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OSHA Compliance Checklist for Medical Offices

A one-page checklist of the OSHA requirements that apply to most medical offices and med spas, grouped the way an inspector would look at them. Mark what applies, what's done, and where the proof is kept.

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OSHA Compliance Checklist for Medical Offices

MedSpaBinder

Clinic

Number of employees

Checked by / date

Covers federal OSHA. States that run their own OSHA plans can add rules. Mark N/A for anything that doesn't apply.

Requirement
Applies (Y/N)
Done (Y/N)
Date
Evidence / where kept
Posting and injury records
OSHA "It's the Law" poster displayed
Report: death in 8 hrs; hospitalization, amputation, eye 24 hrs
OSHA 300 injury log kept (if required)
Bloodborne pathogens (1910.1030)
Written exposure control plan, reviewed every year
Hepatitis B vaccine offered; declinations signed
Training at hire and every 12 months; records kept 3 years
Sharps containers, safer sharps and PPE provided free
Post-exposure provider and steps in place
Hazard communication (1910.1200)
Written hazard communication program
List of hazardous chemicals; safety data sheets at hand
Containers labeled; staff trained on the chemicals used
Emergencies and fire (1910.38, .39, .157)
Emergency action plan (in writing if more than 10 staff)
Fire prevention plan (in writing if more than 10 staff)
Exits marked and kept clear
Extinguishers: monthly look, yearly service, staff trained
Eyewash where corrosive chemicals are used (1910.151)
PPE (1910.132)
Written hazard assessment certification for PPE
Good practice (no specific OSHA standard)
Laser safety program (ANSI Z136.3), if you use lasers
Cords, outlets and equipment in good repair
Reviewed by (initials)

Next review due: ____________ Reviewed by: ______________________

Which OSHA rules apply to a medical office or med spa?

Most of what OSHA expects from a small clinic comes from a handful of standards. The Bloodborne Pathogens Standard is the big one for anyone who handles needles or blood. Hazard Communication covers the disinfectants, peels and other chemicals you keep. Emergency action and fire prevention plans, exit routes and fire extinguishers cover emergencies. The personal protective equipment standard asks for a written hazard assessment, and the recordkeeping rules cover injuries.

OSHA doesn't publish one "medical office manual" that you fill in. Your written programs (exposure control plan, hazard communication program, and emergency and fire plans) plus your training and injury records are the manual an inspector will ask to see.

What changes for small offices

  • With 10 or fewer employees, the emergency action plan and fire prevention plan may be communicated orally instead of in writing.
  • Employers with 10 or fewer employees all last year, and businesses in partially exempt industries (the list includes offices of physicians and personal care services), don't have to keep the OSHA 300 injury log unless OSHA asks them to.
  • Every employer, however small, must report a work-related death within 8 hours, and an in-patient hospitalization, amputation or loss of an eye within 24 hours.
  • The Bloodborne Pathogens and Hazard Communication standards have no small-employer exemption.

How to use this checklist

  • Mark each line as applying or not, then whether it's done, and write where the proof is kept: a binder tab, a shared folder, or the wall the poster is on.
  • Work through the gaps one section at a time, starting with bloodborne pathogens if your staff use needles.
  • Review the checklist once a year, when your exposure control plan is due for its annual review.

Questions

Is there a free OSHA manual for medical offices?

OSHA doesn't publish a single required manual. What you need is your own set of written programs and records: an exposure control plan, a hazard communication program, emergency and fire plans (written if you have more than 10 staff), and training and injury records. Our free exposure control plan template covers the biggest one.

How often does OSHA require bloodborne pathogens training?

When someone first starts tasks with exposure to blood, and at least every 12 months after that, within one year of their previous training. Training records must be kept for 3 years.

Sources

General guidance, not legal or medical advice. Requirements vary by state; follow your medical director and product labels.