Does a Texas Vet Clinic Need a Written OSHA Safety Plan?

State OSHA coverage

Texas does not operate an OSHA-approved state plan. Federal OSHA states: "Texas is not an OSHA-approved State Plan, and is under federal OSHA jurisdiction which covers most private sector workers within the state". The federal requirements in this plan are therefore the applicable occupational safety standards for a private Texas veterinary practice — there are no state-plan additions to layer on top. ¹

State overlays to fold into the plan

Texas registers veterinary x-ray machines through the DSHS Radiation Control Program under 25 TAC §289.233: "apply for registration with the agency within 30 days after beginning use of the radiation machine"; mobile services need authorization before providing service. ^{2 3}

Apply with DSHS forms RC 226-2 (machine application), RC 226-1 (business information), RC 42-R (Radiation Safety Officer designation), and RC 204 (Radiation Machine Source Unit). ³

Veterinary clinics are squarely covered by Texas's medical-waste rules: the DSHS "special waste from health care-related facilities" rules apply to "clinics, including but not limited to medical, dental, veterinary", so sharps generated by the practice are regulated medical waste under 30 TAC Chapter 326 (TCEQ). The "animal waste" category is narrower — waste from animals intentionally exposed to pathogens — so ordinary animal waste is not medical waste, but your sharps always are. ^{4 5 6 7}

Records the plan should point to

Controlled-substance records — 5 years. Texas veterinarians "shall maintain at their place of business records of all scheduled drugs listed in the Texas Controlled Substances Act in their possession. These records shall be maintained for a minimum of five years." The record must be per-drug, "complete, contemporaneous, and legible," and show date of acquisition, quantity purchased, date administered or dispensed, quantity administered or dispensed, client and patient name, and a running balance on hand. The CS log in this kit captures all six elements — keep completed logs, invoices, and inventories for five years, not the federal two. ⁸

Patient medical records and radiographs — 3 years after the last visit; TBVME's inspection standards (22 TAC §§573.52/573.53) require individual records to be "maintained at the veterinarian's place of business" and to be complete, contemporaneous, and legible. ^{9 10 11}