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Issue: 62 - Feb 14, 2014
OSHA Updates: February through April OSHA Posting Requirements And Other Winter Tidbits
By: Chery F. Kendrick, DVM, MPVM, MLT, CFS
Kendrick Technical Services, LLC

February burst on the scene this year with a deep freeze, more snow and the wonderful groundhog prognosticator. It also led to that sudden sinking feeling that there was yet another form, some OSHA form that needed to be posted. Ah yes that OSHA 300A Summary of Illnesses and Injuries form. That’s what we had forgotten!

While we scramble to figure it all out, we often end up just letting it go as it is ‘too much work’ and we are always easily distracted from onerous OSHA tasks by the next patient.

Fear not - it really is simple - but do not let complacency win this year especially, as it is more likely than ever that OSHA will pay YOUR clinic a visit. If you have NOT posted the form 300A then you will be in for a $1,500 fine at the minimum. One quick fact that may exempt you from this form: Only required if at any time during 2013 you had ten or more employees.

So let’s look at simple solutions to this 300A form.

First What Is the Dreaded 301A form: OSHA Form 300 A is the “Summary of Work-Related Injuries and Illnesses” form.

It is simply that: a summary of any injuries or occupationally related illnesses that your employees suffered the previous year.

It is an ‘in-house’ form - meaning we don’t send it off to anyone. However we Must post it so all employees know what injuries have occurred over the last calendar year and more importantly understand why you are going to be discussing this at the next staff meeting.

The whole purpose for this form is to see where the trends are for injuries in the clinic, and hence where we need to have more training.

For example one of my consulting client clinics saw an increase of 13% in bites and scratches so thought it was time to review the animal handling training with the staff.

Another client noted that 89% of all injuries were reported by one employee and so a meeting was set up with the supervisor, employee and safety officer to discuss ways to deal with this.

Paperwork duties can always be looked at as onerous, annoying, time consuming beasts; however, they are an internal gage for you and the management of your practice to ensure safety. I have also found there is usually at least one person on your staff who enjoys this task of looking up injury reports, making the calculations in the worksheet provided then completing the summary form. It is important to remember that even if there were no injuries (congratulations!) you still have to fill in form and post.

So take a look at the forms in the link below, fill in your sheets do your calculations and post the summary, then use this information to open up your OSHA discussion at your next staff meeting.

Click link here for OSHA form and info on filling it out and posting requirements: https://www.osha.gov/recordkeeping/RKform300pkg-fillable-enabled.pdf

So that is the major OSHA concern this February however an update on OSHA inspections: OSHA has picked up there numbers of inspections of veterinary hospitals nationwide. They are finding a lack of GHS training, lack of understanding of SDS changes and for the hospitals that do have my charts in place for secondary containers they are being disappointed by no finables – yes I am giving myself a blatant plug here because it is true and so nice to report that OSHA inspectors have been showing up at my client clinics and walking away empty handed.

The average fine at clinics is running around $35,400 with reduction to $2500 upon appeal.

It is not a game, or at least it should not be, because we do indeed care about safety in the workplace and I am proud of our profession for having some of the safest workplace environments in the country. But since OSHA instituted the adversarial nature into the game of inspections by giving inspectors bonuses for finding violations plus adding the ability to charge fines at the free OSHA inspections- well they have lost what little respect they once had.

So be forewarned - OSHA inspectors are indeed out there.

Here are some additional things they are looking at this winter:

  1. Cold weather plan of safety: what do you do in terms of cold weather and your employees in terms of them walking patients, and most especially ice on walkways and driveways. They are also looking at Emergency Weather plans, for example my manuals for my OSHA consulting client clinics have plans that address protocol for snow days, ice days and frigid temperature days that include getting employees safely to and from work. Several clinics go as far as to list those who have all wheel drive snow tires who are willing to pick others, who may not have a vehicle so equipped, up and take them home. It also needs to include when to close early and who does what in terms of de- icing the property.
  2. OSHA Postings: the new GHS information and Family Medical Leave Act information. Do NOT spend hundreds on posters every tear- simply download and post updated forms or use one of the reasonably priced poster companies- Feel free to email or call me to inquire about the company I use exclusively as their complete laminated full color poster is less than $50.
  3. GHS and SDS training- this is their big moneymaker this year. Too many ignored the December 1, 2013 deadline and the inspectors have increased their inspections simply because this is a no-brainer easy money maker for them. Don’t get caught out- again a plug here – I still have the only Vet Med specific GHS training materials available including the only VetMed specific GHS chart.

Complaint’s filed with OSHA are increasing - all I can say is it is the world we live in - and we still have no teeth to fight with - there is no way we can protect ourselves from these disgruntled employees calling OSHA and causing us headaches in time lost dealing with the inspections and follow up reports and appeals, and money lost in fines if you are not successful in your appeals. So be sure to protect yourself carefully. Once a complaint is filed, you can expect to fight a long battle, providing lots of documentation and wasting a lot of your time, or your practice manager’s time. It is always better to be prepared before an inspection but yes I will represent you after an inspection.

Note not one of my clients have EVER had to pay fines.

So stay safe out there, post your 300A form, get your OSHA plans and training in place and don’t forget the weather safety sections. Before we know it we will have spring storms to be prepared for!

As always please feel free to contact me with any questions or concerns.

Chery

865-405-4255

Chery F. Kendrick, DVM, MPVM, MLT, CFS is a writer, educator, speaker and consultant. She is the nation’s leading veterinary regulatory control and OSHA expert. Her time spent in Washington D.C. as an advocate for the veterinary profession with OSHA and other regulatory agencies has resulted in many positive compliance changes for our industry. Her manuals and training programs are used by clinics and animal care facilities nationwide. She has the only GHS compliance program specifically for the veterinary practice. She speaks at association meetings, and conferences nationwide. Her well attended workshops are constantly praised as powerful resources for practice managers, veterinarians and their staff.

Chery F. Kendrick, DVM, MPVM, MLT, CFS KendrickTechServices.com

Please feel free to contact her @  chery@KendrickTechServices.com with your questions and visit her web site at www.KendrickTechServices.com

For information on Dr. Kendrick’s OSHA manuals, training programs, charts and onsite consulting services please feel free to contact her 24/7 at Kendrick Veterinary Consulting Group 865-405-4255 or chery@KendrickTechServices.com