A Medical Office Safety Manual provides written occupational safety and health programs, procedures, and responsibilities for physician offices, medical practices, outpatient clinics, specialty practices, urgent-care offices, diagnostic practices, and other outpatient medical workplaces.
Medical office employees may work with blood and other potentially infectious materials, needles and other sharps, patient specimens, disinfectants, hazardous chemicals, medical waste, oxygen and compressed gases, sterilization equipment, X-ray equipment, medications, laboratory materials, and other potential workplace hazards.
Employees may also be exposed to infectious diseases, respiratory hazards, ergonomic hazards, slips and falls, workplace violence, electrical hazards, radiation, hazardous drugs, and other exposures associated with the medical services provided.
Because medical practices vary considerably in size and services, the safety manual should reflect the procedures performed, employee job classifications, equipment used, chemicals present, medications handled, diagnostic procedures, laboratory activities, and employee exposures actually present.
The contents of a Medical Office Safety Manual should reflect the practice’s actual operations.
A primary-care physician’s office may need a different combination of programs than an urgent-care clinic, dermatology practice, oncology office, orthopedic practice, diagnostic clinic, or specialty practice performing minor surgical or laboratory procedures.
Depending on operations, the manual may address:
Programs should be selected according to the work actually performed, hazards present, equipment used, and applicable safety requirements.
An effective Medical Office Safety Program establishes responsibilities and procedures for identifying workplace hazards, preventing occupational exposures, safely handling sharps and specimens, controlling chemical and respiratory hazards, providing appropriate PPE, and correcting unsafe conditions.
Management should provide employees with the equipment, safeguards, training, PPE, and resources necessary to perform their assigned work safely.
Physicians, managers, supervisors, and other designated personnel should:
Employees should follow established procedures, use required engineering controls and PPE, report unsafe conditions, and immediately report occupational exposure incidents.
Medical-office operations should be evaluated to identify biological, chemical, ergonomic, physical, and other workplace hazards.
Hazard assessments may consider:
Assessments should be reviewed when procedures, equipment, chemicals, medications, technology, or workplace conditions change significantly.
Periodic safety inspections can help identify unsafe conditions and verify that established procedures are being followed.
Inspections may include:
Identified deficiencies should be documented and corrected in a timely manner.
A Job Safety Analysis (JSA/JHA) may be useful for selected medical-office tasks where a step-by-step hazard analysis can improve employee protection.
Potential JSAs/JHAs may address:
Routine clinical procedures may be more appropriately addressed through clinical protocols, exposure-control procedures, and established work practices rather than creating a JSA for every medical procedure.
Medical office employees with occupational exposure to blood or other potentially infectious materials should be protected according to applicable Bloodborne Pathogens requirements.
Potential exposure may occur during:
The Bloodborne Pathogens Program should address applicable exposure determination, engineering controls, work-practice controls, PPE, housekeeping, Hepatitis B vaccination, post-exposure evaluation, employee training, and recordkeeping.
Medical practices with employees who have occupational exposure should maintain an Exposure Control Plan.
The plan should address applicable:
The Exposure Control Plan should be reviewed and updated as required.
The employer should identify employees who have reasonably anticipated occupational exposure to blood or OPIM while performing their assigned duties.
Potentially exposed employees may include:
Employees should be evaluated according to their actual duties rather than simply their job title.
Administrative employees without occupational exposure should not automatically be included solely because they work in a medical office.
Universal Precautions should be observed to prevent contact with blood and other potentially infectious materials.
Applicable blood and OPIM should be treated as potentially infectious regardless of a patient’s known or perceived infection status.
Employees should use required engineering controls, work-practice controls, and PPE.
Engineering controls should be used to eliminate or minimize occupational exposure where feasible.
Depending on the procedures performed, controls may include:
Engineering controls should be examined and maintained or replaced as necessary to ensure their effectiveness.
Medical offices should identify, evaluate, and implement appropriate safer medical devices when required.
The evaluation should reflect the procedures performed and devices used by the practice.
Employees responsible for direct patient care should be involved in identifying, evaluating, and selecting effective engineering controls where required.
Needles, lancets, scalpels, suture needles, and other contaminated sharps can expose employees to bloodborne pathogens.
Employees should:
Sharps-safety procedures should be incorporated into employee training.
Contaminated needles should not be bent, recapped, or removed except when permitted by applicable requirements.
When recapping or removal is necessary for a specific procedure and no feasible alternative exists, an appropriate mechanical device or one-handed technique should be used.
Employees should receive instruction on the approved method.
Sharps containers should be appropriate for the materials being discarded and positioned for convenient employee use.
Containers should be:
Containers should be replaced before overfilling creates an additional hazard.
Employees with occupational exposure should be offered Hepatitis B vaccination according to applicable requirements.
The vaccination should be made available within the required timeframe following initial assignment unless an applicable exception exists.
Employees who decline vaccination should complete required declination documentation.
Employees who initially decline may later request vaccination while remaining occupationally exposed.
Needlesticks, cuts from contaminated sharps, splashes to mucous membranes, and other qualifying occupational exposures should be immediately reported.
Procedures should address:
Employees should understand the importance of prompt reporting.
Following a qualifying exposure incident, the employer should provide confidential medical evaluation and follow-up according to applicable requirements.
Required information should be provided to the evaluating healthcare professional.
The employee should receive required information concerning the results of the evaluation.
Medical information should be maintained confidentially.
Employees collecting or handling blood and other patient specimens may be exposed through sharps, leaking containers, splashes, broken containers, or contaminated surfaces.
Procedures should address:
Employees should minimize unnecessary handling of specimens.
Specimens should be placed in appropriate containers that prevent leakage during collection, handling, processing, storage, transport, or shipping as applicable.
Employees should follow established procedures when primary containers are contaminated externally or become damaged.
Medical practices performing laboratory testing should evaluate the hazards associated with their specific laboratory activities.
Potential hazards may include:
Laboratory safety procedures should reflect the tests and processes actually performed.
Employees operating centrifuges should follow manufacturer instructions and established procedures.
Procedures may address:
Employees should not open or service equipment in a manner that exposes them to moving components or contaminated materials.
Medical office employees may encounter patients with communicable diseases.
The practice should evaluate foreseeable employee exposures and establish appropriate infection-prevention and occupational safety procedures.
Controls may include:
The measures used should reflect the diseases, services, and exposures reasonably anticipated in the practice.
Medical office employees may encounter infectious aerosols, airborne contaminants, hazardous chemicals, or other respiratory hazards depending on the services provided.
The employer should evaluate respiratory hazards and determine appropriate controls.
Controls may include:
When respirators are necessary to protect employees from occupational respiratory hazards, an appropriate Respiratory Protection Program should be established.
Applicable requirements may include:
Employees required to use tight-fitting respirators should complete applicable medical evaluation and fit-testing requirements before required use.
Employees should understand the difference between a face mask used for source control or splash protection and a respirator used to protect the wearer from applicable inhalation hazards.
A surgical or procedure mask should not automatically be treated as equivalent to an appropriate respirator.
Respiratory protection should be selected according to the identified occupational hazard.
PPE should be selected based on the employee’s assigned tasks and anticipated exposures.
Depending on the work performed, PPE may include:
PPE should be appropriately selected, maintained, used, removed, and disposed of or decontaminated.
Appropriate gloves should be used when hand contact with blood, OPIM, hazardous chemicals, or other identified hazards is reasonably anticipated.
Disposable gloves should be replaced when torn, punctured, contaminated, or when their ability to function as a barrier is compromised.
Disposable gloves should not be washed or decontaminated for reuse.
Alternative glove materials should be available where necessary.
Employees should use appropriate eye and face protection when procedures may generate splashes, sprays, droplets, or flying particles.
Protection may include:
Protection should be selected according to the anticipated hazard.
Protective clothing should be appropriate for the task and anticipated exposure.
Depending on procedures, this may include gowns, laboratory coats, clinic jackets, or other protective garments.
Contaminated protective clothing should be removed and handled according to established procedures.
Medical offices using hazardous chemicals should maintain an appropriate Hazard Communication Program.
The program should address applicable:
Employees should understand how to obtain and use Safety Data Sheets.
Medical offices may use disinfectants, cleaners, laboratory reagents, specimen preservatives, sterilants, and other hazardous substances.
Employees should:
Disinfectants and cleaning chemicals should be used according to manufacturer instructions and established procedures.
Employees should understand applicable:
Employees should not mix chemical products unless specifically instructed and authorized to do so.
Medical offices using chemical sterilants or high-level disinfectants should evaluate potential employee exposures.
Procedures should address:
The safety program should reflect the specific products actually used.
Practices using formaldehyde or formaldehyde-containing solutions for specimen preservation or other purposes should evaluate employee exposure and applicable regulatory requirements.
Controls may include:
Formaldehyde requirements should not be included in practices where the chemical is not present.
Medical practices that receive, prepare, administer, or dispose of hazardous drugs should evaluate occupational exposure.
Potentially affected practices may include oncology, specialty infusion, and other medical settings.
Controls may address:
Hazardous-drug procedures should reflect the drugs and tasks actually present in the practice.
Employees should know how to respond to foreseeable chemical spills.
Procedures should identify:
Employees should not attempt to clean a spill beyond their training or available protective equipment.
Medical office employees may handle ordinary trash, regulated waste, contaminated materials, sharps, pharmaceuticals, and other wastes.
Procedures should distinguish among the different waste streams and identify appropriate handling methods.
Employees should:
Regulated waste associated with blood or OPIM should be handled and contained according to applicable requirements.
Containers should be appropriate for the materials being discarded.
Employees should receive training on which materials are considered regulated waste and how they should be handled.
Medical practices generating pharmaceutical waste should establish appropriate procedures for segregation, storage, handling, and disposal according to applicable requirements.
Employees should not dispose of medications or hazardous pharmaceutical waste through ordinary waste streams when prohibited.
Medical offices that reuse instruments should establish procedures for safe transport, cleaning, disinfection, sterilization, and storage.
Employees may be exposed to:
Appropriate engineering controls, work practices, and PPE should be used.
Sterilizers and autoclaves can expose employees to heat, steam, hot surfaces, and pressurized equipment.
Employees should:
Only appropriately instructed employees should operate sterilization equipment.
Medical offices using oxygen should establish procedures for safe storage, handling, and use.
Oxygen can accelerate combustion.
Employees should:
Compressed gas cylinders should be appropriately secured, stored, handled, and protected from damage.
Employees should use appropriate regulators and connections.
Cylinder valves should be protected from impact or other conditions that could cause uncontrolled release.
Only appropriately trained or authorized employees should change regulators or perform other specialized tasks.
Medical practices using anesthetic gases should evaluate potential employee exposure.
Applicable controls may include:
These procedures should be included only when anesthetic gases are actually used.
Medical practices using X-ray or other radiation-producing equipment should establish appropriate employee-safety procedures.
Procedures may address:
Employees should follow established radiographic safety procedures.
Specialty practices using medical lasers should evaluate potential eye, skin, fire, plume, and electrical hazards.
Controls may include:
The safety program should reflect the type and class of laser equipment used.
Electrical equipment, cords, plugs, receptacles, and panels should be maintained in safe condition.
Employees should not use damaged electrical equipment.
Electrical panels should remain appropriately accessible.
Employees should report equipment that shocks, sparks, overheats, or otherwise operates abnormally.
Only qualified or otherwise authorized personnel should perform electrical work requiring specialized knowledge or training.
Medical offices should maintain examination rooms, corridors, laboratories, waiting areas, procedure rooms, and other walking-working surfaces in safe condition.
Potential hazards include:
Temporary hazards should be promptly corrected or appropriately protected.
Floors, stairs, ramps, walkways, and other walking-working surfaces should be maintained in safe condition.
Equipment, supplies, waste, carts, and other materials should not unnecessarily obstruct employee travel or required exit routes.
Employees should promptly report damaged flooring or other unsafe conditions.
Work areas should be maintained in an orderly and sanitary condition.
The practice should establish appropriate procedures for cleaning and decontaminating surfaces and equipment.
Housekeeping procedures should distinguish between:
Employees should receive appropriate training for the cleanup activities assigned to them.
Where employees may be exposed to corrosive materials requiring immediate flushing, suitable emergency washing facilities should be available as required.
Access should remain unobstructed.
Employees should understand the location and proper use of emergency washing equipment.
Medical office employees may perform repetitive computer work, prolonged standing, patient positioning, material handling, and other tasks that create ergonomic stress.
Potential controls may include:
Employees should report persistent musculoskeletal symptoms.
Some medical offices may require employees to assist patients with transfers, positioning, mobility, or examinations.
The practice should evaluate tasks involving significant patient-handling demands.
Employees should use available assistance, equipment, and appropriate techniques rather than attempting patient-handling tasks that exceed their capabilities.
Medical office employees may interact with distressed, angry, intoxicated, cognitively impaired, or otherwise unpredictable patients and visitors.
Workplace violence procedures should reflect the practice’s actual risk factors.
Controls may address:
Employees should prioritize personal safety when confronted by threatening behavior.
Employees should understand how to respond when a patient, family member, or visitor becomes verbally abusive, threatening, or physically aggressive.
Employees should:
Employees working alone during opening, closing, after-hours procedures, laboratory work, or other activities may face increased risk during medical, security, or workplace-violence emergencies.
Where employees work alone, procedures should address communication and access to emergency assistance.
Higher-risk tasks should be evaluated to determine whether working alone is appropriate.
Security procedures should reflect the practice’s location, patient population, hours, staffing, and previous incidents.
Measures may include:
Security controls should support employee safety without unnecessarily interfering with emergency egress.
Fire-prevention procedures should address the hazards present within the medical practice.
Potential considerations include:
Fire extinguishers and other fire-protection equipment should remain accessible.
Employees should understand procedures to follow during foreseeable medical-office emergencies.
The Emergency Action Plan may address:
Employees should understand alarm methods, exit routes, assembly locations, emergency communication procedures, and assigned responsibilities.
Medical offices should establish procedures for foreseeable patient and employee medical emergencies.
Employees should understand:
Employees should perform only those emergency-response activities for which they are appropriately trained and authorized.
The practice should maintain appropriate procedures for obtaining prompt medical assistance for employee injuries.
Employees should understand how to report workplace injuries and obtain necessary care.
Occupational exposure incidents involving blood or OPIM should be handled according to Bloodborne Pathogens procedures rather than solely as ordinary first-aid events.
Medical offices may use outside contractors for equipment service, electrical work, HVAC maintenance, cleaning, construction, renovation, waste handling, and other specialized work.
Contractor activities should be coordinated to protect employees, patients, and visitors.
Relevant hazard information should be exchanged when required.
Safety training should reflect each employee’s assigned duties and occupational exposures.
Depending on the practice, training may address:
Training should be provided at required intervals and whenever changes in tasks, procedures, equipment, or exposures make additional training necessary.
New employees should receive appropriate safety orientation before independently performing work that exposes them to workplace hazards.
Orientation may address:
Employees should receive task-specific training before performing specialized work.
Periodic safety meetings can reinforce safe work practices and address current workplace concerns.
Potential topics include:
Medical practices should maintain occupational safety and health records required for their operations.
Records may include:
Confidential employee medical information should be maintained according to applicable requirements.
Depending on medical-office operations, additional safety programs may be necessary for:
These programs should be included when employee activities or workplace hazards make them applicable rather than automatically adding programs unrelated to the practice’s operations.
A useful Medical Office Safety Manual should reflect the actual practice rather than simply combining generic healthcare policies.
A primary-care office may require a different combination of programs than an urgent-care clinic, oncology practice, dermatology office, orthopedic practice, diagnostic clinic, or other specialty medical practice.
The manual should consider:
Selecting the appropriate programs creates a manual that is comprehensive without filling it with procedures unrelated to the medical practice.
A Medical Office Safety Manual can be developed around the specific procedures, employee exposures, equipment, chemicals, medications, diagnostic services, laboratory activities, and other hazards of the practice.
The finished manual may incorporate applicable programs for Bloodborne Pathogens, sharps safety, exposure incidents, infectious disease, Respiratory Protection, Hazard Communication, PPE, medical waste, compressed gases, radiation, workplace violence, emergency procedures, and other hazards present within the operation.
This provides medical employers with a practical safety manual organized around the work their employees actually perform.