The beginning of a new year is always a great time to make resolutions, but it's also a great time to reflect on the activities of the previous year. Looking back at publicly available Occupational Safety and Health Administration (OSHA) inspection findings can help your laboratory be aware of the standards that OSHA is assessing during inspections and ensure that your facility has established processes in place to meet the safety requirements. Federal OSHA and State OSHA programs publish information on the inspections that they conduct, including the number of inspections, number of citations issues, and the penalties associated with the citations (the penalties published reflect current rather than initial amounts). The recently published data reflects the inspection information associated with the period of October 2016 through September 2017 (fiscal year).
To help understand how all businesses are categorized, the North American Industry Classification System (NAICS) groups similar businesses into specific classification codes. So, if we want to look at OSHA inspection information for health care businesses, we would search for the “Health Care and Social Services Assistance” category in NAICS using Code 62. If we want to get even more specific and look at laboratories, we would search for “Medical and Diagnostic Laboratories” that are categorized in NAICS using Code 6215.
The OSHA citations for these categories, and those for other NAICS codes, are available on the OSHA web page Frequently Cited OSHA Standards and include search criteria for the number of employees in the establishment, Federal or State Jurisdiction, and NAICS code. Some states have their own OSHA programs, and the inspection information for those states is also available by selecting the specific state. Below are links to the latest inspection information for the federal and Minnesota findings for Health Care and Social Services and also Medical and Diagnostic Laboratories:
- OSHA citations for fiscal year for NAICS Code 62: Health Care and Social Assistance
- OSHA citations for fiscal year for NAICS Code 6215: Medical and Diagnostic Laboratories
- Federal Data
- Minnesota Data (no published data)
The following table is from the website with the Federal Data for Medical and Diagnostic Laboratories (NAICS Code 6215), and it shows (in descending order for the number of citations) the totals and specific breakdown by OSHA standard, number of citations and inspections, and the current penalty for the citations issued. There is also a link to each of the OSHA standards listed so that you can review the requirements:
Federal OSHA Citations for Medical and Diagnostic Laboratories
(October 2016 through September 2017):
|Total||30||12||$86,061||All standards cited for medical and diagnostic laboratories|
|1910.0147||5||1||$26,880||The control of hazardous energy (lockout/tagout)|
|1904.0039||1||1||$0||No description found|
|1910.0111||1||1||$3,549||Storage and handling of anhydrous ammonia|
|1910.0133||1||1||$4,617||Eye and face protection|
|1910.0305||1||1||$3,500||Wiring methods, components, and equipment for general use|
It is not surprising that for laboratories, the "Bloodborne Pathogen" standard was the most frequently cited standard for the last fiscal year, and it’s also the number one citation for businesses in the Health Care and Social Assistance classification.
I did some digging and found some resources on OSHA citations as well as compliance guidance for the Bloodborne Pathogens standard and information on the General Duty Clause. I hope you get a chance to look through some of the information; it is very interesting.
For your reading pleasure on OSHA citations:
- OSHA’s Top 10 Most Cited Violations for 2016
- OSHA’s Top 10 Most Cited Violations for Fiscal Year 2017
- Q & A with OSHA’s Patrick Kapust
- OSHA's Top 10 Most Cited Violations
- Fall Protection Leads OSHA’s "Top 10" List of Most Frequently Cited Violations
- OSHA's Top 10: The More Things Change . . .
- OSHA's Top 10: Present and Past
- Quick Reference Guide to the Bloodborne Pathogens Standard
- OSHA Fact Sheet Bloodborne Pathogens Standard
- Most Frequently Asked Questions Concerning the Bloodborne Pathogen Standard
- Model Plans and Programs for the OSHA Bloodborne Pathogens and Hazard Communication Standards
- Information for Employers Complying with OSHA’s Bloodborne Pathogens Standard
General Duty Clause: