- Poorly written exposure control plans.
- Inadequate implementation of engineering controls and work practice controls.
- Failure to include hourly employees in the selection of safe devices.
- Failure to maintain the required sharps injury log and the confidential sharps injury log identification key.
- Failure to properly contain regulated waste.
- Lack of adequate and accessible hand washing facilities.
- Failure to use and/or failure to enforce the required use of personal protective equipment.
- Failure to use an Environmental Protection Agency-approved disinfectant.
- Failure to offer/provide hepatitis B immunization as requirements prescribe.
- Failure to provide training consistent with the requirements of the standard.
- Failure to show how the information contained in the sharps injury log is used as a tool to improve the quality of the bloodborne pathogen program.
This infectious bacterial disease is another area that seems to cause confusion. Most LTC facilities (or at least the ones I work with) do not provide care to residents with active tuberculosis (TB). Be that as it may, it does not relinquish the obligation to have a written plan in place. If your facility does not provide care to residents with TB, that fact should be one of the opening statements in your written plan.
The good news is that if your facility has not had a suspected or confirmed TB case in the past six months, then the SHCO will move on to another area without pushing this issue. If you have had a suspected or confirmed TB case in the past six months, then the emphasis will be placed on your isolation capabilities or your abatement capabilities. Additionally, your response to the well-being of the employees who may have been exposed to the suspected or confirmed resident with TB will be screened as well. Your plan should spell out the specifics as required by your local health department and state and federal agencies.
Workplace violence is reaching epidemic proportions in healthcare facilities, including those in long-term care. No regulatory standards address this issue. That said, OSHA has issued numerous citations under Section (5)(a)(i) of the General Duty Clause, stating that LTC facilities (actually, any and all healthcare facilities and agencies) know the risk exists and, therefore, have the obligation to take steps to minimize it.
OSHA Guideline 3148 titled “Guidelines for Preventing Workplace Violence for Healthcare and Social Service Workers” details what a complete workplace violence prevention program should look like. Although this is a guideline and not a codified standard, it provides excellent direction in how to structure a workplace violence program, including the written plan, training requirements and recordkeeping.
Hazard communications (HazCom) has recently gone through some major changes, with new requirements for all employers. By the time you read this, your facility should have made several critical changes to your HazCom program, consistent with the revised standard.