FAQs

If you have other questions or would like to order the Interactive Regulatory Guide or other regulatory-related items from the CVMA, visit the CVMA Products section of our website or call 800.655.2862. 

Please choose one of the following for detailed information: 

  

Cal/OSHA Inspections 

How frequently must I inspect my hospital/clinic?

There is at least one area in California where Cal/OSHA inspectors insist upon monthly safety inspections of facilities like veterinary hospitals. The CVMA suggests doing the inspections monthly, at least initially. If you can establish a pattern of finding no unsafe conditions, you may be able to justify less frequent inspections. Keep documentation of your inspection results to show any inspector who might question your inspection intervals. 

What are my rights if a Cal/OSHA inspector shows up at my front door?

You can and should ask for identification. All state inspectors will have and should be happy to show their photo ID cards. You can demand an inspection warrant, but that will only buy you a day or so. It's probably not worth the risk of upsetting the inspector, although Cal/OSHA insists that will not happen. Stay with the inspector except when he/she wants to interview employees in private. Inspectors are not required to inform you of the reason for the inspection. 

Cal/OSHA inspectors will arrive unannounced, but they may be willing to wait until an owner or manager can return to the practice if the owner is not present. In some cases, they may be willing to return at a later time—there's no harm in asking. 

What problems are most often found in a veterinary hospital/clinic?

  • Incomplete written safety program
  • Inadequate or missing secondary labels
  • Incomplete hazardous substances list
  • Incomplete MSDS collection
  • Electrical wiring problems and improper use of extension cords
  • Unsecured storage shelves and bookcases
  • Human food stored or consumed in areas considered unsafe


What triggers a Cal/OSHA inspection?

Employee complaint or serious injury or illness have been the basis of all Cal/OSHA inspections of which we are aware. None have been part of a scheduled or random inspection program. 

Does Cal/OSHA fund itself with the money generated by fines?

Funding for Cal/OSHA comes from two sources—some federal money and the state general fund. All revenues generated by fines are sent back to the general fund. 

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Practice Procedures

Do I need to monitor exposure to waste anesthetic gases?

At the present time there is no requirement to monitor waste anesthetic gas levels. However, you must keep exposure levels below 2 ppm on a time weighted average. There are several badge systems (available from some veterinary distributors) for measuring waste anesthetic gas exposure. 

What are the requirements for disposing of syringes?

Used needles are to be treated as sharps waste; the syringe barrel and plunger, in most areas of California, can still be treated as normal waste and can be discarded in the regular trash stream. We recommend, however, that the syringes be discarded with the rest of your medical waste. There have been headline newspaper articles showing syringes from veterinary hospitals found in the street. These articles often name the veterinarian and the hospital involved—not the kind of PR we want. Some counties do not allow syringes to be put into their landfills. In these areas, you will be required to dispose of them as medical waste. 

What are the options for disposal of radiographic fix?

Spent radiographic waste must not be put into the sewer or septic system; it must be taken from your facility by a licensed hauler. Alternatively, you can treat the fix on-site to remove the silver from the fluid. Once the silver is removed, the remaining fluid can be put into the sewer system. 

Do the Blood Borne Pathogens Regulations apply to veterinary medicine?

At the present time, these regulations apply specifically to human blood and tissue; therefore, they do not apply to veterinary practices except under conditions where employees might be exposed to human blood as part of their assigned duties (such as first aid providers). 

Can I permit or should I require pregnant employees to wear gas masks while working in surgery?

No. Gas masks are to be used only when all other procedural and engineering measures have been taken and exposure still cannot be eliminated. To minimize risk from anesthetic gases, use charcoal canisters or scavenging systems and limit the employee's exposure time. 

To minimize exposure risk to anesthetic gases: 

  • Use a scavenging system to vent the anesthetic gas to the outside or a charcoal canister to absorb the gas.
  • Provide adequate ventilation in the surgery/recovery areas.
  • Train employees in the safe use of anesthetic equipment, including leak testing and proper filling techniques. 


The use of gas masks would also require implementation of a Respiratory Protection Program that includes a written program and an extensive set of requirements. These requirements include a physical examination by a physician to make sure the employee is capable of breathing properly while using a gas mask and "fit testing" to assure that leaks do not occur. The full Respiratory Protection Program is required whenever masks are used for respiratory protection. An exception is allowed for the use of approved dust masks to protect against "incidental dust," as might be found while sweeping out a barn. 

Do I need to have employees trained in first aid/CPR?

Cal/OSHA is apparently using an emergency response time of four minutes to determine your need to assign first aid duties to your employees. If emergency care is available to your location within four minutes (fire department, EMTs, etc.), you do not need to train a team of your own. If you are in a remote area, however, you are required to provide and train someone to provide first aid for each work shift. The phrase "adequate training" is used in the regulations but is not defined. American Red Cross training is the type of training described by Fed/OSHA as being adequate. 

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Procedures for Chemicals

I use ethylene oxide. Do I need to do anything special?

Ethylene oxide (EtO) is considered a highly carcinogenic agent and therefore has some strict requirements for its use. Your supplier should be able to help you meet the requirements. In addition to carefully limiting human exposure, you need to send a "report of use" to Cal/OSHA. It is important to conduct initial exposure monitoring when EtO is introduced into your practice. Contact the CVMA if you are using EtO and have additional questions. 

Are there special requirements for using formaldehyde?

Formaldehyde is also considered a highly carcinogenic agent, but the 10% solution the labs provide for tissue fixation is not considered hazardous. Again, Cal/OSHA requires a "report of use" form or documentation that exposure is below the action level. Typical use in a veterinary hospital almost certainly will not cause exposure above the action level, but there is no documentation supporting that view available at this time. Badges are available to measure formaldehyde exposure if you elect to document exposure in your work setting. If you choose to neither measure your exposure nor to file a "report of use," be prepared to justify your decision. If you choose to file a "report of use" with Cal/OSHA, be prepared for a possible inspection. Filing a "report of use" can occasionally trigger a Cal/OSHA enforcement inspection. 

How long can I store open containers of ether?

Old open cans of ether can pose an explosion risk if not handled carefully. Exposure to air permits the formation of peroxides which tend to form crystals. These peroxide crystals are shock sensitive, exploding when moved or jarred. Extreme care must be used when moving any old can of ether. Cal/OSHA calls the Bomb Squad when they find an old can of ether. A Material Safety Data Sheet (MSDS) provided with cans of ether states that any unused portion should be discarded after one or two days. A possible alternative is to use the pressurized cans of starter fluid that are normally sprayed into carburetors. These are usually composed of almost 100% ether. Because the containers are not opened and exposed to air, the likelihood of peroxide formation is greatly reduced, and these products can be stored for longer periods. 

What is required on a secondary label?

  • The name of the substance
  • The hazards associated with the substance 


Do I need to dispose of used vaccine vials as medical waste?

No. In most cases, we can still handle these as normal trash. There are two exceptions: 

  • Contagious ecthyma
  • Brucella 

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Posted Signs

Which posters do I need to display?

Cal/OSHA requires the following: 


Department Of Health Services requires the following:

Other Agency Requirements 

  • Harassment or Discrimination in Employment (California Dept. of Fair Employment and Housing)**
  • Payday Notice**
  • Voters Time Off Notice**
  • Minimum Wage and Overtime (California – Dept. of Labor)**
  • Employee Polygraph Protection Act (Dept. of Labor)**
  • Unemployment Insurance and Disability Insurance Notice (EDD)**
  • Access to Medical and Exposure Records**
  • Workers Compensation Notice**
  • Equal Opportunity Employment Commission Poster with ADA Revisions (EEOC)**
  • Wage Order 5-2001
  • USERRA Notice    

Veterinary Medical Board (VMB) 

  • VMB License for DVMs and RVTs
  • Premises Permit
  • Abandoned Animal Notice
  • Written Prescription Option for Client    

** Available from the CVMA 

*** Not required for facilities with fewer than 10 employees. 

Do I need a "Microwave in Use" sign for our microwave in the lunch room?

No. Cal/OSHA representatives have stated that the sign requirements are intended for large industrial microwave units, not the type used in homes. 

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Employees

What are my responsibilities with an employee who has trouble remembering Cal/OSHA-related training?

As with all employees, document any training which is provided. Beyond your responsibility to provide adequate training, you should take steps to prevent placing an employee with special needs in a situation dangerous to that individual. For example, don't use an employee for patient restraint if that individual can't remember how to hold animals. 

What is a Log 300? Do I need to complete one?

A Cal/OSHA form 300 is a form used to record certain work-related injuries and illnesses. The summary portion of the Log (Form 300A) must be posted for a three-month period from February 1 through April 30. If you have 10 or fewer employees, you are exempt from this requirement. 

What kinds of injuries must be reported to Cal/OSHA?

Any fatality or serious injury or illness. Serious means hospitalization for more than 24 hours or any injury that causes permanent disfigurement. These reports must be made by telephone within eight hours. 

What kinds of injuries must we investigate? Scratches or bites?

All injuries and illness should be investigated. In fact, you should also investigate near misses or any unusual occurrence. 

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Equipment

Do I need to install an eye-wash station?

Yes. Virtually all veterinary clinics/hospitals will need an eye-wash station. Just the use of cleaning solutions such as bleach, Parvasol, Novasan, etc. would probably require an eye-wash station. Radiographic developer and fix, formaldehyde, anesthetic gases, alcohol, and other substances further reinforce this requirement. 

What kind of eye-wash station is acceptable?

As of mid-1995, Cal/OSHA has a policy of accepting certain faucet mounted eye-wash station. If the manufacturer is willing to state that their unit meets the required ANSI standards for eye-wash stations, Cal/OSHA will accept the unit. There is at least one manufacturer willing to provide such a statement. 

The best solution is to use a dedicated eye-wash station plumbed with cool water only. This unit should have two streams of water and must be capable of being activated with one motion. Once activated, the unit must remain on, with no further action required. Most plumbers can obtain and install these units for you. 

Do I need to install an active waste anesthetic gas scavenging system?

Cal/OSHA does not specify how you are to maintain safe levels of waste anesthetic gases in the workplace, only that you must keep these levels below 2 ppm (time weighted average exposure) for halothane and isoflorane. Active or passive scavenging systems, charcoal filters, adequate ventilation, limited use of anesthetic gases, or any combination of these can be used. 

Is emergency lighting required?

The only specific requirement for a veterinary facility that I can find is in the surgery area, where emergency lighting is required by the Veterinary Medical Board. Cal/OSHA might require emergency lighting in some areas where it would be needed in an emergency, such as a dark stairwell used as an exit. 

Do I need to install illuminated exit signs?

Cal/OSHA regulations require large illuminated exit signs similar to those we see in movie theaters and auditoriums. There is an exemption, however, for buildings or rooms with an occupancy load of 50 or less. This includes most veterinary facilities where non-illuminated signs are acceptable. Check local fire department requirements. Some very large hospitals or those located in shopping centers may be required to have such signs in place.

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Material Safety Data Sheets (MSDS)

How many MSDS's am I required to have?

The average MSDS collection in a veterinary facility will be very extensive. Most will fill at least one 4-inch three-ring binder. Many will require more. Some of the information included might not be required, but it is better to have too much information available than too little. 

Do I need an MSDS for pharmacy items?

Probably not, especially if you are only dispensing an item and not administering the product. But MSDS's are becoming easier to obtain, and there is no penalty for having too much information. The CVMA recommends having an MSDS in your collection for pharmacy items, or use a copy of the drug insert if an MSDS is unavailable. 

Is the AVDA MSDS book OK to use as is?

Probably not. But if you prepare an index that can be used to find a specific MSDS, a collection like the AVDA MSDS book published and distributed in 1990 will probably be acceptable. The key will be your staff's ability to locate a specific MSDS. Make sure they are familiar with your organizational system and can find any MSDS within a few minutes. With a little practice, most employees will need only 30-60 seconds. 

How should I organize my MSDS collection?

Cal/OSHA has not specified any particular organizational structure. They simply want the information contained in an MSDS to be readily available. Any logical organizational system should be adequate as long as your employees know your system. The CVMA suggests a simple alphabetical system without subcategories or sections. 

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Miscellaneous

Where can we store and consume human food?

Cal/OSHA requires that storage and consumption of food occur only in areas where contamination by hazardous substances will not occur. Therefore, human food cannot be placed in the same refrigerator used to store biologicals, antibiotics, or lab supplies. Food should not be consumed in most areas of veterinary clinics/hospitals. 

Does the CVMA have a waste anesthetic gas monitoring service?

Not at this time. Waste anesthetic gas measuring badges are available from some veterinary distributors. 

What should be included on my hazardous substances list?

Anything that may pose any sort of threat. Your lists will be very long. Anything on this list should have an MSDS or equivalent information sheet available in your MSDS collection. 

How long must I keep radiographs?

Radiographs are considered to be part of your medical records and must be maintained for at least three years beyond the last medical entry. 

What is an SIC Number?

SIC is the acronym for Standard Industry Code. All industries are assigned a code number by a federal agency. The code for veterinary services is 0742. The code for agriculture is 07, and veterinary medicine is considered a subdivision of agriculture services in this system. 

What is the waste code for radiographic fix?

There are two codes which could apply to radiographic fix. The first—a state code for fix—is 541. This is the code that was used for state forms from the DTSC (Cal/EPA). The second—a federal code for silver—is D011. 

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