Employer Responsibilities

To ensure worker safety, management and employees must share a commitment to a culture of safety. In a true culture of safety, mutual respect is present. Employees proactively identify unsafe conditions and behaviors and are empowered by management to intervene and correct them. Employees perceive the presence of a culture of safety based on multiple factors, including:

• Actions taken by management to improve safety
• Availability of written safety guidelines and policies
• Worker involvement in the writing of safety-related policies
• Management attitudes regarding safety practices
• Availability of relevant safety and protective equipment

All of these factors serve to communicate the organization’s attitude and commitment to safety. In a positive culture, safety is a core value of the organization, even at the expense of production or efficiency. A successful culture of safety depends on the active engagement of leadership. To protect sonographers, management must:

• Be aware of schedules and allow for adequate breaks. Scheduling templates should comply with local, state, and federal labor standards as well as facility policies for rest breaks and meal periods.
• Vary exam types whenever possible. A variety of exams throughout the day allows the sonographer to use different sets of muscles during different exams, thus allowing muscle groups to rest periodically. This is particularly important for physically demanding exams.
• Limit portable/bedside exams to critical patients, with task rotation implemented to reduce exposure rate.
• Provide adequate space in scanning rooms for proper patient positioning, workstation and ultrasound equipment optimization.
• Maintain reasonable expectations regarding the limitations of body habitus on the ability to obtain diagnostic imaging data.
• Provide equipment with exam specific features and adjustability for optimizing scanning posture. This includes not only the ultrasound system, but also the exam tables, scanning chairs, external monitors, and adaptive support devices.

Shared Sonographer-Employer Responsibility

Even in areas where the Occupational Safety and Health Administration (OSHA) has not set forth a standard addressing a specific hazard, there is employer and employee responsibility for complying with the Occupational Safety and Health Act of 1970 (OSH Act)¹². The general duty clause (Section 5) of the OSH Act states that:

Each employer

• shall furnish to each of his[/her] employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his[/her] employees;
• shall comply with occupational safety and health standards promulgated under this Act.

Each employee

• shall comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to this Act which are applicable to his[/ her] own actions and conduct.

Furthermore, the Occupational Safety and Health Act of 1970 gives employees and their representatives the right to confidentially file a complaint and request an OSHA inspection of their workplace if they believe there is a serious hazard or their employer is not following OSHA standards. Workers can file a complaint without fear of retaliation by calling 1-800-321-OSHA (6742), online via eComplaint Form, or by printing the complaint form and mailing or faxing it to the local OSHA area office.¹³

Excerpt from the Work Related Musculoskeletal Disorders in Sonography white paper.

6. Evans K, Roll S, Baker J. Work-Related Musculoskeletal Disorders (WRMSD) Among Registered Diagnostic Medical Sonographers and Vascular Technologists: A Representative Sample. Journal of Diagnostic Medical Sonography 2009;25(6):287-299.

12. OSHA Act of 1970. Occupational Safety and Health Administration 2016. Available at: https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=OSHACT&p_id=3359. Accessed July 15, 2016.

13. How to File a Safety and Health Complaint. Occupational Safety and Health Administration 2016. Available at: https://www.osha.gov/workers/file_complaint.html. Accessed July 15, 2016.