By James L. Curtis and Craig B. Simonsen
OSHA has released an “Inspection Guidance for Inpatient Healthcare Settings,” that will focus its inspectors attention to musculoskeletal disorders, workplace violence, bloodborne pathogens, tuberculosis, and slips, trips, and falls.
The Guidance focuses on hazards that were included in OSHA’s recently-concluded National Emphasis Program on Nursing and Residential Care Facilities, CPL 03-00-016. OSHA’s Administrator, Dr. David Michaels, commented on the Guidance that “workers who take care of us when we are sick or hurt should not be at such high risk for injuries — that simply is not right.” “The most recent statistics tell us that almost half of all reported injuries in the healthcare industry were attributed to overexertion and related tasks. Nurses and nursing assistants each accounted for a substantial share of this total.”
As noted above, the Guidance main focus areas include musculoskeletal disorders (MSDs), workplace violence (WPV), bloodborne pathogens (BBP) and tuberculosis (TB), and slips, trips, and falls (STFs).
Musculoskeletal Disorders and Overexertion
According to OSHA, the Bureau of Labor Statistics data for 2013 show that 44 percent of reported injuries within the healthcare industry were attributed to overexertion-related incidents. The Guidance remarks that the rate “equates to almost one and a half times the total MSD rate (33 percent) for all reported injuries for all industries.” Nurses and nursing assistants accounted for a substantial share of the total. Accordingly, MSDs will be a substantial focus of OSHA’s inspections.
Workplace Violence is defined as violent acts (including physical assaults and threats of assaults) directed toward persons at work or on duty. OSHA notes that WPV is a recognized hazard in hospitals, and in nursing and residential care facilities. According to OSHA, in the healthcare and social assistance sector, 13 percent of the injuries and illnesses were the result of violence. “Fifteen percent of the days-away-from-work cases for nursing assistants were the result of violence.” Accordingly, WPV will be evaluated in every inpatient healthcare OSHA inspection.
Bloodborne Pathogens and Tuberculosis
OSHA’s enforcement data indicated that 29 CFR 1910.1030, the Bloodborne Pathogens Standard, is one of the most frequently cited standards in nursing and residential care facilities. Additionally, employees working in nursing and residential care facilities have been identified by the Centers for Disease Control and Prevention as having the highest risk for exposure to TB due to the case rate of disease among persons 65 years of age. Accordingly, BBP and TB will continue to receive substantial focus under the National Emphasis Program in every inpatient healthcare OSHA inspection.
Slips, Trips, and Falls
While not typically the source of serious injuries, OSHA indicates that injuries from STFs were a driving cause of occupational injury and illness cases reported in nursing and residential care facilities. “Taken together, overexertion together with slips, trips, and falls accounted for 68.6% of all reported cases with days away from work.”
In addition to its focus on musculoskeletal disorders, bloodborne pathogens and tuberculosis, workplace violence, and slips, trips, and falls, the Guidance indicates that inspectors should also be watchful for:
- 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 Guidance is effective immediately. The Guidance notes that “because these hazards are nationwide, State Plans are expected to follow the guidance.”
Healthcare employers should take heed of this Guidance. Special attention should be taken to update your policies, procedures, and training systems to include these topics. Make note, because OSHA inspectors certainly will.