Does an Illinois Vet Clinic Need a Written OSHA Safety Plan?

State OSHA coverage

Illinois operates an OSHA-approved State Plan covering state and local government workers only. Private-sector employers and workers, including private veterinary practices, are covered by federal OSHA. ¹

State overlays to fold into the plan

Illinois Part 360 applies to all uses of x-rays in veterinary medicine. The registrant must direct operation of x-ray systems and register with the Agency under 32 Ill. Adm. Code 320 all x-ray equipment used at the facility and all portable or mobile x-ray equipment used by the registrant. The registrant must also provide written operating and safety procedures to each x-ray operator and provide initial and annual in-service radiation-safety training for individuals (excluding licensed practitioners) who apply ionizing radiation at the facility. ²

Illinois veterinary radiographic-system rules require the useful beam to be limited to the area of clinical interest, the image receptor to be consistent with the objectives of the examination, the x-ray field not to exceed the image receptor dimensions by more than two percent of the SID (beam perpendicular to receptor), and the exposure control switch to be arranged so the operator can be at least 1.83 meters (6 feet) from the animal, the x-ray tube, and the useful beam. All individuals whose presence is required during an x-ray examination shall be protected from scatter radiation by protective aprons or gowns of not less than 0.25 millimeter lead equivalent or by whole-body protective barriers. No individual other than the operator shall be in the x-ray room or area while exposures are being made unless that individual's assistance is required; when an animal must be held in position during radiography, mechanical supporting or restraining devices shall be used when technique permits; and any person required to hold an animal shall be protected with appropriate shielding devices, such as protective gloves and apron, and positioned so that no part of the body except hands and arms will be struck by the useful beam. ³

Illinois EPA identifies potentially infectious medical waste (PIMW) as waste generated in connection with diagnosis, treatment, or immunization of humans or animals, and lists used sharps, animal waste, and unused sharps among PIMW waste types. Used and unused sharps generated in animal diagnosis, treatment, or immunization are PIMW; discarded live or attenuated vaccines and culture dishes/devices generated in animal diagnosis, treatment, or immunization are also PIMW. ⁴

Records the plan should point to

Veterinary medical records: minimum 5 years from last known contact. Illinois veterinary standards of professional conduct treat failure to maintain adequate medical records as a disciplinary standard. Minimum record contents include patient identification, client identification, dated reason for visit and pertinent history, physical exam findings, diagnostic/medical/surgical/therapeutic procedures performed, medication given in the practice with date, dosage, route, frequency, and duration, medicines dispensed or prescribed with directions and quantity, medication or dosage changes (including telephonic or electronic changes), and necropsy findings when a necropsy is performed. Patient records must be maintained for a minimum of 5 years from the date of last known contact, and copies must be released to the client upon written request. ⁵

Controlled-substance records: keep the Illinois practitioner controlled-substance log and dispensing records described in Section 312, either alongside the medical record or in a separate controlled-substance record system. Pharmacy copies or written memoranda for Schedule III-V fax/oral prescriptions must be retained by the pharmacy for at least 2 years, but the veterinary practice should keep its own medical and controlled-substance records for the longer applicable retention period. ⁶