OSHA Compliance: How-Tos for the Medical Provider

How-Tos for the Medical Provider

Dr. Josh HyattExecutive Directive, Integrated Risk ManagementKeck Medicine of USC

OSHA COMPLIANCE:

LEARNING OBJECTIVES:• Define the specific components of a safety and health program in the

medical setting and ideas for implementation.

• Identify the key areas that are part of an OSHA inspection and how to prepare for an inspection.

• Recognize the importance of developing a comprehensive program for personal protective equipment for medical providers, and the regulatory risks for systemic failures.

• Explain the OSHA survey process and how to respond to findings.

OSHA in Health CareProgram DevelopmentProgram Implementation The OSHA Inspection

• Occupational Safety and Health Act of 1970- Occupational Safety and Health Administration (OSHA)

• OSHA is part of the United States Department of Labor.

• Covers most private sector employers and their workers, in addition to some public sector employers

• Does not cover • Certain types of employers or workers,• Self-employed workers • Immediate family members working on farms• Workers covered by other federal safety programs

OSHA’S MISSION

OSHA FEDERAL REGULATIONS VS.

INDIVIDUAL STATE PLANS

• States may administer their own job safety and health programs, or State Plans

• Most State Plans have adopted Federal OSHA regulations and standards verbatim.

• These states have standards that are more stringent than Federal OSHA standards or address hazards not covered by Federal OSHA.

California Occupational Safety and Health Act of 1973

California Code of Regulations, Title 8, Section 3203

Hospital Patient and Health Care Worker Injury Protection Act

CAL/OSHA: MORE STRINGENT THAN OSHA STANDARDS

WORKERS’ RIGHTS UNDER THE OSH ACT

• Ask OSHA to inspect their workplace;

• Use their rights under the law without retaliation and discrimination;

• Receive information and training about hazards, methods to prevent harm, and the OSHA standards that apply to their workplace; the training must be in a language that workers can understand;

• Get copies of test results done to find hazards in the workplace;

• Review records of work-related injuries and illnesses;

• Get copies of their medical records.

DISCUSSION QUESTION

According to the Bureau of Labor Statistics, the likelihood of injury or illness resulting in days away from work is highest in which of the following occupations?

a. Constructionb. Manufacturingc. Leisure and Hospitalityd. Hospitals

Figure 1. Injury and illness rates by industry, 1989-2011.3

INJURY AND ILLNESS RATES BY INDUSTRY: 1989-2011

HOSPITAL WORKER INJURIES

Figure 2. Injuries and illnesses resulting in days away from work, by healthcare sector, 1992–2011.5

INJURIES AND ILLNESSES BY HEALTHCARE SECTOR

EMPLOYEE ASSISTANCE AND WELLNESS PROGRAMS

Fundamental Goal: to provide opportunities for individuals to improve their health and wellness.

Employee Assistance Programs: serve to provide psychological counseling or referral services

Employer-Sponsored Wellness Programs: serve to encourage workers to adopt healthy lifestyles (e.g., through smoking cessation programs and weight loss programs).

WORKERS’ COMPENSATION

Workers' compensation is the nation's oldest social insurance program.

Employees are entitled to receive prompt, effective medical treatment for on-the-job injuries or illnesses no matter who is at fault and, in return, are prevented from suing employers over those injuries.

Workers' compensation benefits are not administered by a government agency.

The vast majority of workers' compensation claims are resolved between the insurance company and the injured worker.

MEDICAL CASE MANAGEMENT

Medical Case Managers are involved in almost all of today’s Workers’ Compensation claims

Employers support the trend because they see how case managers reduce medical costs by preventing unnecessary utilization of expensive medical tests and services

1) Medical guidance

2) Active employee involvement in his/her medical care

3) Improved quality of care

KEY OSHA STANDARDS FOR HEALTHCARE SETTINGS7

Blood borne pathogens: Engineering controls Sharps with engineered sharps injury protections, Proper disposal sites

Personal protective equipment: Infectious materialsPPEs: Protective gloves, gowns, aprons and face shields NIOSH-rated N95 respirators Training

Workplace violence: Administrative controls

Signage: Danger signs Caution signs

Patient handling:Safety and Health Management Systems

HOSPITAL PATIENT AND HEALTH CARE WORKER INJURY PROTECTION ACT Requirements of the Act8

Health Care Worker Injury Prevention Plan

Patient Handling Policy

Choosing a Lifting Method or Device

Designated Lift Coordinator

Hospital Back Safety Training

Health Care Worker Protections

ACCIDENT/INCIDENT INVESTIGATION [EXAMPLE]9

1. Notification his/her supervisor immediately.2. Medical care first!3. Supervisor should investigate 4. Supervisor’s Injury and Illness Incident Report 5. Employee will need to complete 2 forms and return them to

Risk Management: a. Employee’s Report of Work Injury/Illness b. Employee’s Claim for Workers’ Compensation (DWC 1)

6. EH&S will evaluate Supervisor’s report and determine if investigation is

needed.7. EH&S investigation

INTEGRATING PATIENT AND WORKPLACE SAFETY PROGRAMS

WHAT IS THE SOLUTION?

Safety and Health Management System

Hospitals can successfully manage both patient and employee safety risks using an integrated approach.10

[AKA] Injury and Illness Prevention Program

SAFETY AND HEALTH MANAGEMENT SYSTEM [AKA]

Injury and Illness Prevention Program

An Injury and Illness Prevention Program (IIPP) six core elements:

• Management leadership• Employee participation• Hazard identification and assessment• Hazard prevention and control• Education and training• Program evaluation and improvement

OSHA has developed a Safety and Health Management Systems eTool which is an electronic Compliance Assistance Tool that provides guidance information for developing a comprehensive safety and health program.11

OSHA AND THE JOINT COMMISSION/JOINT COMMISSION RESOURCES ALLIANCE

OSHA and The Joint Commission/Joint Commission Resources continue to recognize the value of maintaining a collaborative relationship to foster safer and more healthful American workplaces.12

ENVIRONMENT OF CARE AND SAFETY ROUNDS

Environment of Care (EC)

Some of these links include, but are not limited to, the following EC issues:

• Routine housekeeping• Sterilization of medical devices• Containment of contaminated laundry• Installation and maintenance of filters to trap airborne contaminants in the air• Selection and care of toys in the pediatric unit• Treatment of water used for dialysis• Use of standard precautions by plumbers and electricians• Use of tacky mats or other dust-control devices at the exits of construction zones• Placement of hand-washing sinks, hand rub dispensers, and hygiene products• Cleaning carpets

HEALTHCARE-ASSOCIATED INFECTION

Healthcare-associated infections (HAI)

1 in 25 hospital patients has at least one healthcare-associated infection.

Estimated 722,000 HAIs in U.S. acute care hospitals in 2011

75,000 hospital patients with HAIs died during their hospitalizations

Device-associated infections accounted for 25.6% of all

Non-ventilator pneumonia and surgical-site infection were the most common infection types

C. difficile was the most common pathogen

TARGETED SOLUTIONS TOOL®15

The Targeted Solutions Tool (TST)® is one such application and is available on the Joint Commission's new Transitions of Care Portal16 for the following projects:

• New! Preventing Falls• Hand Hygiene• Hand-off Communications• Safe Surgery

PREVENTING FALLS TARGETED SOLUTIONS TOOL®17

HAND HYGIENE TST®18

Organizations that have used the TST increased their hand hygiene compliance.

The Hand-off Communications 19

80 percent of serious medical errors involve miscommunication between caregivers when patients are transferred or handed-off.

SAFE PATIENT HANDLING: DEBUNKING THE MYTHS20

BLOOD BORNE PATHOGEN STANDARD21

Engineering controls include: • sharps disposal containers • self-sheathing needles • sharps with engineered sharps injury protections and

needleless systems

Training

Sharps injury log:• the sharps type and brand of device involved • the department or work area of the exposure incident • explanation of how incident occurred• must protect the confidentiality of the injured worker

TUBERCULOSIS22

Hierarchy of Infection Control

Administrative controls

Environmental controls

Respiratory protection controls

RELEVANCE TO BIOLOGIC TERRORISM PREPAREDNESS

Multidrug-resistant M. tuberculosis is classified as a category C agent of biologic terrorism.

ADMINISTRATIVE CONTROLS

• Responsibility for TB infection control (IC)• Health department • Timely lab processing and reporting• Work practices for managing TB patients

• Test and evaluate at risk HCWs • Train • Cleaning of equipment• Signage

ENVIRONMENTAL CONTROLS

Technologies for removing or inactivating M. tuberculosis consist of:

• Local exhaust ventilation• General ventilation• Air-cleaning methods, e.g., high-efficiency

particulate air (HEPA) filtration, ultraviolet germicidal irradiation (UVGI)

RESPIRATORY PROTECTION CONTROLS

• “airborne infection isolation”• Initiating and discontinuing precautions• Respirator fit testing • Decision on use of respiratory protection (RP) in labs

should be made on case-by-case basis

• Minimum respiratory protection is a filtering facepiece respirator (non-powered, air-purifying, half-facepiece, such as N95 disposable)• In high-risk situations (cough- or aerosol-producing

activities), additional protection may be needed

CONSIDERATIONS FOR SELECTING RESPIRATORS

Respirators must be CDC/NIOSH approved under 42 CFR, Part 84

Types of Respiratory Protection

• Non-powered air-purifying respirators• Powered air-purifying respirators (PAPRs)• Supplied-air respirators

SLIPS, TRIPS, AND FALLS23

SLIPS, TRIPS AND FALLS

The National Institute for Occupational Safety and Health (NIOSH)

THE OSHA INSPECTION

TIPS: Plan for an inspection in advance

FORMAT:Opening Conference Walk-around InspectionClosing Conference

OPENING CONFERENCE

Overview and discuss the purpose of the inspection.

The records to be reviewed

OSHA 200 log

Ergonomic hazards

Areas from which employee or union complaints have originated

Environmental sampling (noise levels, presence of air contaminants, etc.)

Question employees about any job related symptoms they may have, what work areas they feel are problem areas, and about the training they have received.

WALK-AROUND INSPECTION

CLOSING CONFERENCE

Unsafe conditions discussed

Issue formal citations within six months of the inspection

The inspector does not propose penalties

The U.S. Department of Labor area director will notify you in writing by certified mail of any citations/penalties received

HOW TO PREPARE FOR AN OSHA HEALTH FACILITY INSPECTION

As of June, 2015, the focus hazards are:

• Musculoskeletal disorders (MSDs) relating to patient or resident handling

• Workplace violence (WPV) • Blood borne pathogens (BBP)• Tuberculosis (TB)• Slips, trips and falls (STFs)

Other hazards that may be evaluated in these settings include:

• 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

THANK YOU

REFERENCES

1. Facts About Hospital Worker Safety. Occupational Safety and Health Administration (OSHA). https://www.osha.gov/dsg/hospitals/documents/1.2_Factbook_508.pdf/ Published September 2013. Accessed 30 Aug 2015.

2. Aon Risk Solutions. http://www.aon.com/attachments/risk-services/2012-HC-WorkersComp_Barometer_Report_Abridged.pdf Accessed 30 Aug 2015. 2012 Health Care Workers Compensation Barometer.

3. Bureau of Labor Statistics. Annual Survey Summary Numbers and Rates. https://www.osha.gov/oshstats/index.html/ Accessed 30 Aug 2015. In this figure, “hospitals” represents SIC 806 (1989–2002) and NAICS 622 (2003–2011), which cover all types of hospitals. “Construction” represents SIC supersector 200000 (1989–2002) and NAICS supersector GP1CON (2003–2011). “Manufacturing” represents SIC supersector 300000 (1989–2002) and NAICS supersector GP1MFG (2003–2011). Data are limited to private industry.

4. Bureau of Labor Statistics. Case and Demographic Numbers. http://www.bls.gov/iif/oshcdnew.htm/ Accessed 30 Aug 2015. These data represent NAICS 622, which covers all types of hospitals. Data are limited to private industry.

REFERENCES

5. Bureau of Labor Statistics. Case and Demographic Incidence Rates. http://www.bls.gov/iif/oshcdnew.htm Accessed 30 Aug 2015. In this figure, “hospitals” represents SIC 806 (1992–2002) and NAICS 622 (2003–2011), which cover all types of hospitals. “Nursing and residential care facilities” represents SIC 805 and 836 (1992–2002) and NAICS 623 (2003–2011), and “ambulatory care” represents SIC 801 and 802 (1992–2002) and NAICS 621(2003–2011). Data are limited to private industry.

6. Schaffer R. Benefits of medical case management guide injured workers to faster recovery. Workers’ Comp Resource Center. http://blog.reduceyourworkerscomp.com/ 2011/03/benefits-of-medical-case-management-guide-injured-workers-to-faster- recovery/ Published 15 Mar 2011. Accessed 30 Aug 2015.

7. Occupational Safety & Health Administration. Compliance Assistance Quick Start: Health Care Industry. https://www.osha.gov/dcsp/compliance_assistance/quickstarts/ health_care/index_hc.html Accessed 1 Sept 2015.

8. CalOSHA. AB 1136: Hospital Patient and Health Care Worker Injury Protection Act: Safe Patient Handling. https://www.dir.ca.gov/dosh/Safe%20Patient%20Handling% 20FAQ.pdf Published 25 Jan 2012. Accessed 1 Sept 2015.

REFERENCES

9. California State University: East Bay. Workers’ Compensation Guide for Managers and Supervisors. https://www20.csueastbay.edu/ af/departments/risk-management/workers-comp/files/docs/10e%20WC%20 Supervisorsguide_061807%209-26-11.pdf Accessed 31 Aug 2015.

10. OSHA. Integrating Patient and Workplace Safety Programs. OSHA 3730 - 09/2013. https://www.osha.gov/dsg/hospitals/documents/2.1_SHMS_integration_508.pd Published Sept. 2013. Accessed 31 Aug 2015.

11. OSHA. Safety & Health Management Systems eTool. https://www.osha.gov/SLTC/etools/safetyhealth/index.html Accessed 1 Sept 2015.

12. OSHA. OSHA National Alliances /The Joint Commission (TJC)/Joint Commission Resources (JCR). https://www.osha.gov/dcsp/alliances/jcaho/jcaho.html#top Accessed 1 Sept 2015.

13. Joint Commission Resources. Infection Prevention and Control Issues in the Environment of Care, 2nd ed. 2009.

14. Magill SS, Edwards JR, Bamberg W, et al. Multistate point-prevalence survey of health care–associated infections. N Eng J Med 27 Mar 2014; 370:1198-1208.

REFERENCES

15. Joint Commission Center for Transforming Healthcare. Targeted Solutions Tool.® http://www.centerfortransforminghealthcare.org/tst.aspx Accessed 1 Sept 2015.

16. The Joint Commission. Transitions of Care (ToC) Portal. http://www.jointcommission.org/toc.aspx Accessed 1 Sept 2015.

17. The Joint Commission. Hospital Accreditation: Take a Stand Against Patient Falls. http://www.jointcommission.org/accreditation/hospitals.aspx Accessed 1 Sept 2015.

18. Joint Commission Center for Transforming Healthcare. Targeted Solutions Tool for Hand Hygiene. http://www.centerfortransforminghealthcare.org/tst_hh.aspx Accessed 1 Sept 2015.

19. Joint Commission Center for Transforming Healthcare. Targeted Solutions Tool for Hand-off Communications. http://www.centerfortransforminghealthcare.org/tst_hoc.aspx Accessed 1 Sept 2015.

REFERENCES

20. OSHA. Safe patient handling: Busting the myths. https://www.osha.gov/dsg/hospitals/documents/3.1_Mythbusters_508.pdf Accessed 2 Sept 2016.

21. OSHA. Quick Reference Guide to the Bloodborne Pathogens Standard. https://www.osha.gov/SLTC/bloodbornepathogens/bloodborne_quickref.html Accessed 2 Sept 2015.

22. Division of Tuberculosis Elimination. Guidelines for Preventing the Transmission of M. tuberculosis in Health-Care Settings, 2005. Updated Dec 2006. Accessed 2 Sept 2015.

23. OSHA. Slips, Trips & Falls: Identification and Prevention.