OSHA requires several documents and written programs to be accessible to all employees.  This includes Material Safety Data Sheets (MSDS), Bloodborne Pathogens, and Permit Required Confined Spaces.  In the past, documents were required to be printed out and stored in a binder.  Frequently, multiple copies needed to be printed for different buildings or locations creating document control problems, like pages being out of order or ripped out by employees.  Other frustrations included outdated documents in circulation, extensive time required to update all the copies, and being known as the “tree killer” when approaching the copy machine. Now that we are well into the digital age, OSHA has thankfully recognized the need for some businesses to shift away from paper.  In a Standard Interpretation Letter dated September 16, 2008, OSHA states that employee access to written programs may be in paper or electronic format.  Where a standard requires that the written program be made available to employees, they must know how to easily access the documents without any barriers.  The program must meet all other requirements of the standard.   

However, it may not be that simple!  An OSHA Letter of Interpretation dated 10/28/1996 states that when computers are used for MSDS access, employees must be trained on how to obtain the information, and the employer must integrate the system into their overall hazard communication program.  This could be a major hurdle for some employers if their workforce is uncomfortable or unfamiliar with computers.   The same letter also states that employers should provide a backup computer system when the main system is down for short periods of time for maintenance, repair, or power disruption.  Providing a backup system to the main computer or printing a hard copy set of MSDS’s before shutting down the system would meet the standard’s intent.  To comply with these requirements, an employer would still be required to print a complete set of MSDS sheets or create a computer system which has an independent power source, such as a generator, and have databases stored on a server and local drive!                     

Allcare Dental’s Nashua, N.H., dental office faces $76,500 in U.S. Labor Department OSHA fines following employee needlestick injury

Allcare Dental has been cited by OSHA for alleged willful and serious violations of occupational health standards at its Nashua, N.H., dental office after an employee suffered a needlestick injury. The office faces $76,500 in proposed fines.

OSHA’s inspection found that the office did not provide the injured employee with no-cost, post-exposure medical evaluation and follow-up, and did not have the blood of the source individual tested, as required under OSHA’s bloodborne pathogens standard.

In addition, the office’s training program did not include the proper method of removing the capped needle from a syringe, did not explain procedures to be followed in the event of an exposure and did not provide an opportunity for employees to ask questions about the training. The office’s exposure control program also was incomplete and not updated annually. Finally, the office did not use needles with engineered safety devices for user protection.

“OSHA standards spell out the steps that an employer must take to safeguard the health of employees whose duties may involve contact with blood or other potentially infectious materials,” said Rosemarie Ohar, OSHA’s area director in Concord. “It’s vital that these safeguards be effectively implemented, communicated and kept up-to-date so that employees and managers know how to both minimize hazards and respond in the event of an exposure.”

OSHA has issued Allcare one willful citation, with a $63,000 proposed fine, for not testing the source individual’s blood for infection even after OSHA notified the office that this was required. OSHA defines a willful violation as one committed with plain indifference to or intentional disregard for employee safety and health.

Six serious citations, with $13,500 in proposed fines, have been issued for not providing the post-exposure evaluation and follow-up; not annually reviewing and updating the exposure control program; training deficiencies; and not using sharps with engineered sharps protection. A serious citation is issued when death or serious physical harm is likely to result from a hazard about which the employer knew or should have known.

OSHA’s Web site provides more in-depth information about bloodborne pathogens and needlestick prevention on a page dedicated to that topic at www.osha.gov/SLTC/bloodbornepathogens.