Facility Compliance Intelligence

OSHA & ADA Compliance
for Arizona Medical Offices

Physical facility compliance is a capital variable in every Arizona optometry transaction. Unresolved ADA violations or OSHA deficiencies discovered during due diligence become escrow holdbacks — or transaction killers. Lumina maps facility compliance requirements before capital is committed.

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Compliance Intelligence

Why Facility Compliance Matters at Acquisition

When a buyer acquires a medical practice, they inherit its facility's compliance status — including any pre-existing violations. Lumina Medical Capital integrates facility compliance review into every transaction's due diligence protocol, protecting buyers from inheriting undisclosed liability and helping sellers remediate issues before they erode negotiating position.

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ADA Title III — Places of Public Accommodation

Optometry practices open to the public are places of public accommodation under ADA Title III. Facilities constructed or significantly renovated after January 26, 1993 must meet the 2010 ADA Standards for Accessible Design. Pre-1993 facilities must remove barriers where "readily achievable." Acquisition triggers a fresh compliance obligation assessment.

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OSHA Bloodborne Pathogens

29 CFR 1910.1030 requires written Exposure Control Plans, annual staff training documentation, hepatitis B vaccination program records, and post-exposure procedures for all practices where staff may contact blood or OPIM (other potentially infectious materials) — including contact lens fitting and certain ophthalmic procedures.

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Hazard Communication

OSHA's Hazard Communication Standard (29 CFR 1910.1200) requires Safety Data Sheets for all chemical products — ophthalmic dilating agents, disinfectants, cleaning solutions — and a written Hazard Communication Program accessible to all employees. An SDS library gap discovered during acquisition due diligence is a common escrow holdback trigger.

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Arizona Fire & Building Code

Maricopa County medical office occupancies are classified as Group B (Business) or Group I-2 (ambulatory healthcare facility if patients are incapable of self-preservation) under the IBC. Occupancy classification determines sprinkler requirements, egress specifications, and fire separation distances — all of which impact build-out capital requirements for acquired or newly leased spaces.

ADA Checklist

ADA Physical Access Checklist — Optometry Office

These are the highest-frequency ADA findings in Arizona optometry practice acquisitions and facility renovations.

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Accessible Parking
Minimum 1 accessible space per 25 total spaces; van-accessible space required; proper signage and access aisle dimensions (60" min).
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Accessible Route
Continuous accessible path from parking to building entrance, minimum 36" clear width throughout, slopes ≤1:20 on walking surfaces.
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Entrance Door
Minimum 32" clear opening width; lever or push hardware; maximum 5 lbf opening force for interior doors; accessible door hardware at 34"–48" height.
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Reception Counter
Accessible transaction surface at 28"–34" AFF with minimum 30" x 48" clear floor space for wheelchair approach. Required at all check-in counters.
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Exam Room Access
Minimum one exam room on accessible route with 60" turning radius, accessible exam chair, and side-transfer space. Not required for all exam rooms in multi-room practices.
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Accessible Restroom
If restroom provided, must be fully accessible: 60" turning radius, grab bars, accessible fixtures, proper reach ranges, and correct door hardware and clearances.
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Optical Frame Display
Merchandise within reach range (15"–48" AFF for side reach; 20"–44" AFF for forward reach); aisles between displays minimum 36" clear width.
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Signage & Wayfinding
Tactile and Braille signage required for permanent rooms and spaces; mounting at 60" AFF centerline; non-glare finish and compliant character proportions.
OSHA Checklist

OSHA Compliance Checklist — Optometry Practice

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Written Exposure Control Plan
Current (updated annually), accessible to all employees, identifies job classifications with exposure potential, and documents engineering and work practice controls.
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Annual BBP Training Records
Documented annual training for all exposed employees; records must include date, content summary, trainer name, and employee names with signatures. Retain 3 years.
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SDS Library (Hazard Communication)
Current Safety Data Sheets for all chemical products; accessible to employees during all work shifts; written HazCom program identifying responsible persons.
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OSHA 300 Log (Injury & Illness)
Required for establishments with 10+ employees; must be posted Feb 1–Apr 30 annually; retain logs 5 years. Review for patterns that indicate unremediated hazards.
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Eye & Face Protection Program
Written program required when splash hazard exists (dilating agents, irrigation); appropriate PPE available and documented in training records.
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Emergency Action Plan
Written EAP required for all facilities with 10+ employees; must include evacuation procedures, emergency contacts, employee duties, and be posted at conspicuous locations.
Facility Capital Intelligence

Leasehold Improvement Capital

ADA and OSHA remediation is capital — not overhead. When compliance deficiencies require physical facility upgrades, Lumina structures the improvement capital to execute remediation efficiently and permanently.

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Capital Deployment

Compliance Gaps Are Capital Events

Every compliance deficiency discovered during acquisition due diligence becomes a negotiating point. Sellers who remediate proactively control the narrative — and the multiple. Lumina integrates facility compliance review into every transaction from day one.

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