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Though they are dedicated to treating those suffering from injury or illness, inpatient health care settings boast distressingly high rates of workplace injury and illness. Accordingly, OSHA has announced that it will be dedicating its enforcement resources to reducing that number. OSHA identified the following five areas of focus in inpatient health care settings:
- Musculoskeletal disorders related to patient or resident handling
- Bloodborne pathogens
- Workplace violence
- Tuberculosis
- Slips, trips and falls
Fortunately, many of the workplace injuries caused by these hazards are easily preventable, and there are a number of steps that employers can take to reduce workplace illness and injury. In so doing, inpatient health care employers can minimize the risk of OSHA sanctions.
- Making a inpatient health care workplace safer involves three simple steps. Make sure to include all three in assessing and addressing workplace hazards.
- Understand the problem.
- Implement safety and health management systems.
- Educate employees on safety procedures and best practices.
- Read through OSHA’s memorandum to its inpatient health care facility inspectors. In it, OSHA outlines the specific inspection procedures that inspectors will be using, as well as specific remedies and suggestions for addressing the hazards. For convenience, that section has been reprinted in its entirety as an appendix to this document.
- Visit OSHA’s website and make use of the free resources the agency has made available. OSHA dedicated an entire page—https://www.osha.gov/dsg/hospitals/—to helping employers at hospitals minimize workplace hazards.
- Understand that some workplace injuries (like musculoskeletal disorders) can be radically reduced through training and education, while others (like bloodborne illnesses) will always be present and must instead be contained.
Understanding your workplace hazards and using the tools at your disposal can radically reduce workplace illness and injury in inpatient health care settings. Contact The Safegard Group, Inc. today with any additional concerns you might have about OSHA compliance in inpatient health care settings.
Appendix: OSHA’s Inspection Procedures for Focus Hazards and Other Hazards in Inpatient Health Care Settings
- Ergonomics: MSD Risk Factors Relating to Patient/Resident Handling.This section provides guidance for conducting inspections in workplaces in NAICS Code 622 and 623 as they relate to risk factors for musculoskeletal disorders (MSDs) associated with patient/resident handling. These inspections shall be conducted in accordance with the Field Operations Manual (FOM), and other relevant OSHA reference documents.
- Establishment Evaluation. Inspections of MSD risk factors will begin with an initial determination of the extent of patient/resident handling hazards and the manner in which they are or are not addressed. This will be accomplished by an assessment of establishment incidence and severity rates and whether the establishment has implemented a process to address these hazards in an effective way.Certified Safety and Health Officers (CSHOs) should ask for the maximum census of patients/residents permitted and the current census during the inspection. Additionally, CSHOs should inquire about the degree of ambulation of the patients/residents, as this information may provide some indication of the level of assistance given to patients/residents or the degree of hazards that may be present.Note: If there is indication from injury records or from employer or employee interviews that other sources of ergonomics-related injuries exist (e.g., MSDs related to office work, laundry, kitchen or maintenance duties), the compliance officer must include the identified work area and affected employees in the assessment.
- Program Evaluation. Compliance officers should evaluate program elements, such as the following:
- Program Management
- Is there a system for hazard identification and analysis?
- Is there a system for the development of strategies to address identified hazards?
- Who has the responsibility and authority to administer this system?
- What are the credentials or experience of the individual responsible for administering the program?
- What input have employees provided in the development of the establishment’s lifting, transferring or repositioning procedures?
- Is there a system for monitoring compliance with the establishment’s policies and procedures and for following up on deficiencies?
- Are there records of recent changes in policies/procedures and an evaluation of the effect they have had (positive or negative) on resident-handling injuries and illnesses?
- Program Implementation
- How is patient/resident mobility determined and how is the mobility determination communicated to staff?
- What is the decision logic for selection and use of lifting, transferring or repositioning devices?
- When and under what circumstances may manual lifting, transferring, or repositioning occur?
- Who decides how to lift, transfer or reposition patients/residents?
- Is there is an adequate quantity and variety of appropriate lifting, transferring, or repositioning assistive devices available that are operational? Note that no single lift assist device is appropriate in all circumstances. Manual pump or crank devices may create additional hazards.
- Are there adequate numbers of supplies, such as slings, batteries and charging stations, for lifting devices? (Note: There should be a minimum of one sling for every resident that needs the device and some extras to account for laundering and repair. There should be adequate numbers of batteries to accomplish all necessary lifts during a shift). There should be appropriate types and sizes of slings specific for all patients/residents.
- Are there appropriate quantities and types of the assistive devices (such as, but not limited to, slip sheets, mechanical lifts, sit-to-stand assists, walk assists or air-hover transfer pads) available within close proximity and maintained in a usable and sanitary condition?
- Are there appropriate policies and procedures in place to eliminate or reduce exposure to the manual lifting, transferring or repositioning hazards at the establishment?
- Employee Training
- Have employees (nurses and therapists) been trained in the recognition of ergonomic hazards associated with manual patient/resident lifting, transferring, or repositioning, on the early reporting of injuries, and on the establishment’s process for abating those hazards?
- Have the employees (nurses and therapists) been trained on proper techniques and procedures to avoid exposure to ergonomic risk factors and can they demonstrate competency in performing the lifting, transferring or repositioning task using the assistive device?
- Program Management
- Occupational Health Management
Is there a recognized process to ensure that work-related disorders are identified and treated early in order to prevent the development of more serious problems? And, does this process include restricted or accommodated work assignments?After evaluating the facility’s incidence and severity rates and the extent of the employer’s program, a decision will be made about the need to continue the ergonomic portion of the inspection. Where there is a need to address these issues, the Area Office (AO) will follow OSHA reference documents in determining whether to send an Ergonomic Hazard Alert Letter (EHAL), other communication or to issue citations. In all cases, the AO will notify the Regional Ergonomic Coordinator (REC) of the result of the inspection.OSHA will contact all employers who receive ergonomic hazard alert letters in order to determine whether the deficiencies identified in the letters have been addressed. Please refer to CPL 02-00-144, Ergonomic Hazard Alert Letter Follow-up Policy, for the process for contacting employers who receive ergonomic hazard alert letters. During this contact, OSHA may again provide information on available consultation and compliance assistance. In appropriate cases, OSHA will consider conducting another compliance inspection.Some states (e.g., California, Alaska, Minnesota, Washington and Oregon) have existing regulations or codes that can be applied to ergonomics-related injuries. In these cases, state or local regulations may support the 5(a)(1) element of industry recognition. - Citation Guidance
Refer to the FOM and other OSHA reference documents prior to proceeding with citation issuance. When conditions indicate that a General Duty Clause citation relating to patient/resident handling may be warranted, the AO will contact the REC and collaborate with the Regional Solicitor (RSOL) on the case prior to issuing a citation. Attachment 3 is provided only as an example of the language that may be used in an Alleged Violation Description (AVD) for patient/resident handling-related incidents.- Workplace Violence
OSHA Instruction CPL 02-01-052, Enforcement Procedures for Investigating or Inspecting Workplace Violence Incidents, establishes agency enforcement policies and provides uniform procedures which apply when conducting inspections in response to incidents of workplace violence. This Instruction directs CSHOs, who conduct programmed inspections at worksites that are in industries with a high incidence of workplace violence, such as health and residential care facilities, to investigate for the potential or existence of this hazard. - Tuberculosis (TB)
For further detailed guidance, CSHOs should refer to OSHA Instruction CPL 02-00-106, Enforcement Procedures and Scheduling for Occupational Exposure to Tuberculosis.NOTE: CPL 02-00-106 will soon be revised. Until then, CSHOs shall note the employer’s compliance with current CDC Guidelines: Centers for Disease Control and Prevention (CDC), Guidelines for Preventing the Transmission of Mycobacterium tuberculosis in Health-Care Settings, 2005, MMWR December 30, 2005/ Vol. 54/ No. RR-17.* - Bloodborne Pathogens
CSHOs should refer to OSHA Instruction CPL 02-02-069, Enforcement Procedures for Occupational Exposure to Bloodborne Pathogens. - Slip, Trips and Falls
If employees are exposed to hazards from falling while performing various tasks, including maintenance from elevated surfaces, then OSHA Instruction STD 01-01-013, Fall Protection in General Industry, should be reviewed to determine the applicability of 29 CFR 1910.23(c)(1), 1910.23(c)(3) and 1910.132(a). - Other Hazards
As detailed in the FOM, CPL 02-00-150, when additional hazards are brought to the attention of the compliance officer, the scope of the inspection may be expanded to include those hazards. Although they are not included in the focus hazards for inspections conducted in inpatient health care settings in NAICS Code 622 and 623, unprotected occupational exposures to multi-drug resistant organisms, or exposure to hazardous chemicals (i.e., hazard communication) should be investigated if these or other hazards are brought to the attention of the compliance officer during the course of an inspection.- Methicillin-resistant Staphylococcus aureus (MRSA) and other multi-drug resistant organisms (MDROs)
Compliance officers are expected to investigate situations where it is determined during inspections conducted in such workplaces that employees are not protected from potential transmission of MDROs, such as MRSA.Refer to the FOM and other OSHA reference documents prior to proceeding with citation issuance. Recommendations for standard precautions and contact precautions to reduce or eliminate exposure to MRSA and other MDROs are outlined in CDC guidelines, including the 2007 Guideline for Isolation Precautions: Preventing Transmission of Infectious Agents in Healthcare Settings. [12, CDC] Attachment 3 contains information that is provided only as an example of language that may be used in an AVD for unprotected occupational exposure to MRSA specific to nursing and residential care facilities.NOTE: Violations of applicable OSHA standards—e.g., personal protective equipment (PPE) standards—must be documented in accordance with the FOM. In General Duty Clause citations, the recognized hazard must be described in terms of the danger to which employees are exposed, e.g. the danger of being infected by MRSA, not the lack of a particular abatement method. Feasible abatement methods that are available and likely to correct the hazard must be identified. - Hazard Communication
Employee exposure to hazardous chemicals, such as sanitizers, disinfectants and hazardous drugs, may be encountered in inpatient health care settings in NAICS Codes 622 and 623. Employers are required to implement a written program that meets the requirements of the Hazard Communication standard (HCS) to provide worker training, warning labels and access to Material Safety Data Sheets (replaced with Safety Data Sheets (SDS) under the HCS revised in 2012).NOTE: Inspection and citation guidance are contained in OSHA Instruction, CPL 02-02-038, Inspection Procedures for the Hazard Communication Standard. A revised HCS compliance instruction (CPL) will soon be issued, at which point CSHOs shall follow the revised HCS CPL.
- Methicillin-resistant Staphylococcus aureus (MRSA) and other multi-drug resistant organisms (MDROs)
- Workplace Violence
Article sourced from the Occupational Safety and Health Administration https://www.osha.gov/dep/enforcement/inpatient_insp_06252015.html
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