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Clinician checking labelled stock on clinical shelving

OSHA standards

The OSHA standards that apply to a medical office.

A physician, dental or podiatry practice is subject to a defined set of general industry standards. These are the ones that come up in nearly every inspection we attend.

Core standards

Standard by standard, what your office must have.

Each entry lists the citation, what the standard requires in practice, and the documentation an inspector will ask to see.

Bloodborne pathogens — 29 CFR 1910.1030
A written exposure control plan reviewed and updated at least annually and whenever tasks change. Requires an exposure determination by job classification, documented consideration of safer sharps devices with frontline employee input, the hepatitis B vaccination series offered within ten working days of assignment at no cost, a signed declination form where refused, a sharps injury log, and annual training.
Hazard communication — 29 CFR 1910.1200
A written programme, a current inventory of every hazardous chemical on the premises, a safety data sheet immediately accessible for each one, GHS-compliant labels on primary and secondary containers, and employee training on pictograms, signal words and the SDS format.
Personal protective equipment — 29 CFR 1910.132
A documented hazard assessment certifying which PPE each task requires, employer-provided equipment at no cost to the employee, and training in selection, donning, doffing, limitations and disposal. Eye and face protection falls under 1910.133, hand protection under 1910.138.
Respiratory protection — 29 CFR 1910.134
Where respirators are required, a written programme, medical evaluation before fit testing, annual fit testing for tight-fitting facepieces, and training. Directly relevant to any practice screening for or treating tuberculosis or other airborne infectious disease.
Tuberculosis exposure control
OSHA enforces TB protection through the General Duty Clause, Section 5(a)(1), together with CDC guidelines. Expect to show a risk assessment for your setting, a screening protocol, and airborne precautions appropriate to that risk level.
Ionizing radiation — 29 CFR 1910.1096
Applies to practices with radiographic equipment. Requires restricted area posting, personnel dosimetry where doses may exceed defined limits, exposure records, and coordination with your state radiation control programme.
Electrical safety — 29 CFR 1910 Subpart S
Covers wiring design and protection, working clearance around panels, grounding of equipment, and the prohibition on daisy-chained power strips and permanent use of extension cords — a common and easily corrected citation in clinical areas.
Fire prevention and means of egress — 29 CFR 1910 Subpart E and 1910.157
A written emergency action plan and fire prevention plan where required, unobstructed and marked exit routes, monthly visual and annual maintenance inspection of portable extinguishers, and employee training on the alarm and evacuation procedure.
Recording and reporting — 29 CFR 1904
Employers with more than ten employees maintain the OSHA 300 log, the 301 incident report and the 300A annual summary, which is posted from 1 February to 30 April. Fatalities are reported within eight hours; in-patient hospitalisation, amputation or loss of an eye within twenty-four hours.

Self-check

Ten questions an inspector may ask on the day.

  • Who is your designated safety officer, and can they produce the written plans?
  • When was your exposure control plan last reviewed, and is the review dated and signed?
  • Which safer sharps devices did you evaluate this year, and which frontline staff took part?
  • Can you produce hepatitis B vaccination records or signed declinations for every clinical employee?
  • Where is the sharps injury log, and is it kept for the required retention period?
  • Show me the safety data sheet for the disinfectant currently in that spray bottle.
  • Is that secondary container labelled with product identifier and hazard information?
  • When did each employee last complete bloodborne pathogens training, and who delivered it?
  • Where is the eyewash station, is it unobstructed, and where is the weekly activation log?
  • Is the OSHA 300A summary posted, and were last year’s records retained?
Clinical team in full personal protective equipment

Most offices that fail an inspection do not fail on practice. They fail on documentation. Get the paperwork right and the rest follows.

Not sure which standards apply to your practice?

That is the first question we answer. A consultation establishes your exact regulatory footprint before anything is written.