In , BLS data reported that days-away-from-work cases were caused by approximately 14, assaults by persons in hospitals and nursing and residential care facilities. Hospitals reported approximately 5, assaults and nursing and residential care facilities reported approximately 8, assaults.
Other sectors in the healthcare industry have WPV concerns as well. Injuries from STFs were also among the nonfatal occupational injury and illness cases reported in nursing and residential care facilities. Taken together, overexertion together with slips, trips, and falls accounted for Other Hazards. Hazards other than those selected for focus in this initiative are likely to exist in inpatient healthcare settings.
For example, a commonly recognized hazard in these settings is exposure to multi-drug resistant organisms MDROs , such as methicillin-resistant Staphylococcus aureus MRSA. The CDC has identified healthcare settings, such as hospitals and nursing care facilities, among those at increased risk for colonization with MRSA, and recommends that employers institute standard precautions and contact precautions to protect workers who must provide care and services to residents or patients colonized with MRSA or other MDROs.
Employee exposures to hazardous chemicals, such as sanitizers, disinfectants, anesthetic gases, and hazardous drugs e. A recent article in the American Journal of Infection Control notes that, in addition to environmental service workers, many other healthcare workers routinely use cleaning and disinfecting products. These chemicals are both irritants and sensitizers, causing a variety of adverse health effects, including eye irritation, irritant and allergic contact dermatitis, upper and lower respiratory symptoms, work-related asthma and chronic bronchitis.
Note: Some cleaning and disinfecting chemicals are known to be mutagens, carcinogens and reproductive toxins. The article reviews knowledge gaps and research priorities and calls for a more integrated approach to both occupational illness prevention and infection control.
Establishment Evaluation. 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 manner. Note: If there is indication from injury records, or from employer or employee interviews that other sources of ergonomics-related injuries exist e.
Is there a recognized process to ensure that work-related disorders are identified and treated early to prevent the development of more serious problems and whether this process includes 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. OSHA will contact all employers who receive an ergonomic hazard alert letter to determine whether the deficiencies identified in the letter have been addressed.
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. In these cases, State or local regulations may support the 5 a 1 element of industry recognition. This Instruction directs CSHOs, who conduct programmed inspections at worksites that are in industries with high incidence of workplace violence, such as health and residential care facilities, to investigate for the potential or existence of this hazard.
Although they are not included in the focus hazards for inspections conducted in inpatient healthcare settings in NAICS Codes and , unprotected occupational exposures to multi-drug resistant organisms, or exposure to hazardous chemicals i. 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.
In General Duty Clause citations the recognized hazard must be described in terms of the danger to which employees are exposed, e. Feasible abatement methods that are available and likely to correct the hazard must be identified. Employee exposures to hazardous chemicals, such as sanitizers, disinfectants, and hazardous drugs may be encountered in inpatient healthcare settings in NAICS Codes and Section 5 a 1 of the Occupational Safety and Health Act of The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause serious physical harm to employees, in that employees were required to perform lifting tasks resulting in stressors that have caused or were likely to cause musculoskeletal disorders MSDs : a.
Feasible means of abatement include but are not limited to implementing a safe patient handling and movement policy for transferring and lifting of non-weight bearing and partial weight bearing residents.
This necessitates the use of mechanical lift assist and transfer devices. Note: AVD must be adapted to the specific circumstances noted in each inspection.
The AVD above is an example that will be appropriate in some circumstances. Section 5 a 1 of the Occupational Safety and Health Act of The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to communicable diseases:. Location - Address: On or about Date employees were exposed to drug-resistant infections while providing care to residents with infections such as, but not limited to, Methicillin-Resistant Staphylococcus aureus MRSA.
Standard Number:. Section 5 a 1. Department of Labor. Other Hazards: In addition to the focus hazards listed above, and hazards that may be the subject of the programmed or unprogrammed inspection, other hazards that may be encountered in inpatient healthcare settings include, but are not limited to: Exposure to multi-drug resistant organisms MDROs , such as Methicillin-resistant Staphylococcus aureus MRSA.
Exposures to hazardous chemicals, such as sanitizers, disinfectants, anesthetic gases, and hazardous drugs. The NEP will focus primarily on hazards that the statistics show are prevalent in nursing and residential care facilities: ergonomic hazards associated with patient lifting and handling, bloodborne pathogens, tuberculosis; workplace violence; and slips, trips, and falls.
The NEP will also focus on exposure to hazardous chemicals—including some that may raise some eyebrows: hand sanitizers, disinfectants, and drugs administered to patients. This list of focus hazards is notable for several reasons.
Second, this list is a good basis for nursing and residential care employer self-audits or third-party audits. Please discuss with your NP attorney whether it is appropriate to conduct such audits under attorney-client privilege in whole or part.
This always raises a potential concern about agency overreaching since specific standards can be onerous but they also often serve to limit the scope of enforcement activity as well.
For example, a new NEP-specific inspection list will be created in using data from the data initiative, which covers calendar year Placement on the NEP-specific list is not a guarantee that an NEP inspection will be conducted, nor is exclusion from the list a guarantee that one will not.
Area OSHA offices will inspect nursing and residential care facilities on the NEP-specific inspection list in a random order, and there is no requirement that they inspect every facility on the list in any year. In , for example, an inspector conducting a non-programmed inspection of a facility in response to an employee complaint will review the OSHA logs for calendar years , and Although the initial scope of the inspection is set by the NEP, once on site the inspector may expand the scope if other hazards come to light through observation or employee interviews e.
Therefore, nursing homes and residential care facilities should evaluate their likelihood of being targeted by calculating their DART rate for calendar years , and They should continue to monitor their rates for each calendar year through the end of the NEP.
The DART rate is calculated using the following formula:. EH is the total number of hours worked by all employees including management, temporary and leased employees during the calendar year. The , corresponds to the base number of hours worked by full-time equivalent employees. Nursing homes and residential care facilities should prepare for any potential inspection by studying the inspection process described in the NEP to ensure they have adequate policies and protocols in place for the covered hazards.
Management should clearly communicate those policies and protocols to staff members at each facility and instruct them how to handle an unannounced OSHA inspection. Management should also be aware of the most commonly cited standards in OSHA enforcement procedures in their industry.
The following table consists of the top 10 commonly cited standards for nursing and residential care facilities in the NEP-covered codes from October through September Standard
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