Is Your Clinic Ready for an OSHA Inspection?Why Outpatient Facilities Are Under the Microscope in 2025 — and How to Prepare

By: Drew Duffy, MHA, FACHE

From dental offices to IV lounges, OSHA’s compliance spotlight is expanding. Here’s what your clinic needs to know.

The Occupational Safety and Health Administration (OSHA) is no longer focused solely on large hospitals and inpatient facilities. As of 2025, outpatient clinics — including primary care, specialty practices, mobile health units, and even IV therapy centers — are firmly in OSHA’s crosshairs.

Many small healthcare providers mistakenly believe they are too small to trigger attention. But in reality, OSHA has expanded its enforcement in precisely your direction, with several key changes in inspection priorities and compliance expectations.

Let’s break down what’s happening, why it matters to your practice, and what you can do about it — before a complaint, injury, or audit lands you on OSHA’s radar.

🚨 Why OSHA Is Paying More Attention to Clinics in 2025

1. Increased Enforcement of National Emphasis Programs (NEPs)
   OSHA continues to prioritize certain workplace hazards via NEPs — focused campaigns that direct inspectors to industries with known risks.
   Healthcare is now a high-priority industry under multiple NEPs, including:
   • Respiratory protection (post-COVID focus)
   • Workplace violence prevention
   • Bloodborne pathogens and sharps injuries
   • Heat illness prevention (especially for mobile or outdoor services)
   Even clinics without a history of incidents may be subject to random inspections or follow-up if OSHA is investigating other nearby healthcare employers.

2. Post-COVID Fallout: Compliance Gaps in Small Clinics
   The pandemic exposed serious gaps in how small providers protect staff — especially around PPE, exposure control, and hazard communication. In 2024–2025, OSHA began following up with outpatient clinics that previously self-reported deficiencies or received citations under the Emergency Temporary Standards.

3. State-Level Enforcement in Minnesota Is Stepping Up
   Minnesota operates its own OSHA plan (MNOSHA), which tends to be more proactive than federal OSHA. Clinics in Minnesota face a higher likelihood of inspection, especially if:
   • You offer procedures involving sharps, anesthesia, or blood products
   • You’ve had staff injuries or filed workers’ comp claims
   • A patient, vendor, or employee files a complaint

🧯 5 Core OSHA Risks in Outpatient Clinics

Even if your clinic looks clean and professional, it may be out of compliance on paper — and that’s all OSHA needs to issue fines or require mandatory correction.

1. No Written OSHA Program
   Does your clinic have a written Exposure Control Plan, Hazard Communication Plan, or Emergency Action Plan?
   If not, you’re already out of compliance. These documents are required for any workplace where staff could be exposed to blood, chemicals, or emergency scenarios — including medical clinics, dental offices, mobile IV lounges, and wellness spas.

2. Missing or Incomplete Bloodborne Pathogen Training
   Are your employees trained annually on bloodborne pathogen safety and sharps handling?
   OSHA requires annual, documented training. Staff who handle even a single lancet, needle, or blood specimen fall under this rule.

3. Lack of Respiratory Protection Program
   If you require or allow N95 or KN95 use in your clinic, do you have a written Respiratory Protection Program (RPP)?
   Without an RPP — including fit testing and medical clearance where required — your clinic may be violating both federal and MN OSHA standards.

4. Failure to Post Required Notices or Report Injuries
   Is your OSHA 300 log up to date? Do you know which injuries must be reported within 24 hours?
   Many clinics fail to file injury logs, especially if they’re small. But if a staff member is hospitalized, loses an eye, or suffers amputation — even if they’re treated and return to work — you must report within 24 hours.

5. Workplace Violence Prevention: A New Requirement
   Do you have a plan to prevent, report, and respond to workplace violence or threats?
   This is especially relevant for behavioral health clinics, urgent care, and clinics serving high-risk populations. OSHA now considers workplace violence a foreseeable hazard in healthcare — meaning you must actively plan for it.

🧠 OSHA and Mental Health Clinics: A Growing Focus Area

Mental health clinics, counseling centers, and behavioral health providers face unique OSHA compliance challenges that are often overlooked.

While many think OSHA only applies to settings with obvious physical hazards, behavioral health settings have distinct risks that OSHA is increasingly scrutinizing, including:

• Workplace violence and staff safety: Behavioral health clinics report higher incidents of patient aggression, verbal threats, and physical assaults. OSHA now classifies workplace violence as a foreseeable hazard in healthcare, requiring clinics to have formal prevention and response plans.

• Staff burnout and ergonomic concerns: Long hours, high emotional stress, and inadequate breaks can lead to musculoskeletal injuries and mental fatigue — all OSHA-relevant workplace health issues.

• Confidentiality and workspace design: Maintaining patient privacy while ensuring staff safety requires thoughtful clinic layout and policies that comply with OSHA’s standards for environmental safety.

Minnesota’s MNOSHA has been particularly active in visiting behavioral health providers to verify workplace violence prevention policies and evaluate staff training.

If you run a mental health clinic, don’t assume OSHA won’t come knocking. Preparing a solid workplace violence prevention plan and training your team is now a best practice — and increasingly, a legal requirement.

💥 Real-World Penalties for Non-Compliance

Even a basic OSHA violation — like failure to maintain training records — can trigger fines starting at $1,500 to $15,000 per item. In 2025, the penalty cap for serious violations rose to over $16,000 per citation — with additional daily fines for uncorrected issues.

In recent outpatient clinic citations, OSHA issued penalties for:
• No Exposure Control Plan for sharps/needles
• No annual BBP training
• Using expired disinfectants or unlabeled chemical containers
• Missing eyewash stations in treatment rooms where chemicals were stored

✅ What You Can Do Today to Prepare

You don’t need a 300-page binder — but you do need written plans, training documentation, and safety protocols that match your clinic’s scope.

Start with these 5 steps:

1. Create or update your Exposure Control Plan and Hazard Communication Plan.

2. Conduct and document annual staff training on bloodborne pathogens, workplace safety, and emergency procedures.

3. Review your PPE policies, including respiratory protection, gloves, and gowns.

4. Audit your injury logs and incident reporting practices.

5. Establish a basic Workplace Violence Prevention Policy.

If you have mobile units or unique procedures (like IV therapy or regenerative medicine), you may need additional hazard assessments to stay compliant.

-Drew

🛡️ ClearPath Can Help You Get OSHA-Ready — Without the Overwhelm

We help clinics across Minnesota and the Midwest navigate OSHA compliance with practical, affordable solutions that don’t disrupt patient care.

• Custom OSHA plans and templates
• Staff training (virtual or in-person)
• Emergency preparedness and documentation audits
• Mock inspections and compliance coaching

Whether you're building a clinic from scratch or responding to a recent incident, ClearPath makes compliance clear, manageable, and clinic-friendly.

📞 1-888-996-8376
📧 info@clearpathcompliance.org
🌐 www.clearpathcompliance.org

Discounted services available for clinics serving underserved or publicly insured populations.