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OSHA's Emphasis Is on Nursing Homes

December 1, 2002
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When OSHA's National Emphasis Program inspectors come to call By Sandra Hoben, Managing Editor
OSHA's Emphasis Is on Nursing Homes What to do if (or when) the federal safety inspectors pay a visit under the new National Emphasis Program

BY SANDRA HOBAN, MANAGING EDITOR Still recognizing the nursing home industry as one of the most hazardous in the United States, the Occupational Safety and Health Administration (OSHA) has developed a National Emphasis Program (NEP) for the industry. Is your organization a candidate for inspection? You could be if your facility is an SIC Code 8051'Skilled Nursing Facilities, 8052'Intermediate Care Facilities, or 8059'Nursing and Personal Care Facilities, Not Elsewhere Classified; if there is a safety-related complaint lodged against the facility; or if there are 14 or more injuries or illnesses per year that result in lost workdays or restricted activity for every 100 full-time employees (LWDII rate). On a secondary level, the NEP gives facilities with 8 or more injuries and illnesses a reasonable chance of inspection. The likelihood of inspections, for nursing homes, is relatively strong: According to Bureau of Labor statistics calculated for calendar year 2000, while the national LWDII rate for private industry was 3.0, the LWDII for nursing and personal care facilities was 7.9. Although many administrators today still fear the knock on the door, OSHA says that its intention-first and foremost-is to provide a safe working environment for employees, which, in turn, benefits the facility and its residents. Indeed, included in its NEP is an outreach effort designed to help facilities meet current safety standards before any inspectors come knocking.

If (or when) they do, though, what should you expect? All About OSHA (OSHA 2056, revised 2000) is available online at www.osha.gov/Publications/osha2056.pdf and offers the following guidance. The OSHA Inspection Before any inspection begins, you should insist on seeing the compliance officer's photo credentials, which are issued by the U.S. Department of Labor. Credentials also bear a serial number that can be verified by calling the nearest OSHA office. Prior to the facility walkaround, the OSHA compliance officer will explain why the facility is being inspected. The compliance officer will also explain the purpose of the visit, the inspection procedures and scope, the employee representation and/or interviews anticipated, and what the closing conference will entail.

As guided by the NEP, OSHA inspectors have narrowed the scope of their walkarounds to focus on four major areas of concern in the nursing home environment: (1) ergonomics; (2) exposure to blood and other potentially infectious materials; (3) exposure to tuberculosis (TB); and (4) slips, trips, and falls. Be advised that the NEP allows compliance officers to expand the range of scrutiny if observations, records, interviews, or a pattern of violations indicate that a facility might have other critical issues that need to be corrected.

The following is a general description of the infractions that OSHA inspectors will be looking for in the four focus areas.

Ergonomics. Prior to the walkaround, the compliance officer will review a facility's injury incident and severity rate records to determine if there was any increase or decrease over a three-year period, which indicates whether the facility's ergonomics program management and implementation exist and have been effective. Issues of importance include, but are not limited to, whether:
    'the facility has a system for hazard identification and analysis,
    'employees contribute to the development of lift and transfer procedures,
    'there is a system in place to monitor compliance, and
    'policies and procedures have had a positive or negative effect on the prevalence of injuries.

It is very important to present documentation that only those employees who have been trained to use the on-premises lifts and other transfer devices (gait belts, slings, slip sheets, etc.) are performing lifts and that, if an injury does occur, they recognize the importance of reporting the incident immediately.

Exposure to blood and other potentially infectious materials. When evaluating this hazard, a compliance officer will look at the facility's Exposure Control Plan (ECP) to determine how exposure to blood and other infectious ma-terials is to be handled. After reviewing the ECP, the compliance officer will seek to verify whether work practice controls and physical safeguards indicated by the facility's ECP are in place and being used correctly on the nursing floors.

For example, in situations that involve sharps such as insulin injections, the OSHA inspector will determine whether the employer has selected and is, in fact, using needleless systems and/or sharps products engineered to prevent a needle-stick injury. In addition, if the facility does not stock safer devices-such as retractable needles, safety needles on prefilled syringes, or single-use blood tube holders-the compliance officer will ask why. In addition to sharps protection, the facility must show that it has proper work procedures in place- especially relating to proper waste disposal-and that its employees consistently use protective gear.