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How to Set Your Medical Practice Up for Success - Part 1: Training

Kevin Webber - Feb 23, 2018 11:25:25 AM

Proper training is a critical activity for any medical facility, but how do you manage it effectively when you must attend to budget and scheduling pressures daily? Partnering with a compliant local medical waste service provider can be a great way to maintain training requirements, especially when they offer convenient online training solutions.

Nurse-taking-compliance-training-course-on-laptop.jpgFailing to stay on top of your facility’s training requirements can have negative consequences, but just how bad are they? Two of OSHA’s top 10 most frequent reasons for issuing citations are related to improper or incomplete employee training, and fines up to $70,000 mean even a single violation could hit your medical facility hard.

Medical waste violations can be even costlier, with the Department of Transportation levying fines of up to $50,000 per violation and maximum civil penalties of up to $100,000.

Meanwhile, HIPAA violations can incur penalties as high as $1.5 million, and may even lead to individual employees being charged with additional civil or criminal penalties, while doctors and nurses can be punished with ethical violations, sanctions and even a loss of license. HIPAA’s enforcement arm has settled or levied punishments in 53 cases, for a total dollar amount over $75 million.

If one of your employees faces such penalties and didn’t receive adequate training, the entire medical facility may be held liable for those violations.

Given the steep consequences for compliance failure, which training programs are mandatory to protect your medical facility and uphold your legal requirements?

OSHA Training

The following training is required for larger medical and dental facilities, but additional training may be mandatory for some offices. Carefully review the complete text of Title 29 in the Code of Federal Regulations and consult with your medical waste services provider to ensure your facility meets any other requirements.

In all cases, you must offer training to an employee within ten days of their assignment to a relevant position, and annually from then on.

The following are required OSHA training courses for every medical facility, what those courses consist of, and who is required to complete them.

Bloodborne Pathogens (BBP)

Even minor mistakes when handling blood-contaminated material can spread disease, so OSHA training focuses on maintaining safe BBP procedures.

Content Covered

  • Sharps management
  • Development and maintenance of an exposure control plan
  • Managing regulated medical waste disposal, including container and labeling requirements
  • Communicating hazardous conditions to employees

Who Should Take

Any employee with a reasonably anticipated risk of exposure, as determined by each facility. In general, you should flag any position for training if those employees will ever come near patients, patient-care areas, or disposal and collection points for medical waste, even when those employees are purely administrative or non-clinical support.

Fire Prevention and Fire Extinguisher Types

OSHA requires all employers to maintain compliant fire prevention plans. Your plan needs to be in writing and always be kept in the workplace, freely available for employees to review. If your medical facility has fewer than ten employees, you can also communicate the plan orally, instead.

Content Covered

A thorough review of the entire fire prevention plan, including training about how to identify and correct potential fire hazards.

Who Should Take

All employees

Waste Handling and Classification Regulations

After the EPA transferred responsibility for establishing and enforcing regulated medical waste procedures, there are a variety of state and federal guidelines in play. Those guidelines are stringent, strictly mandatory and often change, so it is vital for your medical facility to conduct regular OSHA training to update staff and reinforce knowledge retention.

Content Covered

Training covers preparing and maintaining a medical waste plan and how to comply with all packaging and labeling requirements.

Who Should Take

Any employee with potential exposure to regulated medical waste, and the designated compliance point-person for your facility.

Personal Protective Equipment (PPE)

Employees and visitors depend on the correct usage of PPE to ensure safe operations and minimize hazards, so regular training is required by OSHA to ensure all relevant parties understand their obligations and procedures.

Content Covered

Training reviews a variety of PPE, how it's used to prevent exposure, and how to dress, wear and remove it safely and effectively to prevent secondary contamination.

Who Should Take

PPE training is mandatory for anyone with a risk for potential exposure to infectious diseases. That may include some support staff, and always includes anybody who comes into direct contact with patients in any capacity.

Radiation Orientation

Sources of ionizing radiation are a severe health risk for your entire medical facility and its workers, so OSHA standards focus on providing technical and regulatory information training your employees to recognize, assess and control radiation hazards.

Content Covered

Training covers the regulations, safety requirements and imaging standards for using X-Ray equipment, as well as managing all sources of ionizing radiation and radioactive materials.

Who Should Take

If your medical facility uses equipment or material that emits any radiation, the entire facility’s staff should take training to protect against those risks.

Hazardous Communication and Chemical Safety (HAZCOM) GHS Standard

OSHA standards stipulate that your employees have the right and requirement to understand the hazards and identities of dangerous chemicals in the workplace, including what measures are available or required for their protection.

Content Covered

Training covers a review of your HAZCOM program and all protective measures.

Who Should Take

Any employee with potential exposure to harmful chemicals or hazardous materials.

Department of Transportation Training

Administrative staff responsible for maintaining hazardous materials paperwork and communications require related training. Additionally, any person who performs any function related to hazardous materials must be trained, barring specific exceptions.

Training is required for anybody who signs waste manifests in your facility, and all hazmat employees require training for general awareness, function-specific activities and overall safety. This training must be offered within 90 days of assignment and every three years afterward.

D.O.T. Hazardous Materials Transportation Regulations (HM-181)

Your medical facility is legally responsible for its regulated waste from the moment it’s created until it’s properly disposed of or destroyed. This training helps ensure your medical facility is equipped and knowledgeable about all insurance, permitting and licensing requirements.

Content Covered

Specific medical waste transportation requirements that your staff should be aware of to maintain compliance, even when working with a partner.

Who Should Take

Your designated manifest signer and your compliance point-person

Pharmaceutical Waste Identification, Segregation and Disposal

Your facility’s pharmaceutical waste is also subject to state and federal disposal regulations.

Content Covered

Training should cover a review of the Resource Conservation and Recovery Act, classification of pharmaceuticals, and all requirements for packaging, labeling and manifesting pharmaceutical waste.

Who Should Take

Pharmacy staff and anybody who signs a hazardous waste manifest

HIPAA Training

This training is mandatory for any employee who comes into contact with protected health information (PHI), including new employees. Training is required “periodically,” but the legal definition of that period often changes, so annual training is advised.


Training should review everything that’s covered under HIPAA, and how that information is created and handled by your facility.

Content Covered

Learning how to design, implement and maintain a compliance program.

Who Should Take

Anybody in contact with PHI, including clinical staff, administrative staff and part-timers or interns.

HIPAA, Social Media & Texting Compliance

Social media is a great tool for engaging with patients but carries communication compliance risks that must be understood and prevented.

Content Covered

Social media overview in healthcare, along with benefits and risks related to HIPAA. Additionally, cover internal HIPAA procedures and risk mitigation.

Who Should Take

Anybody who comes into contact with PHI or works with your facility’s social media.

While failing to comply with any of the above requirements can lead to significant fines and violations for your facility, maintaining appropriate training programs in partnership with your medical waste provider’s online services is the best way to safeguard your workplace and its operations.

Download medical waste handling guide (ebook)

Topics: Compliance- HIPAA- OSHA

Kevin Webber

Kevin Webber

Kevin Webber is a partner at TriHaz Solutions and actively involved in the day-to-day business from a strategic and operational standpoint. He has a successful background in business/investment management and entrepreneurship, including recognition by Inc. Magazine’s 5000 list of fastest-growing private companies.

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