Featured Guest: Karen Daw

What she does:  Karen is an occupational health and safety expert in the health care industry with over two decades' experience helping medical, dental, and professional offices with safety, infection control, and compliance systems.  She began career in the emergency department at Ohio Health's Riverside Methodist Hospital and then served as the assistant director of sterilization monitoring for the Ohio State University College of Dentistry before becoming it's health and safety director and now works with health care professionals and entities across the US.  She has authored articles and CE courses on safety in dentistry and is an authorized US Department of Labor OSHA trainer as well as an active and current member of the Organization for Safety, Asepsis and Prevention, and CDC Dental Infection Control.

On risk:  "There's the risk of receiving citations and those inspections are public information. I can do a quick search and tell you all the medical practices that were inspected by OSHA so it's public information sometimes that lands you on the evening news, too. That's another thing as well is your reputation is at stake. I look at it from not just the immediate impact of it, but what are some of those indirect and also long term implications of not adhering to OSHA requirements too so there's that association with the risk … When people are assessing their practices, looking for the not so obvious, really thinking, be forward thinking, look for the things that is there a possibility this might occur? What can we do to prevent that now? The risk is low, but it's never a zero … People look at it from this very broad brushstroke. They're doing annual training and I always tell people you're doing a great job of addressing the more obvious things, what I want you to do is look for the not so obvious."

Transcript

Scott Nelson  0:01  
Welcome to The Risky Health Care Business Podcast, where we help you prepare for the future by sharing stories, insights, and skills from expert voices in and around the United States health care world with a mission to inform, educate, and help health care organizations and individuals, ranging from one doctor practices to large integrated systems and organizations throughout the dental, medical, and veterinary health care industry with risk, while hopefully having some fun along the way. I'm your host, Scott Nelson, a guy that grew up in Ohio and has been working all over the United States during my 20 plus year and counting career in the health care industry, with a commitment to accelerating health care performance through creativity, not just productivity. Let's dive in.

Each year the Occupational Safety and Health Administration - OSHA -  documents a substantial number of occupational health and safety incidents within the health care industry. The data highlights persistent and emerging risks that health care workers face in their work environments.  For example, issues like exposure to hazardous substances and materials, respiratory protection, bloodborne pathogens, and hazard communications.  Workplace violence is also a critical issue.  Press Ganey's Safety in healthcare 2024 report noted assaults against nursing personnel jumped 5% year over year. In 2023, the rate of reported assaults against nurses increased to 2.71 per 100 nursing personnel, up from 2.59 the previous year.  

Occupational health and safety can directly affect metrics like retention, loyalty, and “Likelihood to Recommend” - which in turn can impact financial metrics and performance.  Fines can also impact financial performance and the overall success of a health care entity.  OSHA's minimum and maximum penalty amounts can vary depending on type of violation, reaching a maximum amount of $16,131 per violation.     

In this episode I'm speaking with Karen Daw about occupational health and safety as a risk in health care.  Karen is an occupational health and safety expert in the health care industry with over two decades' experience helping medical, dental, and professional offices with safety, infection control, and compliance systems.  She began career in the emergency department at OhioHealth's Riverside Methodist Hospital and then served as the assistant director of sterilization monitoring for the Ohio State University College of Dentistry before becoming it's health and safety director and now works with health care professionals and entities across the US.  She has authored articles and CE courses on safety in dentistry and is an authorized US Department of Labor OSHA trainer as well as an active and current member of the Organization for Safety, Asepsis and Prevention, and CDC Dental Infection Control. Let's talk with Karen about risk in occupational health and safety and health care.

Karen, welcome to the show.

Karen Daw  2:45  
Hi, Scott. Good day. So glad to be here.

Scott Nelson  2:49  
I'm so glad to have you here as well. Before we begin talking about risk in health care and occupational safety and health let's go back to the beginning. How did you get into health care and where you are today?

Karen Daw  2:49  
I'm not going to take you back to four year old Karen that was riding around in her dad's truck at Hickam Air Force Base, growing up and watching him do electrical safety standards training. But I think that it's ingrained in me growing up in a military family. I also earned the moniker at a very young age of little boss lady, because I just love telling people what to do. And my mom always joked if you can make a living doing just this and talking you'll be set. And so I went to Ohio State, The Ohio State University, and got my communications degree. And as you know, the weather in Columbus is so similar to Honolulu. I ended up staying afterwards, I got my masters in healthcare administration and business management. And my very first job out of college was in the emergency department at Riverside Methodist Hospital. And I knew then I had a passion for safety. That's what introduced me to the whole world of infection control and compliance. And then from there, I was recruited to be the assistant director of sterilization monitoring, and then the clinic health and safety director for the OSU College of Dentistry. And then from there after 17 years, I launched my own business doing this. It's something that I, you know, the saying is so true if you love what you do it's never work, it's never work. And I love what I do. I love the people that I meet all over the country and being able to assist them with this area. Because let's face it, it's government language. It's a lot of legal jargon. It's not fun. If you tell your team hey, guys, it's time for annual OSHA training, like nobody woke up extra early that day like it was Christmas morning, right? So I knew early on I had to do something different, keep it lively, keep it airy, keep it engaging. So that ultimately, ultimately, the end goal is that the team listens, they pay attention, they learn, and they implement. That's the final goal. So I got into this early on knowing I wanted to be an educator. That's how this all started.

Scott Nelson  4:57  
I'd like to start our conversation with some general education on occupational safety and health oversight. US law, specifically the Occupational Safety and Health Act of 1970, requires worker safety to be enforced either through an approved state level occupational safety and health program, or the federal Occupational Safety and Health Administration known as OSHA, which is part of the Department of Labor, so a workplace is regulated by either the federal Occupational Safety and Health Administration or a state occupational safety and health program. So whether a facility is covered by the federal or state program depends on the state. There are currently 22 state plans covering both private sector and public employees, and seven state plans covering only public employees. So what is occupational safety and health? What's its purpose? And who does it affect?

Karen Daw  5:42  
Great question, well, you have some good trivia stuff back in there. Yeah, so when Nixon signed the OSHA Act, prior to that was a wild wild west, we didn't have any safety worker safety laws. So as the name implies, Occupational Safety and Health Administration has to do with employee safety. If you're in dentistry or medicine, that you know, OSHA doesn't really care what's happening to the patients, I hate to say that, but really, their focus isn't that their focus is on an employee. So you can have one employee and you will be subject to DOL standards under OSHA. So it affects every industry. While I focus on just the health care sector OSHA covers everything from construction to maritime, to general industry, which is what health care falls under. And going back to what you were saying about what they're who they impact, they can indirectly impact patient care as well, because when we look at some of the things that we're doing to protect our employees and our team members, we're also protecting our employees in an indirect manner to and it all has to do with a culture, which I hope we'll talk about later on. But the culture of safety, not just a check off the box type of environment when it comes to employee safety and risk management, but does it truly is a good fit for our organization? How are we going to make sure that our team is getting the information that they need to do their job safely? Are we training properly? It's not enough just put them in front of a video and say, hey, here's all the stuff you need to know every single year. But are they truly getting it? Are they are they able to then turn around and educate someone else on that as well. So Occupational Safety and Health Administration, more than just worker oversight and training, which I think a lot of people think is just one government agency that's going around trying to bust people and that's the exact opposite. I hope that people will reframe their view of OSHA and think about how amazing and empowering it is to have an entire federal agency dedicated to my safety. So as an employee I used to not look forward to OSHA safety training. It was dull, it was boring. And I didn't get it. I didn't get it. And now I look at it go, wow, there's an entire department at a federal level, and in many states as you mentioned, dedicated at a local level to my safety and my well being. How amazing is that? So I think that we should, I wish they had a different name for OSHA because I can tell you that it's not it's not synonymous with fun times or viewed in a positive manner in some respects.

Scott Nelson  8:04  
How do you view and think about risk in health care related to occupational safety and health? And why is it important to plan and prepare for it as a risk?

Karen Daw  8:13  
Yeah, well, I think the big one is people are worried about fines that are associated with it. And you know, a current willful neglect fine, if you had you probably know the answer, Scott, but I'll pause for the listeners to throw out a number in their minds. But if you had to guess what the current minimum willful neglect fine dollar amount is, right, and I've seen it, I've seen it used in against health care facilities, some private practices even, it's currently over $161,000, right, and so, and people wonder, well, what if I have multiple sites, right, well, there's the repeat violation as well. So there's the one aspect of it, which is OSHA's role with risk management is that they can cite your practice if you're not doing what you're doing. And again, I'm going to go back to OSHA would much rather us do what we're supposed to be doing. They would much rather us have that safe environment. And then following all the existing standards, then to receive and complaint and have to follow up with that complaint. They're not out to bust anybody. And the other thing that we need to remember is if OSHA does show up in the practice or at the in the or in the health care setting, that they probably, you know, they received that complaint most often it's complaint driven, and they must legally follow up with that complaint. Sometimes they give you an opportunity to respond via letter, email, but if they show up it must have been so egregious, or they received multiple complaints from numerous people, formal complaints, that they felt like they had no choice but to show up to mitigate any risks. So OSHA's role is in protecting employees, and the what's associated with not doing we're supposed to be doing, there's the risk of receiving citations. And those inspections are public information. I can do a quick search and tell you all the medical practices that were inspected from 2023 to current date 2024, that were inspected by OSHA in the state of Colorado, for example. So it's public information sometimes that lands you on the evening news, too. So that's another thing as well, is your reputation is at stake. So I try to like, look at it from not just the immediate impact of it, but what are some of those indirect and also long term implications of not adhering to OSHA requirements too so there's that association with the risk.

Scott Nelson  10:26  
What are the most common occupational safety and health related issues or complaints, you said many times complaints are what starts this process, so what are the most common ones that are facing health care facilities today? What areas within a health care facility are most prone to an occupational safety and health related risk?

Karen Daw  10:44  
Yeah, I think whether it's veterinary medicine, dentistry, or medicine, or medical care, they all kind of tend to be around the same thing. So for example, medical and dental blood borne pathogens standard and, and by the way, when I talk about a standard, right, 1910.1030 or HazCom standard 1910.1200, there's like, hundreds of things that are in each, under each of those that OSHA can cite a practice for. So for example, do we train upon hire and then annually by qualified trainers? So there's so many components of just training itself, right, and yet I see so many people who will plop their employees in front of a video or a DVD and say, hey, watch this and then and then there's gonna be questions at the end. And then I worked with a practice recently that admitted we have the answers and we just pass around the answers, we fast forward the video, we answer the questions at the end, it spits out a certificate, we completed our training for that year. God forbid one office I walked into was training using a VHS tape. Some of your listeners are not even gonna know what that is. Or a Betamax.

Scott Nelson  11:46  
I was just thinking Betamax because I am one who, I know what the VHS is and I also remember what a Betamax tape is.

Karen Daw  11:53  
Yes. So they're watching, they're watching the VHS or Betamax, I don't remember which one it was, but it was a, it was a videotape of a training and I thought oh my gosh, how dated is this? And I was not ready to look, I mean, as predicted their compliance program, their forms, their documentation were all dated. So there's the blood borne pathogen standard, one of the most common ones, and then underneath that probably safety device evaluations within the blood borne pathogens standard. So not evaluating safety devices on an annual basis is a big one, not performing proper training, not having HepB records on file for everyone. So in health care it's pretty standard, it's blood borne pathogens, respiratory protection, people think just because we we relaxed our COVID guidance that we don't need to have a written respiratory protection program. And what I tell people is like, well, we got to remember is that this, that written program predated COVID. Before COVID, we were dealing with things like measles and tuberculosis, and are we doing baseline TB testing for all of our employees, which is not a common thing in dentistry. That's, there's such a huge disconnect, I think, between medicine between medical and dental, I should say, both under the umbrella of health care, where medical practice, I can go into any medical office, and I know for a fact they're doing baseline TB testing and annual TB risk assessments for the practice. And then I go nto dentistry, and they're like, wait a minute, we're supposed to be doing what, it's just a huge disconnect. So my goal is to kind of bridge that gap between the two, because OSHA is looking at both of them exactly the same. And that's why we tend to see the same type of violations within dentistry that we see in on the medical side as well, which is respiratory protection, blood borne pathogens, and then I would say rounding out the top three hazard communication. In the top most often collected as far as dollar amounts in fines for health care, is fire safety. And I don't think people a lot of people think about that they're thinking, oh, HepB immunizations and infection control. And we're thinking, respiratory protection, and we're thinking aerosol transmissible diseases, or we're thinking safety data sheets and labeling of secondary containers, but they don't think about fire safety. Have we done a fire drill? Do we have a written fire protocol? Are we required in our state to have a fire brigade, you know, certain states actually have that requirement. The states, some state approved states, for OSHA need to have that requirement. And it's so interesting how few people are aware of that. On the veterinary side, it's formaldehyde safety data sheets as well, not so much on the blood borne pathogens standard in vet medicine, but they're the things that you don't typically think about. The other one too, the LOTO standard, so OSHA's Lockout Tagout. One of the top five violations in medicine, dental, and veterinary medicine is the control of hazardous energy. And I don't think people think about that.

Scott Nelson  14:47  
If I juxtapose that to thinking about ones and maybe that is the hazards, the hazardous, and the fire. Are there ones that people overlook and can can cause them issues and cause them problems and then create the fines other than, you know those big ticket item ones?

Karen Daw  15:05  
That's a great question because I think a lot of people kind of look at it from this very, they paint it with a very broad brushstroke. And they're like, oh, we're doing our annual training, blood borne pathogens. And I always tell people, yeah, you're doing a great job of addressing the more obvious things, what I want you to do is look for the not so obvious. It's not always blood borne pathogens, right? Do you have a designated meeting area in the event of a tornado or a fire? Do you have a written building emergency action plan or a BEAP on record that your team knows how to access that you reviewed during your regular safety meetings? Are we having safety meetings? So some of those not so obvious items. One thing that I think is often overlooked and that OSHA, you know, it's coming down the pike, are these updated standards that OSHA just released. Its updated safety data as hazard communication standard. The other one they're working on workplace violence. And that one is huge, that's the buzz term right now. And I don't think a lot of people think about workplace violence falling under OSHA. And yet health care, traditionally, was in the top three, top three, they were third at one point for instances of workplace violence. Number one is going to make a lot of sense what I said so. So law enforcement. That makes sense, right? Number two, all they want to do is ensure we have a positive experience. And that's our hospitality and food service workers. And you see these awful videos online of like somebody punching a Taco Bell worker because they didn't get their hot sauce, or throwing hot coffee at someone at Starbucks because they didn't make it right. And it's awful. And I think this is a great segue into this workplace violence conversation, which is kind of also tied into one of the top reasons why OSHA even inspects a facility is lack of communication. I don't think people know how to talk to each other anymore. In an era where we can be texting, keyboard bullies, we can leave negative comments and bully someone, and not even they don't even know our name, it's completely anonymous. We don't see the impact that our words have on other people. And I think it's kind of lended itself to this. So I tell people, a great way to mitigate workplace violence, and also to mitigate OSHA visits, is communication skills. Have we done training around communicating? Are we done conversational training? Do we know how to speak to one another, as colleagues, as coworkers, to with our patients? There are studies that are done that kind of a sidetrack here, but I think it's relevant, where they can predict with a certain degree of certainty which doctors are going to get sued by the patients and all is has to do whether or not the patient likes them or not. Did we establish rapport? Are we having conversations with them? Now certainly there are high risk industries, where communication skills are not going to mitigate workplace violence. But have we been trained on what to look for? Do we know how to deescalate verbally? Have we been trained on verbal judo so that we know if some if the patient's getting aggressive we know not to match their energy, we know to be calm, but assertive, we don't fuel that fire. We know when to call security or when to vocalize, we never want to say you need to calm down, right? Because that's like they do the exact opposite. But if we don't know how to communicate here are the repercussions of your actions. And we can't find our voice then that situation may quickly go from verbal to physical if we're not aware of what are the cues and signs to look for. And I think it all starts with communication. Same thing with OSHA inspections. If we are not communicating that we have an open door policy. Hey, we, we want to know if you have a better way, a safer way, of doing something we want to hear from you at those regular team meetings, inviting them or closing it with does anybody have any suggestions around workplace safety, I'd love to hear from you. And then also take into account that there are people who don't want to speak up at those meetings as well. They may not want to talk in front of a group, they don't feel comfortable speaking in front of a group. Do we have alternative means for them to communicate things that they might have seen or are aware of that they didn't want to bring up in front of a group because they may be noticing something like, you know, I noticed in that nobody in this office is wearing utility gloves, even though when I was onboarded you told me we all had where utility goes when we're cleaning instruments. They may not want to out the rest of their team in front of folks. So do we have an alternative method for them to communicate things that they're seeing or experiencing that it's on the radar for us as well. So do we have those open lines of communication? Do we let our employees know that their safety is important to us? That you matter, you care. In a profession where we're seeing a mass exodus of health care workers leaving, people who've gone to school for four and sometimes eight years or more, and then leaving health care. We saw that huge move, migration, of health care workers as a result of COVID. And they're not coming back and we're short staffed. And that's increasing distress in the workplace, too. It's a great time to make sure that we're checking the pulse of our team. How are we feeling? How are we doing? Now, if we ask them about suggestions, like what do you think we could do better around here? And they say, well, I'm aware of a brand new needle recapping device, then oh, yeah, that's absolutely, want to hear about that. But if they say like, I think we should have a margarita station in the break room, you certainly don't have to entertain that, right, but it couldn't hurt. It would be kind of fun to hear somebody say that and just let them know, oh, that's hilarious. Not related to safety but I hear ya, I hear ya. So again, just building that rapport with the team. Communication goes a very long way.

Scott Nelson  21:03  
Well, along those lines, what are the challenges that health care facilities are facing in keeping up with changing occupational health and safety regulations? Is it communication? Is it this is a lot of moving pieces and parts and it affects an entire business or an entire organization and it can be overwhelming. What are some challenges that people are facing with this?

Karen Daw  21:26  
I think it's cultural, honestly, I think staying abreast of updates, very important, and I don't think a lot of people know where their resources are. Because let's be real, OSHA, CDC, Department of Health is not calling that hospital, or calling that vet practice, or dental office and saying, hey, I just thought you'd like to know that we're working on a new standard, or there's a new administrative code for our state that affects, directly affects, patient and employee safety. No one's doing that. So how are we staying on top of this? Most hospitals, their regular environment of care meetings, they have quality team that meets around, you know, ambulatory care safety team, for example, they'll meet regularly to discuss these things. And as they're, they're kind of tasked with making sure we're updated, that leadership has the information they need to set policies and procedures. But you know, your typical private practice, your ambulatory medical center, your dental practice, they don't have an entire team dedicated. The most often they have a safety officer, and then it's their responsibility to try and stay abreast of this information. And I think that's where the challenge is, they don't know where the resources are. They're going to the osha.gov website, and there, they don't know where to go from there. So I always tell him, like, you know, what, what if we empower that person with additional continuing education. If that person is going to be responsible for our practice's safety and compliance program, what can I do to support this person? So if I have a team member, that's my full time steri fairy, that's all they do is clean instruments. What about earning their credentials in instrument reprocessing. If I have a full time safety officer, how about if they're dentistry how about earning their CDIPC, become certified in dental infection prevention and control? If they're in medicine can we send them for continuing education that would allow them to be a better safety officer, more empowered and more comfortable with their responsibilities? That's the other thing, I think sometimes we people don't volunteer for the role they're voluntold that they're the safety officer and we just dump this gigantic OSHA manual in their lap and they go, and we go, okay, you're, you're in charge now, like you're on your own. And sometimes we kind of need that handholding process initially so they're comfortable with the role, and so that they become hopefully as passionate as I am about it. And then they're actively looking for these updates, because like I said, no one's calling to let you know, hey, this is what's coming down the pike as far as OSHA is concerned, this is what's passing, this is what we're looking for. We have some idea. We put pieces together based on trends from the previous year, and what OSHA has announced, and what's happening within our industry. So we can kind of take a good guesstimate, but no one's going for sure, in black and white, here's what we're looking for this year. There's checklists out there that we can use that will really gives us a leg up. And so I tell people start there, do an assessment, do an honest, internal assessment. Don't just check off the box. Invite somebody from the outside to scrutinize your policies and your practices and observe. The observation portion is so critical. My team can tell me that they're doing X, Y, and Z. But I'm hired by hospitals to do audits of their physicians groups to because they're not under Joint Commission, they're under OSHA then, to walk around and do mock inspections. And you would be surprised by the types of things we still see to this day occurring. And they know better, they know better. So I think there's so many pieces to this. There's the training portion of it, initially, there's ongoing training, training in a way that speaks to them that helps the information stick. I love the idea of a mock inspection, having somebody come in and evaluate, a third party evaluate your processes. And then having open lines of communication between the team and upper management and the executive leadership around safety too. Those are all the pieces of building a culture of safety and compliance. It's not just one person's job. Everybody is now responsible and takes ownership in the compliance program.

Scott Nelson  25:30  
Negative's been mentioned multiple times. I'd like to take a look at the flip side of that because I agree with you, I think that energy gets heightened quite a bit when an organization hears that the OIG is at the front desk, or OSHA is at the front desk, Joint Commission's at the front desk, those types of groups. But to one of your points about OSHA is there to help, what are some of the positive impacts that occupational health and safety has on a health care setting.

Karen Daw  26:02  
Traditionally we can just look at the numbers. We've seen a decrease in the number of workplace injuries, worker fatalities, as a result of the OSHA Act and the creation of OSHA. The other positive impacts, too, I think it can then be used for employee morale. Again, it's just one piece of the puzzle. We're trying to retain employees. We want them to feel heard in every aspect that pertains their job, including safety, every employee is aware of OSHA, what if we were to take that concept of OSHA is something we must do, and have to do, to something we want to do, we look forward to that training, we want to learn about the latest safety devices. So on the plus side, it can increase employee morale and hopefully employee retention. Again, I think the big part of that is the communication piece more than anything, but can you communicate about safety, you 100% can. It's one piece of that big picture for employees. Besides decreased workplace injuries and fatalities, and increased morale, you have the decrease of potential fines too and then you just have a really good reputation. Here's the thing that I know about working with a lot of my friends who are traveling nurses in the industry and that is they talk, they all have nowadays, they all have boards that they post on about places that you would want to work and places you want to avoid like the plague. And that's the thing, same thing with dentistry and vet medicine as well, they're all talking to one another about these organizations for a variety of reasons. And sometimes it is safety related. So we can build a culture where it's driven by positive, not just patient, but employee experiences and engagement too, I think that'll go a long way for an organization and OSHA and safety can definitely play a big part in that.

Scott Nelson  27:54  
To classify, collect, analyze and publish data OSHA uses the North American Industry Classification System, 62 is health care, which replaced the Standard Industrial Classification. If I'm an individual or a larger entity, and I'm thinking about this and continuous improvement and want to make sure I'm proactive and prepared with a plan to implement and operationalize what are some key components of that plan, some strategies and tactics that can ensure preparation and continuous improvement? So if I'm starting out, or if I have a program underway, but want to make it better, how would I go about doing that? What should I be doing?

Karen Daw  28:27  
Having someone who's knowledgeable, supporting them in their ongoing education. The other thing that this person should do, other than doing the annual training, for example, or the new employee training, and by the way, I realize that prerecorded training is convenient for many organizations but we also know from the studies that they're not retaining information, live training tends to be better. So if you have the capability to do live training I would highly recommend that. But then, if this person is doing the training for the organization, making sure that they know what they're talking about. And the way we do that is by making sure they receive the education that they need. Maybe partnering with a third party, an outside entity to come in and identify where the gaps are, and help us acknowledge all the things we're doing well, and then help us acknowledge the gaps and what can we focus on, like help us strategy map, what is low hanging fruit, what is the priority, because you can end up with a laundry list of stuff and then not know where to begin. And then not having just one person, having a team. I don't care how small the practice is, it's a good idea to have more than one safety officer because I can almost guarantee you, if you're ever inspected by OSHA live, it always happens when that safety officer is on vacation in Hawaii. I get that phone call all the time, like OSHA was just in my office and our safety officer was out for lunch or was out for the week or whatever the case may be. So having more than one person. And then there, there's that team dynamic, right? It's not just oh, you know, Karen's in there pointing her fingers at us about wearing our PPE in the break room. No, it's like multiple people going, okay, wait a minute, we all attended the same training, we all heard the same thing. So I think it's, you mentioned the proactive piece, I think there's that the identifying the people who will be part of that safety team or safety committee, empowering them, continuing education for them, as well as for the team. And then ongoing assessment of your program, never resting on your laurels, never gonig okay, I've got my exposure control plan written up, I'm just gonna put this in my OSHA manual, pop that on a shelf, and I don't have to touch it again, for a few more years, right, we have to be reviewing that on an ongoing basis. That OSHA manual and those documents are a living, breathing, written format of our policies and procedures. And as a living, breathing entity, we want to make sure that we're feeding it, and we're checking in on it, and we're making sure that it's healthy and it still makes sense. Do we need to update it? Is there anything that's outdated? And that, that, and that has to be an ongoing process, not just once a year, sometimes, if we're changing our standards, or we introduce new hazards in the workplace, we're gonna have to reflect that in our policies. So having someone do this on a regular basis and giving them the time to do it. Many times when I go into a physician's office or veterinary practice, or, or private, private dental practice, I should see private practices, it's one person who's a full time MA, who's a full time dental assistant or full time dental hygienist, or full time vet tech, their full time doing something else and we've given them the responsibility of safety. But we've given the no extra time to focus on the program. So making sure that we check in with those people responsible for overseeing our program and saying, do you have enough time to be successful in this role? What can we do to help you? Do we need to distribute some of these responsibilities to take some things off your plate? Do we need to give you more time to work on this, maybe we give you an hour, every single week to visit this and focus on this. So it is ongoing. And when we do that they're more invested, it becomes more a labor of love for them and not a chore. And they start looking at those not so obvious things I mentioned earlier. One of the most common questions I get has to do with service animals in a physician's office or in a dental practice. And I actually had a safety officer who was able to find that information because they were empowered, they knew how to navigate through the different government websites, because they have received training around that too. So I know you don't think of service animals with OSHA but it kind of goes hand in hand when you are required to accommodate the two animals officially recognized by the Americans with Disabilities Act as a service animal, but you have a team member that's afraid of dogs, for example. So it kind of goes, I know what people are like with like service animals and OSHA what does that have to do with the other, well, if you're introducing this animal into the workplace, and you have team members that's fearful of it, what do we do? What are what are our rights and what are requirements then? So having the ongoing assessment of our program, and then checking in with the team members that are responsible for our compliance program, it's gonna go a long way, go a long way. And that's gonna bring us back to the very beginning, which is how do we prevent the OSHA inspection to begin with, again, those open lines of communication with our team around this. I have to share this story with you about a wonderful woman I met at a conference named Jenn Morrone and she was speaking on the importance of proper eyewear, safety eyewear, not for ourselves, you know, as as health care professionals, but also for our patients. And she was a patient, she had gone in and she and I were chatting, we bonded over the fact that we're both list makers, she said you know what Karen, I was sitting in that chair and I was making a list in my head of all the things that I had to do after that appointment because it was going to be a long appointment. And she was not offered eyewear nor was she aware she should have asked for some safety eyewear as a patient. The doctor administered the anesthetic injection, passed the needle off to his assistant, passed it across her face, and it was uncapped, and the needle slipped, and the needle went in her eye. She was not even aware. As a result of this, like so he didn't even stop the procedure, he gave her tissue to dab her eye which was starting to tear up at this point. And he sent her home with no recommendation for follow up medical care. She woke up and she said Karen the next day, it felt like my brain was on fire. She underwent several surgeries, surgeries on your eyes, several surgeries. And unfortunately, they weren't able to save her vision. Actually, they were unable to save her eye. She wears a prosthetic eye now. So the the moral of that story is, again, how many patients think there's a real possibility they might lose an eye going to their dentist, right? Nobody ever thinks that. The risk is low, but it's never zero. It's never zero. And that's the takeaway from that. The bottom line is that when people are assessing their practices, you know, we were talking about looking for the not so obvious, you know, really thinking, be forward thinking, look for the things that you know, is there a possibility this might occur? Okay, then what can we do to prevent that now? Is there likelihood, you know, is a is a likelihood that a piano might fall on my head if I walk out my front door? No. But again, the risk is low, but it's never a zero. I've heard crazier things happening. We think it'll never happen to us and yet it happened.

Scott Nelson  35:29  
And I think that also gets back to one of the things that you mentioned at the beginning, is the culture of safety, making this a priority, give, providing the time, the tools, the resources, the continuous, the checkins, the education, making this the priority, are core foundations, or core pillars, to creating that culture of safety.

Karen Daw  35:48  
Yes, 100% I would agree with that. Absolutely. It's not just one person's responsibility. We want everybody to know that they have, they play a part in the compliance program. And for that reason I delegate responsibilities. I don't have one person doing everything. There's usually a team, if it's a smaller practice, everyone in that practice has a job or role. And that way, even though that one little microcosm is their responsibility, they have a better appreciation for the other things that are going on, the other requirements and responsibilities that we're responsible for that practice. Yeah, you put it, you put it together nicely, I like that.

Scott Nelson  36:27  
You'd mentioned checklists, and tools, and resources. If somebody is looking for something they can do and do an internal assessment to identify, hey, we have issues here that we need to address, and we need the assistance. What are a couple things that a group might be able to put together if they are looking to put together an internal checklist?

Karen Daw  36:45  
There's so many out there that exist. OSHA even as a pamphlet for medical and dental offices, OSHA 3187. It's dated, they still refer to safety data sheets as MSDSs in that pamphlet, but it does tell you that the top things that they're looking for, they expect is happening in a medical and dental office, that's straight from OSHA. They also have resources at osha.gov, you can go to the dentistry tab, you can go to the health care tab and then you can do a search for whatever topic you're looking for. So if you're looking for an exposure control plan template, you can go and and it'll pop up OSHA document 3186 for you. And it'll give you that template for both blood borne pathogens and hazard communication. So osha.gov is a great resource for you. CDC has an entire oral health division and they even have a CDC dental checklist, infection control checklist, which does overlap in some instances with OSHA as well. So it's a really good, again, free resources, free tools. If you just Google OSHA checklist for veterinary practices there's a variety of free ones out there. I don't know how credible they are, depends on you know who's putting it out, if it's a reputable source, then that's a very easy way to kind of get started on evaluating your internal processes as through these resources.

Scott Nelson  38:07  
Looking back through recent history what are some lessons learned, and looking forward what do you see as potential issues in occupational safety and health and how can individuals and organizations anticipate those and be prepared?

Karen Daw  38:19  
So when COVID hit it kind of took us all by surprise. We had several different standards to draw from, as far as OSHA is concerned, so we kind of pulled some from PPE, we pulled some from respiratory protection, we pulled from pulled some items from the blood borne pathogens standard. So we were kind of, it seemed like we were caught off guard because OSHA didn't have a specific infectious diseases standard. So lessons learned are to be proactive because it's not a matter of if it's a matter of when the next pandemic strikes, depending on who you ask, that's the language that's being used frequently at the conferences I attend, is that we need to be prepared now for the next time. So OSHA, looking ahead, OSHA is working on an infectious disease standard, they are looking at a COVID standard as well. We don't know, depending on what stage those rules are in, we don't know when they might be issued. And it depends on the priority. It depends on a lot of other things too. But looking ahead, I anticipate we'll have something in black and white that will tell us this is what you do. This is what you're supposed to be doing. And because I honestly believe that everyone listening, we want to do the right thing. We just, we just want you to tell us what to do. And so I think OSHA has really ramped up their focus on this and creating something for us, hopefully within the next year or two, that we can follow and adhere to that will make our jobs easier. The easier we can make compliance the better off we all will be, right, without having to go searching for a bunch of the stuff. It was just in one place where I can find it. It's the official standard that'd be so helpful and that that's what I see coming ahead. So lesson learned was we were a little off guard so what are we going to do to prepare ourselves for the next pandemic? And that is what OSHA's focusing on moving ahead.

Scott Nelson  40:13  
Well, that's a great point to conclude our conversation. Karen, thank you very much for your time and sharing your thoughts and experiences today. I really appreciate it. 

Karen Daw  40:20  
It was my pleasure. Thank you so much, Scott. 

Scott Nelson  40:25  
Thank you for listening to The Risky Health Care Business Podcast. You can listen to all episodes from the resource center page of the SpringParker website, springparker.com, or click the Listen link in the show notes to listen and subscribe for free on your platform of choice. And remember, accelerating health care performance is achieved through creativity, not just productivity.