The OSHA Standards: Overview of COM/OHS Plans and Mandatory Training Programs

 (updated 07/30/06)

 

 

The Occupational Safety & Health Administration (OSHA) standards are a series of safety regulations documented in State Bill #308. OSU has been required to comply with the OSHA standards since 1994. An OSHA Coordinator has been appointed by the COM to work with OSU Environmental Health and Safety (EH&S) to bring the College into compliance with the standards. Each department/Center and Institute has appointed a Safety Representative to assist with the administration of safety documents and record keeping. In addition, each COM building has a Building Emergency Coordinator (BEC) and Floor Evacuation Coordinators (FECs) who are responsible for maintaining lists of floor occupants and assisting emergency personnel. Safety issues and training for hospital employees remain with the OSUMC Safety Department.

 

In most cases, each OSHA standard consists of a modifiable safety plan accompanied by a non-modifiable appendix and tables. EH&S (1314 Kinnear Road, 2-1284) writes the safety plans based on the original OSHA standards. These documents are fairly general as they are written to cover all colleges and departments. In the College of Medicine, the template plans are modified by the OSHA Coordinator to reflect particular local requirements. For example, the COM/OHS Laboratory Standard/Chemical Hygiene Plan documents have been modified to reflect the more stringent accreditation requirements of the Medical Center. These modified plans must be used in research laboratories in both College and Medical Center buildings (see 'Lab Standard Documents'). The template plan on the EH&S website, or plans from other departments/colleges, may not be substituted for the COM/OHS plan.

 

Four of the OSHA standards, Hazard Communication, Laboratory Standard/CHP, Bloodborne Pathogens and Emergency Operations and Evacuation (EOEP; ‘Building Safety’) Standards, are of particular relevance to the College of Medicine. Each has mandatory training requirements that involve one or more levels of training; all training must be recorded:

 

Generic (Legal and general aspects, online at the EH&S training website)

Specific (Hazards specific to the workplace, given by the PI or supervisor yearly)

Follow Up (New hazards in the workplace, ongoing by the supervisor)

 

A. Hazard Communication Standard. The Haz Com Plan (document) is generated and maintained by each academic department. It covers all faculty, staff and paid students. This "umbrella" plan is updated annually and is maintained in the main department office. All non-research laboratory employees must train under this standard.

 

1. Generic HazCom Training. This requirement may be fulfilled by taking one of the following modules:

 

(i) Generic HazCom/Lab Std training. A one-time only, one-hour class given monthly at the Office of Environmental Health and Safety (EH&S) at 1314 Kinnear road (2-1284), and four times a year in the College of Medicine.

OR

(ii) Online Haz Com for non-laboratory (clinical) research areas (EH&S Training website).

OR

(iii) FOR OFFICE STAFF ONLY: ‘Plain Talk’ or ‘MD Plain Talk’ training and self-test package. See your departmental Safety Representative.

AND

2. Work Place-Specific Training: Employees in each work area (for example, office, shops) must receive ANNUAL training on hazards in the immediate work area. This workplace-specific training is to be given by the supervisor, or designee. Training records are to be maintained in the work area and must be made available for inspection. Follow-up training should be given when new hazards enter the workplace.

 

 

(B) Laboratory Standard. Each COM/OHS PRINCIPAL INVESTIGATOR in assigned research laboratory space must generate a Chemical Hygiene Plan. This plan must be modified to reflect chemical and operational hazards in his/her lab and must be updated annually. Faculty/PI is the Chemical Hygiene Officer (CHO) for his own lab. All PIs and research laboratory employees must train under this standard. Training requirement may be fulfilled as follows:

 

OSHA Lab Standard/Chemical Hygiene Training:

(i) 'Generic HazCom/Lab Std training'. One time, 1 hour class, monthly at EH&S (2-1284).

(ii)   Online  Lab Standard Training. EH&S training site

AND

 

Lab-Specific Training: Employees in research laboratories must receive ANNUAL training on Standard Operating Procedures (SOPs) for hazards in their labs and shared space. This lab-specific training is given by the Principal Investigator or designee. An Employee Acknowledgement Form (EAF) is completed for each lab-member. Standard Operating Procedures should be listed on the form. The EAFs for the current year must be kept with the Chemical Hygiene Plan. Follow-up training should be given when new hazards (chemical/equipment) enter the workplace.

 

 

(C) Blood Borne Pathogens (BBP) Standard: All COM/OHS employees (research, administrative, clinical) who are likely to come into repeated contact with human and/or primate bloodborne pathogens fall under this standard (see Institutional Biosafety Manual and OSUMC Infection Control Manual).

 

Bloodborne Pathogens Training. This ANNUAL requirement may be fulfilled by:

 

(i)                   'Generic Bloodborne Pathogens Training', a one-hour class given monthly at EH&S

(ii)                 Online  Bloodborne Pathogens Training. EH&S training website

 

AND

 

For those in clinical research areas in OSUMC buildings the 'Infection Prevention Education and Self-Test’ CBL must be completed annually

AND

 

(iii) Lab-Specific Biohazard Training: Employees in research laboratories using human/primate BBPs must receive ANNUAL training on hazards in the immediate work area. This workplace-specific training is to be given by the Principal Investigator/Faculty member to whom the space is assigned, or his/her designee. Current records of specific training (Employee Acknowledgement Form) should be kept at the front of the Institutional Laboratory Biosafety Manual in the laboratory. A list of training topics (for example, SOPS) should be listed on the form.

 

(D) Emergency Operations and Evacuation Plan (EOEP) (“Building Safety”): Occupants of College of Medicine Buildings (plus Means and Starling Loving) fall under this Standard. The EOEP plan (EOEP/Building Safety section of this website) outlines the duties of building occupants, Building Emergency Coordinators and Floor Evacuation Coordinators in several emergency situations. The training requirement may be fulfilled by Taking the Online  EOEP (Building Safety) Training on the EH&S training website

 

Records of attendance at all Generic Safety Training are maintained on line on the ’Training Records’ section of this website. The departmental Safety Representative should maintain a spreadsheet containing training requirements and completions dates for all employees. This record must be made available for inspection by local and/or state inspectors. Records should include employee name and university ID number, date of training, type of training, and instructor.