The Veterinarian-Client-Patient Relationship, or “VCPR,” is the Holy Grail of the practice of veterinary medicine. Business and Professions Code section
Now that your written Cal/OSHA Safety Plan is complete, you will need to implement its various components. Utilizing your written plan as a guide, follow the instructions below to implement the Cal/OSHA regulations that apply to your practice.
Heat Illness Prevention Plan (HIPP) (only applicable to practices with outdoor workers.)
Wildfire Smoke Inhalation (only applicable to practices with outdoor workers.)
Other Cal/OSHA Programs:
(See page 3 of the Sample Safety Plan)
1. Introduce your Cal/OSHA Written Safety Plan to Employees
The first step in implementing your IIPP is introducing the plan to your employees. Your written safety plan (including the EAP, FPP, HCP and various other components that apply to your practice) should be given to every employee and reviewed either on a one-on-one basis or in an office meeting. Your written safety plan should serve as a base document in your ongoing employee training program. Make sure to have employees sign an attendance sheet or statement to prove that they received, reviewed, and understood your practice’s Cal/OSHA written safety plan. CVMA Form 12 – Employee Training Attendance Sheet can be used to document training.
2. Conduct an Initial Safety Inspection
This first safety inspection will be a little more complex than subsequent periodic inspections and should include a detailed hazard evaluation/job safety analysis. You must evaluate each job type or work area for hazards. CVMA Form 1 – Hazard Evaluation System should be utilized during this phase. In addition, you should hand out copies of CVMA Form 2 – Job Safety Analysis to all individuals involved in this phase (this could include all employees) and ask them to complete the form in detail. A site inspection checklist, like the one included with this manual (CVMA Form 9 – Inspection Checklist), should be available to employees for reference during your job safety analysis.
Use the CVMA Form 9 – Inspection Checklist as a reference to conduct a room-by-room detailed inspection. The first few pages of the inspection checklist include paperwork and recordkeeping items. There is a listing of required employee posters. The actual Physical Plant Inspection checklist makes up the second half of the document (beginning on page 7). For each room, you should be able to answer “yes” to all listed items. Any item that requires a “no” answer should include details in the space provided, such as location and a description of the problem. Transfer any deficiencies noted to CVMA Form 8 – Inspection Summary and Action Plan. During this initial safety inspection, note any potential hazards, even if there is no specific problem at this time. For example, if an area tends to have wet, slippery floors, it should be noted on the checklist. One of your code of safe practices might be to take precautions to keep this area dry or to put up a “wet floor” warning sign when appropriate.
After you have made the needed corrections to noted problems, put the Inspection Checklist, Summary and Action Plan, Job Safety Analyses, and Hazard Evaluation System forms into one packet and file in a folder labeled “Inspections” in the Cal/OSHA section of your filing system. This will be the first of a series of periodic (monthly) safety inspections you will be conducting.
The following list includes some of the potential hazards that may be found in veterinary practices. It is only a partial list and should be used as an aid in identifying the specific hazards in your facility.
You must implement the communication system described in section 3 of your IIPP. If bulletin boards are to be used, be sure they are placed in areas easily accessible to all employees. Make copies of CVMA Form 3 – Report of Workplace Hazard and make them available to employees. You may want to consider hanging several copies on the bulletin board along with a note indicating where completed forms can be turned in. Employees should be able to file the form anonymously.
Post a copy of Cal/OSHA’s “Job Safety and Health Protection” in an area where employees will see it. This form is included in the CVMA’s Employee Posting Set along with other posters required by other agencies. The poster is also available directly from Cal/OSHA. Please refer to the CVMA Form 9- Inspection Checklist for a complete list of required posters.
Post a list of emergency phone numbers near telephones. The list should include all emergency responders such as the fire department, police department and medical aid, even if all of them are available by dialing 911. Also include other agencies such as poison control, your hazardous materials handlers, and Cal/OSHA.
If required, post the cancer and reproductive harm warning (plaque available from the CVMA). Employers with 10 or fewer employees are not required to post this notice.
Use the other forms of communication described in your written IIPP to convey information to and from your employees on safety issues. Document all forms of communication. Keep copies of all notices placed on the bulletin board and notes on information provided during meetings. If you use “routed” memos, keep the memo and the initialed routing form in your files. All of these forms of communication can be considered as part of your training program. These documents should be maintained for at least one year.
Whenever a work-related injury or illness occurs, you are required to conduct an investigation to determine the cause and any corrective measures needed to help prevent a future recurrence. This is an ongoing component of your IIPP implementation. Corrective measures should be instituted and documented. If necessary, make additions or changes to your Code of Safe Practices.
Your investigative procedures should include the following:
File reports in a folder labeled “Injury/Illness Investigations” in the Cal/OSHA section of your filing system.
As with your safety inspection program, your training program will prove worthwhile by reducing the rate of work-related injuries and illnesses that occur in your practice. Ideally, training should take place on an ongoing basis in accordance with your IIPP policy statement, the various components included in your practice’s Cal/OSHA written safety plan, and on topics relevant to specific hazards encountered in your practice. At a minimum, training must be provided at the time your IIPP is first implemented, before new employees are assigned to their duties, and when new job tasks are assigned to current employees.
Training should cover the following topics:
Keep copies of your training materials in a central location to make future training sessions easier to organize. Your Code of Safe Practices should serve as a basic training aid. CVMA Form 10 – Notice to Employees can be downloaded, printed and given to all employees or posted in a central location.
Document, document, document! Keep copies of the memos, fliers, lesson plans or outlines you use in your training program. Have employees sign a dated attendance record and keep all of these items together in the “Training” folder located in the Cal/OSHA section of your filing system. CVMA Form 5 – Group Safety Training Documentation can be used to document group training sessions and CVMA Form 6 – Individual Employee Safety Training Documentation to document individual training. Employees with 10 or fewer employees may simply keep a log of training on CVMA Form 7 – Log of Employee Training.
Training records must be maintained for a period of at least one year, but you are encouraged to keep them as long as possible. Exceptions can be made for employees terminated before completing one year of employment. In this case, a copy of the employee’s training records may be given to the employee in addition to keeping the original on file.
Enforcement is an important ongoing part of your safety plan implementation. Employers are required to ensure compliance with safe work practices. You must enforce your safety rules. Follow your written policy as outlined in Section 2 of your IIPP.
Actions taken to enforce compliance must be documented. The following information should be included:
This information should NOT be kept with your IIPP or in the Cal/OSHA section of your filing system. These records are confidential and must be maintained in individual personnel records and stored in a secure location.
Incentives can be documented in a similar manner.
At this point, you should have a complete and effective Injury and Illness Prevention Program in place. To maintain an effective program, you will need to continue your training efforts, your periodic safety inspections, and your injury and illness investigations.
NOTE: Cal/OSHA regulations require that your plan be revisited and updated at least annually. Each time you login to the CVMA Guide to Cal/OSHA Compliance and make changes, the date and time will be automatically captured and reflected on the newly printed version of your plan. Any time you make changes to your guide, it is recommended that you print a new version to have on hand in your practice.
You should periodically review your IIPP, revise/ update, reprint, redistribute to employees, train employees on changes, and document training as needed. At a minimum, you should do this at least annually. Even if you have no changes, logging into your guide and reprinting it at least once yearly will ensure that you have a current copy available in the event of an inspection.
(See page 13 of the Sample Safety Plan)
Implementing your Emergency Action Plan (EAP) involves:
Be sure to point out during the plan implementation where exits are located, where emergency escape route maps are posted, and where employees can find emergency equipment such as flashlights, fire extinguishers, and other items. Employees should also know where the designated primary and secondary meeting places are located outside the practice.
Conduct an emergency evacuation drill with employees to ensure that all aspects of the EAP are understood and followed.
Document your EAP employee training by having them sign an attendance sheet verifying that they received, reviewed and understood the policy and all of its related documents. Use CVMA Form 12 – Employee Attendance Sheet to do this.
(See page 15 of the Sample Safety Plan)
Fire Prevention Plan implementation involves reviewing the written plan with your employees to ensure not only that they are aware of potential fire hazards in the practice, but also to ensure that they understand the plans and procedures that should be followed to minimize fire risk. The implementation should cover identification of the following:
Implementation should also include a thorough assessment of all work practices to determine if and how fire risk minimization can be instituted.
Document your FPP employee training by having them sign an attendance sheet verifying that they received, reviewed and understood the policy and all of its related documents. Use CVMA Form 12 – Employee Training Attendance Sheet to do this.
Each practice must conduct an inventory of hazardous substances.
Use CVMA Form 11 – Hazardous Chemicals Inventory Sheet as an aid to create your initial list. This form is intended to be used when you are inventorying hazardous chemicals in a room-by-room inspection of the practice. After the handwritten list is complete, you may wish to enter the chemical names into an electronic version of the list, then sort the list alphabetically for easy use when searching for a chemical name. This would also be a good time to eliminate unused or duplicate products.
A “hazardous substance” is any item included on a series lists such as The Director’s List of Hazardous Substances (T8 CCR, Section 339), Toxic and Hazardous Substances (29, Code of Federal Regulations, Part 1910, Subpart Z), Air Contaminants (T8 CCR, Section 5155), Chemicals Known to the State to Cause Cancer or Reproductive Toxicity (Prop. 65), and several others – or “Any substances that present a physical or health hazard as determined by scientific evidence.” That last definition means that your list should be very inclusive. If in doubt, list the substance. A complete list of Cal/OSHA Hazardous Substances can be accessed here as a reference.
There are also some exemptions, such as tobacco or tobacco products; wood or wood products; food, drugs (including most pharmaceuticals used in the practice), tapes or films, cosmetics intended for personal consumption by employees, and substances in compliance with regulations of the Director of the Department of Pesticide Regulations (§12981 of the Food & Agricultural Code).
An aid to starting your inventory might be your existing SDS collection. Everything for which you have a SDS should be included on your hazardous substances list. Some practice management computer programs include an inventory of items that are sold or dispensed, and that list could serve as a start, although all items on that list may not need to be included on your hazardous substances list.
A SDS collection can be either hard copy or electronic. If it is electronic, it must be quickly and easily accessible at all times and employees must be trained on how to access it. For this reason, many employers still opt to keep hard copies for employee access and review.
There are now many sources to obtain SDSs. Your veterinary products distributor may have a searchable online database or may be able to send hard copies of SDSs with product shipments. Generally, they can provide an SDS for any product they deliver to you. The internet can be a valuable source too. Try entering the product name and “SDS” into any internet search engine (such as Google) or try visiting the product manufacturer’s website. Many have downloadable copies of their SDSs available. And the last option is to write the manufacturer a letter requesting an SDS for its product. If they respond that an SDS is not required for their product, keep a copy of that letter in your SDS collection.
Many pharmaceuticals may not have SDSs available, and technically may not need to be included in your SDS collection. The CVMA suggests that any drug used in your practice should have an SDS in your collection, if one is available.
Don’t forget some of the common but often overlooked hazardous chemicals such as bleach and other cleaning substances, copier toner, “white out” correction fluid, mineral oil, highlighter markers, carbonless copy paper, sharpie markers, writing pens, etc.
In the event that you discontinue use of a hazardous chemical, the SDS sheet should not be discarded. It is recommended that the SDS be moved to an archived SDS collection for your practice and retained for 30 years. Section 5194 of Title 8 refers to Section 3204 for records retention requirements. Section 3204(d)(1)(A) states:
Safety data sheets shall be retained as necessary to comply with the provisions of section 5194. Where safety data sheets are destroyed, a record of the identity (chemical name if known) of the substance or agent, where it was used, and when it was used shall be retained for at least thirty years; and
Section 3204(c)(5)(D) records concerning the identity of a substance or agent need not be retained for any specified period as long as some record of the identity (chemical name if known) of the substance or agent, where it was used, and when it was used is retained for at least thirty years.
Be sure to review your written Hazard Communication Program with all employees when this program is first put into place. All new employees must be made aware of the details for your HCP, including where to find the written copy, the location of your SDS collection, how to read an SDS and the hazards associated with specific products and substances they will encounter in the workplace. This training must be provided before they start actual work. Cover all of the subjects listed in your HCP. The CVMA suggests conducting this training in the same fashion as the training required by your IIPP and that you keep similar records of training required under that program.
Document your HCP employee training by having them sign an attendance sheet verifying that they received, reviewed and understood the policy and all of its related documents. Use CVMA Form 12 – Employee Training Attendance Sheet to do this.
All employees must be given the Zoonotic Disease Prevention Program training module found under the “Training” section in the menu above. Any zoonotic diseases that are applicable to your practice must be reviewed with employees.
The training section of this guide also has zoonotic disease wall charts to assist with implementation of a prevention program.
Document your Zoonotic Disease Prevention Program employee training by having them sign an attendance sheet verifying that they received, reviewed and understood the policy and all of its related documents. Use CVMA Form 12 – Employee Training Attendance Sheet to do this.
The passage of SB 553 (Cortese) in 2023 requires nearly all California employers to implement a Workplace Violence Prevention Plan (WVPP) either as part of their Cal/OSHA Injury and Illness Prevention Plan, or as a stand-alone policy. Unlike other Cal/OSHA requirements, which are found in Title 8 of the California Code of Regulations, the WVPP requirements are part of statute in Labor Code section 6401.9. The law was implemented on January 1, 2024, but has an implementation deadline for employers of July 1, 2024. WVPP statute defines several workplace violence terms, classifies workplace violence into different types, and requires employers to implement a written policy document, maintain a workplace violence investigation and correction procedure (which includes a specific violent incident log), train employees, and establish and retain specified records for set time periods.
Complete subsections 1 through 21 of Chapter 6 to describe your workplace violence prevention plan. (See pages 22-24 of the Sample Guide to view a finished policy statement.) Each subsection will provide a brief prompt to assist you in understanding relevant information that needs to be entered. For reference, read this article for a more comprehensive view of what the WVPP policy must include. Much of the information that you enter in those subsections should also be included in your Workplace Violence Prevention Plan Training document which can be accessed in the “Training” section.
Should a workplace violence incident occur, use CVMA Form 14- Workplace Violence Incident Log in the “Download Additional Forms” section in the “Additional Resources” box on in your “My Guide” tab.
The California Code of Regulations, Title 8, Section 5162 (Emergency Eyewash and Shower Equipment) requires that emergency eyewash equipment that meets specified criteria be provided at all work areas where, during routine operations or foreseeable emergencies, the eyes of an employee may come into contact with a substance which can cause corrosion, severe irritation or permanent tissue damage or which is toxic by absorption. Water hoses, sink faucets, or showers are not acceptable eyewash facilities. In addition, an emergency shower which meets specifications must be provided at all work areas where, during routine operations or foreseeable emergencies, an area of the body may come into contact with a substance which is corrosive or severely irritating to the skin or which is toxic by skin absorption.
The regulations also require that emergency eyewash/shower stations be in accessible locations that require no more than 10 seconds for the injured person to reach. If both an eyewash and shower are needed, they shall be located so that both can be used at the same time by one person. The area of the eyewash and shower equipment must be maintained free of items which obstruct their use. The stations must supply potable water at specified flow rates and time durations.
Plumbed eyewash and shower equipment must be activated at least monthly to flush the line and to verify proper operation.
These regulations will apply to virtually all veterinary practices since, during the course of carrying out normal duties, employees’ skin and eyes can come into contact with substances that can cause corrosion, severe irritation or tissue damage, or toxicity. Therefore, to implement this section, practices must have ANSI-compliant eyewash and shower stations installed as needed throughout the practice to ensure that the “10-second” rule in subsection (c) is achievable.
Employees must receive instruction on how to operate emergency eyewash and shower stations, and for how long they should rinse in the event of an emergency. Employees should also be made aware of all locations of emergency eyewash/ shower stations. Documentation of employee training should be kept on file and should include employee signatures to indicate that they have received and understand the training. CVMA Form 12- Employee Training Attendance Sheet can be used to document employee training.
The California Code of Regulations, Title 8, Section 5155 outlines the requirements necessary for a workplace monitoring program. This program must be instituted if your practice utilizes either halothane or isoflurane. The specific implementation requirements are outlined in section (e):
(e) Workplace Monitoring.
Based on the note in sub-section (3) above, using an anesthetic gas monitoring badge appears to be a preferred method of implementation of this standard for Cal/OSHA. Monitoring badges are available through a number of sources. Searching for “Anesthesia Gas Monitoring Badges” on the internet will yield a number of businesses.
This section only applies to practices with employees who work outdoors. This includes employees of small animal practices who may walk dogs outside, do outside maintenance and landscaping, or perform other duties outside. Small animal mobile practices may also be considered to have outdoor employees. Most large animal practices will have outdoor employees. Implementation of your HIPP should include review of your HIPP Policy, which you have completed as part of this guide if you checked that you had outdoor workers in the additional questions section of the practice information page.
Heat Illness Training can be conducted using the training module provided in the training section of this guide. It can be accessed in the menu above. In addition to reviewing your practice HIPP policy with employees and completing the training module, the guide has a pocket guide located in the training section that can be distributed to employees.
Document your HIPP employee training by having them sign an attendance sheet verifying that they received, reviewed and understood the policy and all of its related documents. Use CVMA Form 12 – Employee Training Attendance Sheet to do this.
See the two training documents provided in the Training section of the Guide for guidance on training staff and on N95 mask use.
NOTE: In the training document for Wildfire Smoke Inhalation training, you will need to enter your practice name at the top of the document and then complete two form-fillable sections within the training document prior to presenting it to employees.
The first form-fillable section describes the method(s) by which the veterinary practice intends to communicate with employees to alert them that air quality is getting worse and to notify them of protective measures that they should be taking. It also should describe the method by which employees should communicate to the practice if they notice that air quality is getting worse or they are suffering from any symptoms due to air quality. This section should indicate the following:
The second form-fillable section should describe the practice’s methods to protect workers from wildfire smoke, including what actions the employer shall take if the AQI is greater than 151. The training document lists five examples of actions that the employer may take to protect employees. The practice may choose to adopt and list any or all of the five examples, or may elect to list a different method for protecting workers.
Any practice possessing a Class IIIA or above laser must implement a Non-ionizing radiation program that includes employee training, workplace postings and documentation. Details of the requirements can be found in the California Code of Regulations, Title 8, Section 1801. Here are the implementation requirements:
California employers must implement and administer a continuing, effective hearing conservation program whenever employee noise exposures equal or exceed an 8-hour time-weighted average sound level (TWA) of 85 decibels. An 8-hour time-weighted average is determined by computation. Guidance can be found here. While a rare occurrence in veterinary practices, this could be possible in a loud boarding kennel or in situations where the practice is located near sources of noise which qualify. The complete regulation can be found in the California Code of Regulations, Title 8, Section 5097.
Implementation will include monitoring of the workplace to determine if sound levels rise to or above the legal threshold for this requirement, audiometric testing of employees on a periodic basis to evaluate hearing (loss) including test requirements, and professional evaluation requirements. Monitoring usually requires professional service from an outside consultant since highly specialized equipment and testing expertise are required to obtain accurate results. The law also requires that employees be fit for their choice of personal protective equipment, shown how to use the equipment, and monitored to ensure that they are using the equipment in an ongoing and effective manner.
Employees must also receive training on how to use the equipment and employers are responsible for routine inspection of the equipment to ensure that it is in good and effective working condition. CVMA Form 12- Employee Training Attendance Sheet can be used to document this training.
For practices which utilize Ethylene Oxide (EtO) gas sterilizers, extensive Cal/OSHA regulations will apply. The law requires extensive safety measures, employee protection and monitoring, workplace postings, training, recordkeeping and reporting. Title 8, Section 5220 of the California Code of Regulations is written specifically for Ethylene Oxide.
In the absence of an infirmary, clinic, or hospital, in near proximity to the workplace, which is used for the treatment of all injured employees, California employers must ensure that a person or persons are adequately trained to render first aid. Training shall be equal to that of the American Red Cross or the Mine Safety and Health Administration. Title 8, Section 3400 of the California Code of Regulations provides implementation information.
First aid compliance must meet the following criteria:
For any practice that has an elevator, CCR Title 8, Sections 3000-3009 will apply. Implementation involves mainly permitting, installing and maintaining elevators.
GFCI electrical outlets are required for most California businesses with employees. If the building cannot achieve GFCI compliance, the employer must implement and maintain an effective electrical grounding program. To view the regulation, visit CCR Title 8, Section 2360.3.
While not an explicit law, Cal/OSHA encourages employers to institute workplace security measures on a proactive basis. Workplace violence and security is a topic of increasing importance. Homicide is the third largest cause of death in the workplace. While not legally mandated, Cal/OSHA offers guidelines on workplace security including how to implement and maintain a workplace violence and security program. Cal/OSHA recommends this program for all businesses, but especially for businesses engaged in:
The following are links to free Cal/OSHA resources for more information about instituting a workplace security program:
For practices that utilize boilers or air compressors, this set of regulations applies. They can be found in Title 8 regulations, Sections 450-560 and Sections 750-797.
View and print a sample of the CVMA Cal/OSHA Safety Plan
The Veterinarian-Client-Patient Relationship, or “VCPR,” is the Holy Grail of the practice of veterinary medicine. Business and Professions Code section
Water can destroy medical equipment, computer/phone systems, records, and supplies, and may cause significant damage to the walls and floors
The passage of SB 553 (Cortese) in 2023 requires nearly all California employers to implement a Workplace Violence Prevention Plan
CVMA Watchdog is exclusive to active members of the California Veterinary Medical Association (CVMA). The CVMA is one of the largest veterinary medical associations in the nation and assumed its leadership position through ambitious, innovative programs.
