead and get them on your annual schedule so they’re consistent with everyone else.”

While the annual training date for

the entire team should occur around the same time annually, Trimas says new employees should be trained on OSHA within 30 days of hire. “If you decide everyone will receive their training in February and you hired someone in January, there’s no harm in having them go through the initial training and then the annual training to make it consis- tent,” he says. “I think it makes it easier to put everybody on the same schedule. This way, you don’t miss people, which could easily become a problem for large organizations. With such organizations, it may not be possible to get everyone on one day, but if you pick a particular month to get it done, you’re less likely to miss somebody.” Dean says training should be pro-

vided by a member of the staff ap- pointed to serve as an ASC’s exposure control officer. “This would be a person

Some people think that the only thing you have to provide is bloodborne pathogen training, but you have to also

provide training, especially to the clinical folks, on biomedical waste management, personal protective equipment (PPE) and incident reporting as well.”

—Scott J. Trimas, MD, AAAHC Surveyor

interested in learning about this role and capable of providing training and leading activities with the staff,” she says. “And when they do the training, whether it’s through the use of film or a presentation, it needs to be interactive. There should always be time set aside for when the staff can discuss what they have learned.” While ASCs may think that the best

place to keep documentation about an- nual training is in each staff member’s personnel file, Trimas says otherwise. “When OSHA comes in and does their inspections, the best thing to do is to make sure that you have a dedicated OSHA manual with your documenta- tion of your annual training of your em- ployees and staff,” he says. “This way, you can show them this manual rather than having to pull all of your personnel files and show them that way.” ASCs should also keep the initial and annual exposure determination in this manual, Dean says. An exposure determination is the process through which an ASC determines the risk ex- posure level for staff members. “ASCs need to analyze whether a staff member

is at a low, medium or high risk of ex- posure—that’s a requirement,” she says. “You’re looking at the different tasks the staff person performs and determining what could expose them to potentially infectious body fluids or chemicals. For example, the receptionist and her du- ties would usually be low risk, whereas someone working in the operating room (OR) would be the highest risk. This is usually documented on a form, and OSHA now wants this form to be in the ASC’s exposure control workbook.”

Sharps Safety Program Sharps safety in ASCs is a significant area of focus for OSHA, says Gayle Evans, RN, president of ASC consult- ing firm Continuum Healthcare Con- sultants in Kennesaw, Georgia. This became even more apparent when, in April 2011, OSHA announced a new program to reduce the number of needlestick and sharps injuries. During this program, which ended September 30, 2012, OSHA visited a sample of facilities in southeastern states and re- viewed the processes and programs they had in place to protect workers from


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