Applicability
OSHA applies to every ASC as an employer. State plans operate their own programs that must be at least as protective as federal OSHA. The OSH Act's General Duty Clause covers any recognized hazard not addressed by a specific standard.
Bloodborne Pathogens (29 CFR 1910.1030)
The Bloodborne Pathogens standard is the foundation. Required:
- Written Exposure Control Plan, reviewed annually.
- Universal precautions and engineering controls (sharps safety devices, sharps containers).
- Work practice controls (no recapping).
- PPE provided at no cost.
- Hepatitis B vaccination offered at no cost within 10 days of assignment.
- Post-exposure evaluation and follow-up.
- Hazard labeling and signage.
- Training on initial assignment and annually.
- Sharps Injury Log — retained for the duration of employment plus 30 years.
Hazard Communication (29 CFR 1910.1200)
The HazCom standard requires a written program, chemical inventory, accessible Safety Data Sheets (SDS), GHS-aligned labeling, and employee training. Common ASC hazards: disinfectants (glutaraldehyde, OPA, peracetic acid), surgical smoke, compressed gases, waste anesthetic gases.
Respiratory Protection (29 CFR 1910.134)
For ASCs, the most common application is N95 use during airborne-isolation precautions. Required: written program, medical evaluation, fit testing (initial and annual), training, recordkeeping.
PPE (29 CFR 1910.132–138)
Hazard assessment, employer-provided PPE, training, and certification of training. Eye/face, head, foot, hand protection.
Ionizing Radiation (29 CFR 1910.1096)
Relevant where C-arm or fluoroscopy is used. Required: dosimetry, training, posted warnings, dose limits.
Workplace violence
No federal standard, but the OSHA workplace violence guidance for healthcare is a strong basis for a written program.
Recordkeeping (OSHA 300, 300A, 301)
Most ASCs must maintain OSHA Forms 300, 300A, and 301. Form 300A annual summary is posted from February 1 through April 30 each year. Reference: OSHA Recordkeeping .
FAQ
Does OSHA apply to ASCs?
How long must a sharps injury log be retained?
What is OSHA Form 300?
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Keep requirements linked to the policies, logs, files, tasks, and approvals that prove compliance.
Turn findings into owners, due dates, escalation, and documented closure.
Show a clean evidence trail by requirement, owner, date, and status when surveyors ask.