Improving the safety culture in 2014

I had the privilege of visiting several long-term care (LTC) facilities last year, and I saw an array of safety management programs. They ran the gamut between nonexistent and outstanding. In those organizations with less-than-stellar programs, I saw some commonalities:

  • They didn’t want to hear what I was telling them, so they considered it nonsense.
  • Their mind-set was that “not having it in the budget” was a defense for noncompliance.
  • They figured the chances of visit by the Occupational Safety and Health Administration (OSHA) were slim to none, so they weren’t worried about it.

As they say in baseball, three up and three down. I’m not faulting these facilities. This is a tough industry, and every administrator whom I visit reminds me how challenging it is to provide quality care, recruit and retain good employees, and make budget. I understand that, but I’m not the one you have to worry about.  

Fortunately, it’s not too late to change your culture and make workplace safety a way of life in your facility or community. It starts with knowing where the greatest hazards exist, and where to begin to remedy them.

When I perform a safety audit at a client site, I typically start by looking at the areas that an OSHA safety and health compliance officer (SHCO) would look at on a compliance visit. If you look at these areas and take the necessary steps to be compliant with the regulatory standards, you’ll start to see a dynamic improvement in your safety management program.

Let’s explore the areas where the majority of your losses occur and where the SHCO will put the bulk of his or her time and attention.


In this blog, I use the term ergonomics as it relates to resident handling. You know about the back and shoulder injuries that result from improperly lifting and transferring residents. You’ve heard enough on that topic By the same token, every facility or community must have a written safe resident handling plan that addresses these high-risk activities and prescribes methods to minimize the risk to workers.


Every area of your building presents potential slip, trip and fall hazards. Your challenge is twofold: (1) to create a culture where every employee knows that he or she is responsible for eliminating the hazards, and (2) to have an organized program in place to perform periodic safety assessments, identify hazards and implement corrective actions.

Most of the time, when we think of slip, trip and fall hazards, wet floors come to mind, and rightfully so. Slippery and wet floors do create a serious hazard that must be managed. Beyond slippery and wet floors, however, we also must think about broken floor tiles, carpet seams that are coming unraveled, unguarded floor openings, elevated work surfaces and other such hazards. Fix these, and you’ll be well ahead of the game.


Bloodborne pathogens consistently are the killer citations. What started out as a simple program to protect workers from exposure to blood and other potentially infectious materials has now become a monster. It has become detailed and complicated. Do not take this area lightly. Get serious about compliance. The key areas for which citations are issued recognize:

  • 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.

The United States now participates in the Globally Harmonized System of Classification and Labeling of Chemicals. As of Dec. 1, 2013, you should be well into the transition from material safety data sheets (MSDS) to the new safety data sheets (SDS), which are all in a standardized format. Additionally, as of that same date, all of your employees should have received new training that includes:

  • recognizing and understanding the new pictograms in the new labeling system;
  • understanding of hazard statements and the use of the terms danger, warning and caution, and understanding how the elements of the new labels work together;
  • reading and understanding the SDS; and
  • how the SDS and the product label are related.

Many more changes in the HazCom standard are coming. I will keep you apprised as they develop and implementation deadlines approach.


I’ve just touched the tip of the iceberg here. It’s incumbent on the facility or the community to understand compliance requirements and to use them to develop a culture of safety.

This fact is not going to change; it’s not going to go away. The DART (days away, restricted or transferred) rate in healthcare remains unacceptably high, and until the industry improves its safety performance and safety management outcomes, facilities can expect to have the regulatory agencies breathing down their necks as the agencies continue to pick apart safety programs and issue monetary penalties that force facilities to comply.

Stay safe, and stay in touch.

Topics: Executive Leadership , Facility management , Operations , Regulatory Compliance , Risk Management