Death and disability due to unsafe or unhealthy workplaces remain ongoing issues in the United States. In 2009, there were 3.3 million job-related nonfatal injuries and illnesses in the private sector alone. OSHA standards are in place in order to minimize the risks associated with various workplaces, and there are standards in place that uniquely affect healthcare facilities. Bloodborne pathogen compliance, waste management, tuberculosis control, and the ergonomics regulations are all examples of OSHA's impact. This course will outline specific OSHA guidelines for a safe healthcare workplace.
This course is designed for dental healthcare staff in all specialties.
NetCE is designated as an Approved PACE Program Provider by the Academy of General Dentistry. The formal continuing education programs of this program provider are accepted by AGD for Fellowship, Mastership, and membership maintenance credit. Approval does not imply acceptance by a state or provincial board of dentistry or AGD endorsement. The current term of approval extends from 10/1/2015 to 9/30/2021. Provider ID 217994. NetCE is an ADA CERP Recognized Provider. ADA CERP is a service of the American Dental Association to assist dental professionals in identifying quality providers of continuing dental education. ADA CERP does not approve or endorse individual courses or instructors, nor does it imply acceptance of credit hours by boards of dentistry. Concerns or complaints about a CE provider may be directed to the provider or to ADA CERP at www.ada.org/cerp. NetCE is a Registered Provider with the Dental Board of California. Provider Number RP3841. Completion of this course does not constitute authorization for the attendee to perform any services that he or she is not legally authorized to perform based on his or her license or permit type. NetCE is approved as a provider of continuing education by the Florida Board of Dentistry, Provider #50-2405.
NetCE designates this activity for 5 continuing education credits. AGD Subject Code 553. This course meets the Dental Board of California's requirements for 5 unit(s) of continuing education. Dental Board of California course #05-3841-16152.
The purpose of this course is to provide information that will allow facilities to more easily comply with the broad spectrum of rules covered by the OSHA regulations.
Upon completion of this course, you should be able to:
- Explain the history of Occupational Safety and Health Administration (OSHA).
- Describe the purpose of the Bloodborne Pathogens Standard as it applies to the healthcare setting.
- Review the role of OSHA standards in preventing tuberculosis (TB) transmission.
- Explain the impact of OSHA regulations on employee health, including risk management and safety issues in a healthcare setting.
- Discuss hazardous materials and waste management in a healthcare facility.
- Explain the necessity for radiation safety in healthcare facilities.
- Describe the process of handling blood and chemical spills.
- Outline the impact of fire safety on patients and employees in the healthcare facility.
- Discuss indoor air quality, ergonomics, and latex allergy concerns in healthcare facilities.
- Discuss legal issues and employee safety as applied to the healthcare facility.
- Describe what might occur during an OSHA consultation and inspection.
Carol Shenold, RN, ICP, graduated from St. Paul’s Nursing School, Dallas, Texas, achieving her diploma in nursing. Over the past thirty years she has worked in hospital nursing in various states in the areas of obstetrics, orthopedics, intensive care, surgery and general medicine.
Mrs. Shenold served as the Continuum of Care Manager for Vencor Oklahoma City, coordinating quality review, utilization review, Case Management, Infection Control, and Quality Management. During that time, the hospital achieved Accreditation with Commendation with the Joint Commission, with a score of 100.
Mrs. Shenold was previously the Infection Control Nurse for Deaconess Hospital, a 300-bed acute care facility in Oklahoma City. She is an active member of the Association for Professionals in Infection Control and Epidemiology (APIC). She worked for the Oklahoma Foundation for Medical Quality for six years.
Contributing faculty, Carol Shenold, RN, ICP, has disclosed no relevant financial relationship with any product manufacturer or service provider mentioned.
William E. Frey, DDS, MS, FICD
The division planner has disclosed no relevant financial relationship with any product manufacturer or service provider mentioned.
The purpose of NetCE is to provide challenging curricula to assist healthcare professionals to raise their levels of expertise while fulfilling their continuing education requirements, thereby improving the quality of healthcare.
Our contributing faculty members have taken care to ensure that the information and recommendations are accurate and compatible with the standards generally accepted at the time of publication. The publisher disclaims any liability, loss or damage incurred as a consequence, directly or indirectly, of the use and application of any of the contents. Participants are cautioned about the potential risk of using limited knowledge when integrating new techniques into practice.
It is the policy of NetCE not to accept commercial support. Furthermore, commercial interests are prohibited from distributing or providing access to this activity to learners.
- HISTORY OF OSHA
- BLOODBORNE PATHOGENS
- TUBERCULOSIS CONTROL
- OSHA AND EMPLOYEE HEALTH
- SAFETY/RISK MANAGEMENT
- MATERIAL SAFETY DATA SHEETS/HAZARDOUS MATERIAL
- HAZARDOUS WASTE
- CHEMICAL AND BLOOD SPILLS
- FIRE SAFETY
- INDOOR ENVIRONMENTAL QUALITY
- LATEX ALLERGY AND GLOVE MANAGEMENT
- TRAINING AND EDUCATION
- LEGAL ISSUES
- SURVEYS, COMPLIANCE, AND DOCUMENTATION
- GLOSSARY OF ACRONYMS
- Works Cited
- Evidence-Based Practice Recommendations Citations
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#51231: OSHA and Healthcare Facilities
Death and disability due to unsafe or unhealthy workplaces remain ongoing issues in the United States. In 2012, there were 3 million job-related nonfatal injuries and illnesses in the private sector alone . The U.S. Bureau of Labor Statistics reported a total of 4,383 employee deaths in 2012. This figure may not include the deaths of workers due to occupationally acquired diseases . The continuous efforts of the Occupational Safety and Health Administration (OSHA) to promote employee safety are part of what makes it such an important regulatory entity.
At one time OSHA compliance was considered an issue important and applicable to industry only. Healthcare facilities did not normally use heavy equipment or have issues regarding noise levels and high-level chemical spills and, therefore, felt safe. Smaller facilities may have felt protected from inspection because of the number of surveys required.
However, bloodborne pathogen compliance, waste management, tuberculosis control, and ergonomics regulations have increased awareness among healthcare facilities about the impact of OSHA. Entities such as OSHA, Medicare, and the Joint Commission now cooperate and review OSHA regulatory issues when conducting surveys.
In 1970, Congress established OSHA as part of the Occupational Safety and Health Act (i.e., the OSH Act). The Act was signed by President Nixon on December 29, 1970, and became effective on April 28, 1971. OSHA has defined its mission as assuring that working men and women are provided with safe, healthful working conditions. The agency fulfills its mission by applying and enforcing standards developed under the Act. It also provides information, education, training, and assistance to employers so they can maintain safe and healthful workplaces .
The OSH Act established three permanent federal agencies: OSHA, within the Department of Labor; the Occupational Safety and Health Review Commission (OSHRC); and the National Institute for Occupational Safety and Health (NIOSH), within the Department of Health and Human Services. The OSH Act covers only the private sector [4,5].
The duties of OSHA include writing standards, inspecting workplaces for compliance with standards, and prosecuting violations. The OSHRC is responsible for resolving disputes between OSHA and violators of the OSH Act (usually employers). NIOSH conducts research on occupational hazards and makes recommendations for standards (e.g., N95 respirators to be used when caring for tuberculosis patients) [4,5,6].
Workplace inspection is the responsibility of the Secretary of Labor and may result either from an employee complaint or from a problem identified during a previous inspection. An OSHA inspector may either order compliance with a regulation or issue a penalty, such as a fine. There is only one criminal penalty available under the Act, and this is applied if a worker dies from an employer's willful violation [4,7].
As mentioned, the healthcare industry had not previously considered OSHA regulations as affecting it. After all, hospitals did not use large machinery, assembly lines, or equipment that would put employees at risk for major injuries. However, research has identified a wide range of biological, physical, psychosocial, and chemical hazards in the healthcare work environment [8,71].
With the introduction of the human immunodeficiency virus (HIV) and a new focus on bloodborne pathogens, hospitals and other healthcare facilities were faced with the implementation of OSHA standards that would potentially cost both time and money. Many healthcare industries and organizations did not believe that the federal government should be quite so prescriptive and felt that some of the regulatory requirements for general industry might not be appropriate in a healthcare setting. To ensure that regulatory requirements are appropriate for healthcare settings, organizations such as the Association for Practitioners in Infection Control and Epidemiology (APIC) and the Centers for Disease Control and Prevention (CDC) work together with OSHA to develop standards.
In 1989, OSHA published a proposed rule regarding occupational exposure to bloodborne pathogens in hospitals and other healthcare settings. The proposed rule, based on the concept of Universal Precautions, raised concerns in the infection control community. The imbalance toward precautions that protected personnel and away from precautions that protected patients, the lack of proven efficacy of Universal Precautions, and the costs for implementing the proposed regulations were all concerns. After a series of public hearings by OSHA and a review of written comments, the proposed rule was modified and finalized in 1991. Although the final rule was expected to improve occupational safety during the care of patients infected with bloodborne pathogens, the impact on the cost of patient care and on nosocomial infection control remained undefined [9,10].
The OSHA Bloodborne Pathogens Standard brought OSHA visibility to healthcare settings and required education about the implementation of and compliance with OSHA regulations. OSHA has become one of the most important organizations in the fight against bloodborne pathogens as a result of its ability to set standards for the use of barrier precautions and enforce the use of such precautions for employee and patient safety.
OSHA continues to urge improved safety in all categories of the workplace. In October 2010, the Assistant Secretary of Labor for OSHA reported that the agency's priorities for the coming fiscal year were to return to basics, update workplace safety and health regulations, and impose fair and strong enforcement .
The purpose of the Bloodborne Pathogens Standard, which was published by OSHA in final form in 1991, is to limit occupational exposure to blood, bodily fluids, and other potentially infectious materials, because any exposure could result in bloodborne pathogen transmission. This standard applies to all reasonably anticipated occupational exposures to blood or other potentially infectious materials that may result from the performance of an employee's duties . "Good Samaritan" acts, such as resuscitating a co-worker, might not be considered occupational exposure [13,14,15].
The standard requires employers to implement an exposure control plan that mandates Universal Precautions (i.e., treating all body fluids as if they are potentially infectious). The standard also stresses hand hygiene, recommends the use of Personal Protective Equipment (PPE), sets forth processes to minimize needle sticks and blood splashing, ensures appropriate packaging of specimens, and regulates waste by employing biohazardous labeling before shipping .
Employers must require the use of, and provide at no cost, barrier items or PPE for employee protection. This includes gowns, masks, mouthpieces, goggles, resuscitation bags, and the proper gloves for the job being performed. Also included in the standard are methods for disposing of contaminated sharps and other regulated waste in OSHA-compliant containers .
Another aspect of the Bloodborne Pathogens Standard is the requirement that Hepatitis B vaccination be made available at no cost and within 10 working days of assignment to all employees who have occupational exposure to blood. Postexposure evaluation and follow-up must be made available to all employees who have had an exposure incident. Included in the evaluation and follow-up are laboratory testing, counseling, evaluation, and prophylaxis, if deemed necessary and if the employee consents .
Some of the most common bloodborne pathogens include hepatitis C, HIV, and hepatitis B .
Hepatitis C virus (HCV) may be transmitted from patients to healthcare workers through accidental needle sticks or cuts, or through blood splashed onto the conjunctiva. Following percutaneous injury, the risk of infection is approximately 1.8% [16,17,72]. One thousand healthcare workers are occupationally infected annually, and HCV is the leading cause of liver transplantation in the United States [18,19].
The long-term lethal potential of HCV is projected to be higher than that resulting from infection with Hepatitis B. This is due to the high rate of chronic infection and the lack of an effective vaccine. Often, patients with HIV also have HCV, and both pathogens can be transmitted in one exposure. HCV is usually treated with pegylated interferon/ribavirin; however, the treatment is expensive and has many adverse effects, and more than 50% of infected patients do not respond to treatment [18,20]. The CDC has concluded that the evidence is insufficient to recommend postexposure prophylaxis for workers potentially exposed to HCV .
The risk of infection with HIV following percutaneous injury is approximately 0.3%; however, risk is significantly increased if the patient has advanced acquired immunodeficiency syndrome (AIDS), the needle is visibly contaminated with blood, or if the needle has been used in an artery or vein before the exposure occurs [21,72].
Between 1% and 2% of hospital and surgical patients have HIV. Postexposure prophylaxis with combination drug regimens has been shown to decrease seroconversion risk, but this may be compromised by the presence of increased risk factors [18,21].
In 2005, the CDC published updated HIV management guidelines, which further refine the treatment of potential exposures to HIV in the workplace .
Hepatitis B virus (HBV) is highly infectious and transmissible by needlestick in 6% to 30% of exposures, depending on the antigen status of the source . Approximately 5% of HBV infections acquired by persons older than 5 years of age become chronic . Vaccination has dramatically reduced the threat to healthcare workers from this disease; however, not all healthcare workers who are at risk of exposure to blood have been vaccinated . According to the CDC, postvaccination testing to ensure an adequate antibody response is indicated for those individuals who: are immunocompromised; received the vaccination in the buttock; are infants born to HBV-positive mothers; are healthcare workers who either have had contact with blood or are at risk for continued exposure to blood or body fluids; or are sex partners of persons with chronic HBV .
Choose effective PPE (i.e., the right equipment for the job).
Find alternatives for sharps, such as staples for skin closure, rounded tip scissors, nonpenetrating towel clips, needleless intravenous (IV) systems.
Use safer sharps.
Pass and handle sharps safely.
Adopt safe habits (e.g., make certain that knife blades are removed from knife handles before instruments are sent to be cleaned).
Dispose of sharps safely.
Avoid recapping needles.
Evaluate new safety devices carefully.
The CDC has estimated that 385,000 hospital-based healthcare workers suffer sharps injuries each year . The wounds can range from pinpricks to deep cuts. Statistics such as this spurred OSHA, in 1999, to require facilities to put an exposure control plan into place and update it at least annually. OSHA expects healthcare employers to explore and incorporate new methods to protect staff and patients from bloodborne pathogens [12,25].
OSHA regulations require that an employer provide a copy of the Bloodborne Pathogens Standard to the healthcare professional evaluating an employee after an exposure to blood or other potentially infectious material. An employer should also have a copy of this regulation accessible to employees who are receiving bloodborne pathogen training. In addition to providing a copy of the standard to employees, training regarding the standard should take place as each employee is hired and on an annual basis. All training should be documented and its effectiveness evaluated. Integral to the Bloodborne Pathogens Standard is a requirement that each job in a facility is evaluated for its risk of exposing the employee to body fluids .
As administrators and researchers explore new methods to protect patients, healthcare providers, and the environment from bloodborne pathogens, changes should be balanced with the impact on patient care and user satisfaction. OSHA has cited employers who have failed to implement available safer technology and safe work practices for handling sharps as part of their overall exposure control plan .
The United States has been waging a war against tuberculosis (TB) for more than 150 years. After it was found that a multidrug regimen could effectively kill the Mycobacterium tuberculosis organism, the number of those infected decreased dramatically, and many sanitariums were closed. By 1980, prevention programs were ended and pharmaceutical companies had stopped manufacturing streptomycin. By 1985, the number of new cases of TB had increased, and by the early 1990s, the development of multidrug-resistant TB caused the epidemic to begin anew . Due to recent attention and increased vigilance, incidence rates for TB infection in the United States have begun to decline. In 2012, a total of 9,945 cases of TB were reported in the United States, which represented a 5.4% decline compared to the previous year. This was the lowest recorded rate since 1953, when national reporting began . However, it has been estimated that more than 11 million persons in the United States have latent TB infection, with 5% to 10% at risk for future disease [28,29]. Furthermore, the increasing incidence of multidrug-resistant strains of the disease remains a problem.
Some of the increase in TB cases in the 1980s and 1990s could be partially attributed to immigration from developing countries, where routine immunization and treatment of communicable diseases was enforced less vigorously than in the United States. It could also be attributed partially to the susceptibility of immunocompromised patients, such as those with HIV. Substance abuse, homelessness, poverty, and a deterioration in public health infrastructures were other factors in the resurgence of TB .
This increase in TB prompted the CDC, in 1989, to issue a strategic action plan with the goal of decreasing the case rate of TB to less than 1 per million population by the year 2010. However, the plan was not fully implemented and the number of TB cases increased. In 1993, the CDC outlined basic guidelines for TB control, including the recommendation that all facilities have a formalized plan for the control of TB .
In 1997, OSHA proposed a rule to establish a standard for occupational exposure to TB. In 1998 and 1999, the agency held public hearings and gathered comments regarding the proposed rule. Following a lull in activity, OSHA reopened the comment period in 2002.
APIC worked to ensure that OSHA had all of the most recent TB studies, contending that those studies that depicted current TB epidemiology should be admitted and considered carefully before OSHA issued a final rule. Other groups, including the American Hospital Association, the American Lung Association, and the American Healthcare Association, all agreed on the need for OSHA to consider current clinical information before finalizing rules that would affect all healthcare facilities.
Despite these recommendations, OSHA concluded that a new rule was not needed due to the decline in the number of TB cases. The agency further concluded that a new rule would create confusion for healthcare facilities that were already voluntarily following TB guidelines published by the CDC. In 2003, OSHA withdrew the standard that applied only to respiratory protection against TB. Since the withdrawal, the American Nurses Association, as well as several labor groups, have expressed outrage, believing that TB still poses a serious risk to healthcare workers [6,31,32].
In 2010, OSHA published a request for information to determine whether existing standards and organizational voluntary guidelines are effectively protecting healthcare workers from occupational exposure to infectious agents such as TB .
The General Industry Standard mandates that all healthcare facilities in which healthcare workers use respiratory protection establish and implement a written respiratory protection program that includes procedures specific to the worksite. Employers must provide respirators, training, and medical evaluation at no cost to employees .
The CDC has recommended that healthcare workers receive annual training on the nature, extent, and hazards of TB in the healthcare setting. Recommended training topics include risk assessment, use of environmental controls, how to select and use a respirator, and OSHA regulations regarding respirators. Trainees should be given opportunities to practice handling and wearing a respirator to achieve proficiency. They also should be provided with copies of training materials for future reference .
The CDC has recommended that protective devices used in healthcare settings be certified by CDC/NIOSH as either a nonpowered particulate filter respirator (i.e., N-, R-, or P-95, 99, or 100) or a powered air-purifying respirator and properly fitted to the wearer. The minimum respiratory protection is a filtering facepiece respirator (e.g., N95 disposable) .
Fit testing ensures that the user understands what constitutes a proper fit in order to select a device that provides adequate protection. Periodic fit testing should be included in the initial respiratory protection program training and conducted periodically thereafter as a supplement to employee training and retraining .
The Employee Health Department of the healthcare facility has a critical role in the interpretation and implementation of OSHA guidelines. The employee health professional is the point person for many issues discussed in the first sections of this course. Depending upon the facility's policies and structure, its Employee Health Department may be responsible for the oversight (in conjunction with the Infection Control Department) of many OSHA-related issues, from employee injuries and bloodborne pathogen exposures to high efficiency particulate air (HEPA)-type mask fit-testing records.
Because the Employee Health Department is usually the keeper of records related to employee injuries, it becomes responsible for tracking bloodborne pathogen exposures and ensuring that employees are treated appropriately, that laboratory testing follows the appropriate guidelines, and that prophylaxis, if needed, is available. These records should be retained and recorded on the OSHA 300 Log.
In 2002, OSHA revised the rule addressing the recording and reporting of occupational injuries and illnesses. The goal of this revision was to simplify the overall recordkeeping for employers, generate more accurate information about occupational injuries, and better protect employee privacy . Code of Federal Regulations, title 29, sec. 1904, addresses recordkeeping .
One of the most confusing parts of recordkeeping is determining whether an injury or illness is recordable based on first aid or medical treatment. The revised standard sets new definitions of medical treatment and first aid to simplify recording decisions. An injury or illness is considered work-related if an event or exposure in the work environment either caused or contributed to the condition or significantly aggravated a pre-existing condition .
Work-related injuries and illnesses should be recorded if they result in :
Loss of consciousness
Days away from work
Restricted work activity or job transfer
Medical treatment beyond first aid
Work-related fatalities should be reported within 8 hours. Work-related injuries and illnesses that are significant or meet any of the additional criteria listed below should also be recorded. Any significant work-related injury or illness that is diagnosed by a physician or other licensed healthcare professional or that involves cancer, chronic irreversible disease, a fractured or cracked bone, or a punctured eardrum should be recorded as well .
Any needlestick injury or cut from a sharp object that is contaminated with another person's blood or other potentially infectious material
Any case requiring an employee to be medically removed under the requirements of an OSHA health standard
Tuberculosis infection as evidenced by a positive skin test or diagnosis by a physician or other licensed healthcare professional after exposure to a known case of active tuberculosis
Hearing loss as evidenced by a hearing test (audiogram)
Hearing loss has occurred when the audiogram reveals that the employee has experienced a standard threshold shift (STS) in hearing in one or both ears (averaged at 2000, 3000, and 4000 Hz), and the employee's total hearing level is 25 decibels or more above audiometric zero (also averaged at 2000, 3000, and 4000 Hz) in the same ear(s) as the STS .
Administration of immunizations, such as Hepatitis B or rabies (does not include tetanus)
Use of wound-closing devices, such as sutures and staples
Use of rigid means of support to immobilize parts of the body
Physical therapy or chiropractic treatment
Medical treatment does not include :
Visits to a physician or other licensed healthcare professional solely for observation or counseling
The conduct of diagnostic procedures (e.g., x-rays and blood tests), including the administration of prescription medications used solely for diagnostic purposes
Any procedure that may be labeled first aid
Use of a nonprescription medication at nonprescription strength
Administration of tetanus immunizations
Cleaning, flushing, or soaking of wounds on the surface of the skin
Use of wound coverings (e.g., bandages or gauze pads)
Application of hot or cold therapy
Use of any nonrigid means of support (e.g., elastic bandages, wraps, and nonrigid back belts)
Use of temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, or back boards)
Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister
Use of eye patches
Removal of foreign bodies from the eye using only irrigation or a cotton swab
Removal of splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs, or other simple means
Use of finger guards
Administration of massage
Drinking of fluids to relieve heat stress
If an injury is considered reportable, and therefore recordable, it should be recorded on the OSHA 300 Log. In addition, the injury or illness should be recorded on either the OSHA Form 301 or an equivalent. The OSHA Form 301 provides more information about the case and the individual involved. Information such as the events leading up to the injury or illness, affected body parts, and objects or substances involved should be included. Any form, such as a workers' compensation report or accident report, may be used as long as it contains the same information. OSHA Form 300A should be used to record work-related hearing loss . Other items that should be covered following an employee injury include:
Prompt reporting of the injury
Thorough documentation and investigation
Timely treatment if the injury requires medical attention
Consistent follow-up of an accident without injury or lost time to ensure that time is not lost at a later date
Immediate notification of any insurance carriers
Fast repair of any involved equipment
Prompt recovery of a physician statement
Retention of a physician's release to return to work before the employee returns to duty
Methods of returning employees to work as early as possible through prompt rehabilitation or temporary job description alteration
Accurate reporting on the OSHA 300 Log
An annual summary of injuries and illnesses that occurred during the calendar year should be reported. The annual summary is a total of all the columns to the right of the dotted line on the OSHA 300 Log. A company executive should certify that the summary is correct and complete, and it should be posted for 3 months in areas where other employee notices are normally posted. The OSHA 300 Log, privacy case list (if one exists), annual summary, and OSHA 301 Incident Report form should be retained for 5 years following the calendar year to which they relate .
In the hospital setting, most PPE is used as a barrier to blood and body fluids, such as blood tinged mucous, blood, and urine. Code of Federal Regulations, title 29, sec. 1910.132 to 1910.139, originally published in 1994, address PPE. Subsequent revisions to this standard has incorporated current guidelines, hazard assessments for employee work areas, employee training, and properly fitting PPE. Hand equipment should fit properly and provide the proper protection. The type of glove used for protection from blood or body fluids would not be sufficient for a housekeeper handling caustic chemicals. The right glove for the job being performed is an important consideration .
The Employee Health Department is often considered to be the expert on PPE. OSHA addresses employee training in Code of Federal Regulations, title 29, sec. 1910.132(f). Employees should be trained regarding :
When to wear PPE
What type of PPE is necessary
How to properly don, doff, adjust, and wear PPE
Limitations of PPE
Care, maintenance, useful life, and disposal of PPE
To ensure that each employee is properly trained, clear and measurable objectives should be developed. Because the regulation requires that employees demonstrate an understanding of the PPE guidelines, objectives should center on these criteria.
The employer should verify that employees have been provided with all the necessary training. A written form of documentation with the name of the employee and date of training is required, as well as documentation of retraining .
Depending upon the size of the healthcare facility, the risk manager (in conjunction with the Employee Health Department) may also be responsible for safety issues. All employee injuries and illnesses should be assessed with regard to safety and the possibility that it may somehow have been compromised. When evaluating an employee injury, the safety issues that might affect the outcome (e.g., lifting, glove use, ergonomics, or air quality) should be examined to ensure that no overall safety issues exist. Any safety issues discovered should be documented and reported through the facility's Safety Committee to prove that the issues have been addressed and that no hazards are being neglected. Careful documentation will help the facility avoid the perception that it is ignoring OSHA regulations.
Paramount to a successful employee risk management program is the involvement of the managerial and supervisory staff of the facility. This staff is the first line of defense. It will know the employees and what needs to be done, and it will understand that its example will be emulated. Middle management staff is vital to an employee program. Eliciting cooperation from this staff (i.e., supervisors/managers) will greatly increase the program's success. The staff's concerned attitude, use of necessary protective equipment, and safe work habits will encourage employee participation .
The supervisor is frequently first on the scene after an incident is reported and may be responsible for conducting the initial investigation. The supervisor's commitment to safety and accident prevention is key. Strong organizational policies and procedures that are consistently followed may determine whether an incident results in an employee or patient injury .
In addition, the direct supervisor may also be first to spot safety hazards, such as unsafe lifting, failure to wear PPE, employees who ignore wet floor signs, or the improper disposal of sharps that could lead to a blood or body fluid exposure. Prompt correction and disciplinary action, when indicated, are effective tools in preventing a reoccurrence of the incident. Consistency, fair play, and discipline, when necessary, are fundamental aspects of employee safety .
Some facilities have opted to use onsite care for the injured employee in order to control the employee's care and treat the injury quickly, with as little lost work time as possible. Other facilities have opted to contract with a physician who agrees to see all employees injured at the facility. The physician's familiarity with all injuries may help to cut costs and discover fraud. Injury prevention programs and aggressive workers' compensation case management are keys to controlling costs. The primary objective is to eliminate workplace injuries and lost-time accidents .
An inherent problem related to employee injury may result from conflict between the employee's private physician and the facility's physician. This situation may result in the failure of the employee to receive any medical or monetary benefits for an injury. Reform legislation in Oklahoma, passed in 2005, allows employers to select the employee's physician as part of the terms of employment . Since then, other states have adopted similar laws.
Incident reporting, documentation, and investigation are all aspects that will be covered later in the course, but all of these factors may have a direct effect on successful cost containment for a facility .
One of the factors that will complicate any employee injury is workers' compensation. Each state has its own set of laws; however, prompt reporting of treated injuries and an accurate OSHA accident log will help to lessen any conflicts.
Hundreds of thousands of dollars are spent every year on workers' compensation claims, including money for medical/surgical costs, rehabilitation, and legal fees. Back injuries top the list of employee injuries; in a healthcare facility, these are frequently due to a combination of improper patient lifting and failure to ask for assistance when lifting patients. Slips and falls on wet floors account for many employee injuries as well. The physical building, outside surroundings, patient population, equipment in use, and staffing plan all play a part in the assessment of employee risk.
Workers' compensation court usually requires an initial accident report and a first injury report to be filed within ten days of the injury, even if the injury leads to no lost time. The documentation of the injury should be complete and kept at the facility. OSHA requires employee health records to be kept confidential .
A record of an employee injury is also provided to any third-party payer (i.e., insurance carrier). Some facilities are self-insured. Others have one insurance company that specializes in employee injuries and a second company that handles liability claims, such as physician malpractice or patient/visitor injuries. Prompt reporting to the facility's various carriers will put the facility in the best position to keep costs down. In addition, a good relationship with the insurance carriers will often result in the receipt of educational material that may lighten the risk manager's education responsibilities.
Employees should understand that prompt reporting will lead to effective treatment and lower overall costs to the facility. Risk managers should be familiar with the workers' compensation laws in their own states. It is wise to have the handbook available for reference.
Violence in the workplace is an issue that is increasingly receiving public attention. An estimated 2 million workers are injured each year during a workplace assault. While a majority of these injuries are nonfatal, the U.S. Bureau of Labor Statistics has reported that of the 4,383 fatalities in the workplace in 2012, 767 workers were fatally injured by assault and/or violent attack [40,41].
Approximately 48% of all nonfatal workplace assaults occur in service settings, such as hospitals, nursing homes, and social service agencies. This increased risk may be attributed to several factors, such as the prevalence of handguns among patients, their families, or friends; the use of hospitals by the criminal justice system as places to hold disturbed and/or violent individuals; the unrestricted movement of the public in healthcare facilities; and isolated work with patients . Workplace assaults result in lost workdays and millions of dollars in lost wages each year .
Ongoing and thorough employee safety education should be an inherent component of the facility's risk management and employee injury prevention programs. Education on back injuries is especially important, as such injuries are costly. In addition, safety information should always be part of a new employee's orientation to a facility and should include safe patient lifting, hazardous material handling, bloodborne pathogen precautions, sharps handling, and incident reporting. Documentation of this education is essential.
The mission of OSHA is to provide a safe workplace for all employees. A well organized employee health risk management program can help a facility meet OSHA requirements.
The Hazard Communication Standard, also known as the Right-to-Know Law, was first enacted by OSHA in 1983. It was modified in 1994 and is referenced as Code of Federal Regulations, title 29, sec. 1910.1200 [9,44].
The purpose of this standard is to ensure that chemical hazards in the workplace are identified and evaluated. This is the responsibility of chemical manufacturers and importers, who are required to provide hazard information to employers who purchase their products. Employers are then required to inform employees about the hazards of workplace chemicals—from liquid correction fluid to formaldehyde—to ensure that employees can monitor their exposure to hazardous chemicals and protect their health. Employers who neither produce nor import chemicals are only required to ensure that hazard information is transferred to its employees by means of a comprehensive hazard communication program, which should include container labeling and other forms of warning .
The Hazard Communication Standard defines a hazardous chemical as one that presents either a physical hazard (i.e., fire, explosive, or reactive) or a health hazard (i.e., one with systemic or target organ effects) in the workplace. Certain chemicals have been specifically designated as hazardous. A list of these chemicals is provided by several agencies, including :
OSHA Toxic and Hazardous Substances (Code of Federal Regulations, title 29, sec. 1910.1030 App A)
American Conference of Governmental Industrial Hygienists
National Toxicology Program Annual Report on Carcinogens
International Agency for Research on Cancer Monographs
If a chemical is encountered that is not found on one of these lists, it is the employer's responsibility to search other scientific literature to determine if the chemical is hazardous. Every chemical used or encountered in the facility should have a Material Safety Data Sheet (MSDS) readily available to employees, which should be updated on a regular basis. Training and documentation of the training should be provided and take place at the time of initial assignment, whenever a new, potentially dangerous chemical is introduced into the workplace.
A hazard communication program may include, but is not limited to :
Understanding OSHA requirements
Assigning responsibility for tasks
Preparing an inventory of chemicals
Determining where to maintain a list of the hazardous chemicals (i.e., in each work area or in a central location)
Ensuring that containers are labeled
Obtaining MSDS for each chemical
Ensuring that employees are informed of the hazards associated with chemicals contained in unlabeled work areas
Developing and maintaining a written hazard communication program for the workplace
Preparing and distributing MSDS to workers
Training workers regarding hazards and protective measures
Establishing procedures to evaluate the program's effectiveness
Approximately 20% of wastes generated by healthcare facilities are considered hazardous materials that may be infectious, toxic, or radioactive. These materials include :
15% infectious and anatomic waste (i.e., cultures/stocks of infectious agents; wastes from infected patients; wastes contaminated with blood/blood derivatives; infected laboratory animals; contaminated medical supplies or equipment; and recognizable body parts)
3% chemicals (e.g., solvents/disinfectants) and pharmaceuticals
1% sharps (e.g., syringes, disposable scalpels, or blades)
1% genotoxic waste (i.e., highly hazardous, mutagenic, or carcinogenic), radioactive matter, and wastes with high heavy metal content (e.g., broken mercury thermometers)
Hospitals and other healthcare facilities, laboratories, research clinics, mortuaries, autopsy clinics, blood banks, and nursing homes are major sources of healthcare waste. The wealthiest nations can produce up to 6 kg of hazardous waste per person per year. Although poorer nations generate lesser amounts of waste, they typically do not distinguish between hazardous and nonhazardous waste . Each facility that generates infectious waste should have a waste management plan that covers: the segregation, packaging, storage, treatment, transport, and disposal of the waste; and employee training on the proper handling of the waste. Sharps should be kept in leak proof, rigid, puncture-resistant containers that are either red in color or visibly labeled with the word "sharps" and the biohazard symbol. Infectious waste, other than sharps, should be kept in containers that are impenetrable to moisture, strong enough to resist tearing, and stored in a secure area. The area should be air conditioned and inaccessible to animals, rodents, and vermin .
The waste should be autoclaved or incinerated before being disposed of in regular landfills, depending on state laws. If waste is transported away from the facility, it should be placed in containers or compartments that prevent scattering, spillage, and/or leakage of waste during transport, and it should not be transported along with noninfectious waste unless all of the waste is handled as infectious .
The importance of a facility-wide approach to ensure compliance
The necessity for use of established benchmarks, such as pounds of regulated medical waste (RMW) per patient day, or pounds of RMW as a percentage of overall waste in the facility
The careful placement of RMW containers
The issues relating to bidding for services
The appropriateness of waste logos
Reusable versus disposable issues
The treatment options for medical waste
Determining how to reduce waste is an ongoing concern. Replacing disposable waste items from dialysis, surgery, or autopsy (e.g., towels, sheets, lab coats, and underpads) with reusable items has the potential to reduce the weight and volume of red bag waste by 73% and 93% respectively [48,73].
Employers are responsible to evaluate and measure levels of any radiation or concentrations of radioactive material present, where applicable. Appropriate personnel monitoring equipment, such as film badges, should be available, and each radiation area should be conspicuously posted with a sign or signs bearing the radiation caution symbol . (Employers should refer to state guidelines for information regarding the radiation produced by radiographic [x-ray] machines.)
The Nuclear Regulatory Commission (NRC), OSHA, and individual states all provide regulations regarding radiation safety. It is the responsibility of the healthcare organization to determine which regulations are applicable to its facility. NRC regulations apply to facilities that have radioisotopes on site, such as facilities that are engaged in nuclear medicine and using radioactive sources. OSHA regulations apply to organizations that are merely performing medical imaging, including magnetic resonance imaging (MRI). If the facility is a Veteran's Administration or other federal facility, it should always comply with OSHA regulations. However, if a facility is located in a state that has an agreement with OSHA to set its own occupational safety standards (which must be at least as stringent as OSHA's), then the state's requirements apply [49,74].
OSHA has set standards for radiation exposure levels and requires a radiation monitoring program. However, the radiation monitoring program need not continue indefinitely. Employers are not required to provide monitor badges to employees just because they work in an area where radiation is used. They are only required to provide monitor badges to those employees likely to receive a dose of radiation in excess of 25% of the allowed quarterly exposure limits and to employees who work in a high-radiation area. When an organization has the compiled the necessary data through radiation surveys and monitoring results, it may reduce the scope of a program that is costly and time-consuming. The acquired data should document that employee exposure levels to radiation are less than 25% of the allowed quarterly limits set by OSHA .
If data is available to show that employee exposures do not exceed 25% of these quarterly limits and that the employees do not work in a high-radiation area, then the employees need not be monitored or provided with monitor badges. Additional monitoring requirements may apply to employees younger than 18 years of age or those working with radioisotopes. They may also apply if new equipment and processes have been introduced .
The radiation monitoring requirements for the majority of small, rural healthcare organizations are minimal for two reasons. First, these smaller facilities typically use only general radiographic equipment, and second, they do not normally have nuclear medicine programs that utilize radioisotopes.
Part of the healthcare facility's responsibilities for workplace safety rests with its ability to have a plan in place for managing spills of all kinds . Both blood spills and chemical spills (e.g., formaldehyde) contain the potential for employee injury.
Location of the spill (i.e., counter, cabinet, or surgery)
Quantity of the chemical or biological product released
Physical properties of the released substance
Hazardous properties of the material released (i.e., toxicity, flammability, and corrosivity)
Types of protective equipment needed
Clean-up supplies should include, but are not limited to:
Neutralizing agents, such as sodium bicarbonate or sodium bisulfate
Absorbents, such as sand or vermiculite
Pans, small shovels, or scoopers
Containers with lids for disposal
The healthcare facility should follow these guidelines if a spill occurs:
Attend immediately to all personnel who may have been contaminated.
Notify personnel in the immediate area of the spill.
If spilled material is flammable, turn off any electrical sources.
Contain the spill using an absorbent material, for example:
Pour absorbent material around the perimeter of the spill.
Once contained, pour additional absorbent into center of spill.
Use a small shovel or scooper to work absorbent located around the perimeter into the middle until all the chemical is absorbed.
During clean up, use protective equipment, such as gloves, safety glasses, and respiratory protection.
Leave on or establish exhaust ventilation, if safe to do so.
Spill kits for both chemical and blood spills should be placed strategically around the facility. All personnel should be trained in the use of the spill kits, and that training should be documented. Policies should be in place that cover spill clean up, protective equipment, handling solid or liquid spills, and the storage and handling of any chemicals.
The easiest way to prevent spills is through careful storage and handling. Chemicals should be stored in properly labeled containers with special attention to hazard warnings. Flammables should be stored in special storage areas; this includes items such as paint and turpentine. Water-reactive chemicals require dry storage. Compressed gas cylinders should be secured and properly supported.
Workplaces that handle flammable chemicals, process hazardous waste, or house patients should be concerned with the risk of fire. Fire safety should be part of any hazard communication training program. Smoke alarms, sprinklers, and/or fire extinguishers should be present. All employees should know about the fire risks associated with chemicals, gases, or equipment used. They should also know how to respond to a fire, which includes how to rescue patients and other employees, and how to locate and properly use fire extinguishers.
Fire safety plans should include fire emergency preparation, including alarm systems, marked exits, and written emergency plans. Many hospitals use acronyms such as RACE (Rescue, Alert, Confine, Extinguish) to help employees remember the proper steps for fire emergency response.
Annual inspections by the fire marshal, quarterly fire drills, annual fire safety in-services, and monthly fire extinguisher documentation are all elements of a successful fire safety program. Staff education and documentation of the education forms another integral part of the fire safety plan.
OSHA requires that employers develop and maintain on site a written fire prevention plan. The plan must be available for employee review; employers with 10 or less employees may orally communicate the plan. The plan should include a list of all major fire hazards, proper handling and storage procedures for hazardous materials, potential ignition sources and how to control them, and the type of protective equipment needed to control each type of hazard .
Over the last 20 years, concerns about the quality of indoor office environments have risen dramatically in the United States. The term "sick building syndrome" (SBS) describes a range of acute health and comfort effects that workers link to time spent in a building. Workers identify the building as the cause of their symptoms because they find relief from the symptoms when they leave the building. SBS may be caused by inadequate ventilation, chemical contaminants from indoor or outdoor sources, and biological contaminants. Although some symptoms and illnesses have been associated with a building's characteristics (e.g., dampness), medical and environmental tests often are not able to identify an offending contaminant in SBS. In contrast, a building-related illness (BRI) is one in which the symptoms of a diagnosable illness can be both identified and directly attributed to a specific airborne building contaminant [50,51].
NIOSH uses the term indoor environmental quality (IEQ) to describe the problems associated with air quality in an office or other building environment. NIOSH investigates potential health hazards in the workplace by means of a Health Hazard Evaluation (HHE). Results of HHEs have indicated that, in addition to concerns about a building's air quality, employees have reported concerns about comfort, noise, and lighting as well as job-related ergonomic and psychosocial stressors .
When NIOSH conducts an HHE, it investigates a building's pollutant sources and pathways, its heating, ventilating, and air conditioning (HVAC) system, and its occupants. The HVAC system impacts how pollutants are distributed throughout the building as well as how they are removed from the building's air supply. Common pollutants and their sources include carbon dioxide, molds, bacteria, cleaning products, copy machines, and pesticides. An improperly maintained HVAC system may also be a source of pollutants .
An area of IEQ concern for hospitals is the operating room, where workers may be exposed to waste anesthetic gases, including nitrous oxide and halogenated anesthetics (e.g., halothane, enflurane, and isoflurane), while administering anesthesia. Exposure may also occur in the recovery room when the patient exhales the gases.
Some studies have reported miscarriage, genetic damage, and cancer among workers in operating rooms who have experienced long-term exposure to low concentrations of these gases. Exposure to high concentrations may cause headache, irritability, fatigue, nausea, drowsiness, difficulties with judgment/coordination, and liver and kidney disease. NIOSH has recommended the following safeguards to reduce worker exposure to waste anesthetic gases :
Install a well-designed scavenging system that includes securely fitting masks, sufficient flow rates for the exhaust system, and properly vented vacuum pumps.
Install a ventilation system that circulates and replenishes the air in operating rooms and recovery rooms.
Monitor anesthetic equipment with leak test equipment and monitor the room air. Maintain good records of all collected air samples.
Prevent leakage from the anesthetic delivery system by replacing loose-fitting connections, loosely assembled or deformed slip joints and threaded connections, and defective or worn seals, gaskets, breathing bags, and hoses.
Provide employee training on hazard awareness, prevention, and exposure control.
Obtain baseline liver/kidney data for operating-room workers and periodically monitor their organ functioning.
The word ergonomics is derived from the Greek words ergon (work) and nomos (principle or law). It was first coined by a Polish scientist and educator in 1857 . The science of ergonomics was not widely applied until World War II, when the fast pace of war manufacturing created physical and psychological problems among workers . Ergonomics is now defined as the science of fitting workplace conditions and job demands to the capabilities of the working population. Successful fits assure high productivity, reduced worker illness and injury, and increased worker satisfaction .
Although the scope of ergonomics is broad, OSHA primarily uses the term to define and assess work-related factors that put individuals at risk of musculoskeletal disorders (MSDs). Examples of ergonomic risk factors have been identified in jobs and tasks that require prolonged, repetitive movements; recurrent heavy lifting, pushing, or pulling; and prolonged, awkward working positions. Employee exposure to vibration and cold may also be risk factors .
When seeking to identify conditions that may be contributing to MSDs, OSHA has recommended that employers :
Review/analyze injury/illness records (i.e., OSHA 300 Logs, and workers' compensation claims) to determine whether certain jobs/tasks are associated with ergonomic-related injuries;
Analyze the jobs/tasks before assigning them to workers and before injuries have occurred; include employee input and make corrections where necessary; and
Be aware of industry-wide conditions that contribute to ergonomic-related injuries (e.g., back injuries among healthcare workers).
Medical management, employee training and education, and workstation design are important components of an ergonomics program. Many hospitals and physicians' offices have gone paperless, yet millions of workers in the United States continue to work with computers every day . OSHA has developed guidelines for helping employers and employees create workstations that are both safe and comfortable . Although no single correct posture or workstation arrangement exists, adhering to some basic design goals may help to minimize or eliminate problems. Adjustable chairs, foot rests, armrests, and computer monitors may help to reduce injuries. Lighting, work processes, and worker posture are additional factors to consider when conducting an ergonomic assessment of the workplace . Employees should be trained on ergonomic issues to help them identify problem areas within their jobs. Failure to recognize some of the early warning signs (e.g., numbness, blurred vision, aching or tingling, and weakness) may allow a small problem to become a serious injury .
In 1999, OSHA published a proposed Ergonomic Program Standard. This proposed standard applied to general-industry employers whose employees performed manufacturing or manual handling tasks and reported MSDs . In 2000, the House voted to block federal rules aimed at preventing some of the 1.8 million workplace injuries that American workers were suffering annually. In 2001, President George W. Bush signed a joint resolution of Congress that disapproved OSHA's proposed Ergonomics Standard. As a result, the standard is no longer in effect, and employers and employees are not bound by its requirements .
Although no standards exist to universally regulate ergonomics, OSHA has established a protocol for developing industry and task-specific ergonomic guidelines . OSHA has developed guidelines for poultry processing, retail grocery stores, shipyards, and nursing homes; however, specific ergonomic standards for healthcare professionals have yet to be established .
Despite the lack of a final standard, employers are still obligated to follow the General Duty Clause, Section 5(a)(1), of the OSH Act, which requires employers to maintain a workplace that is free of serious hazards, including ergonomic hazards, whether or not voluntary guidelines exist. OSHA will continue to cite for ergonomic hazards [62,63].
Concern over public health issues and the need for occupational PPE has led to an increase in the use of latex gloves among healthcare workers. This increase has in turn resulted in high reports of skin reactions to latex among this population . OSHA has estimated that up to 12% of healthcare workers may be sensitive to latex . Most reactions are not serious and can be prevented. However, for some individuals, exposure to latex may be life threatening. Sensitivity to latex has been found to persist for as long as 5 years beyond discontinued use among some healthcare workers .
Individuals with a high risk of developing a latex allergy include healthcare workers, those with a history of allergies, and anyone who frequently comes in contact with latex products. Latex allergies commonly begin with a rash on the hand after wearing a latex glove. The three main types of reactions are irritant contact dermatitis, allergic contact dermatitis, and hypersensitivity immune system response .
Irritant contact dermatitis is a nonallergic, inflammatory response characterized by dry, itchy, flaky skin (usually on the hands) with cracks and sores. It may be caused by skin irritation from wearing gloves, exposure to other products and chemicals in the workplace, or repetitive hand washing and drying. Powders added to gloves, combined with sweat, may aggravate existing dermatitis. Wearing cotton liners, choosing a nitrate or vinyl glove, and avoiding the use of gloves when possible may provide relief for the dermatitis [67,68].
Allergic contact dermatitis, also referred to as delayed hypersensitivity or chemical sensitivity dermatitis, is not easily distinguished from irritant contact dermatitis because the reactions resemble those caused by poison ivy. However, in spite of the similar symptoms, allergic contact dermatitis is caused by a cellular immune response in the body, activated by repeated exposure to the allergen, latex [67,68].
Hypersensitivity immune system response is an actual latex allergy. This type of response is characterized by pruritus, inflammation, swelling, hives, and wheezing, usually immediately after exposure. Even low levels of exposure may trigger allergic reactions in some sensitized individuals. The response may progress to anaphylaxis in susceptible individuals, which is evidenced by hypotension, confusion, and extreme airway constriction. Individuals experiencing anaphylactic shock require immediate treatment. Allergy to latex should be suspected in any individual who develops specific symptoms, such as nasal irritation, hives, shortness of breath, wheezing, or unexplained shock [67,68].
Changing to a nonlatex glove to eliminate reactions may not work because some nonlatex gloves may still contain chemical sensitizers. Gloves labeled hypoallergenic do not necessarily eliminate allergic reactions. The use of hypoallergenic gloves may minimize the likelihood of an allergic reaction but will not eliminate the possibility of a reaction. Additional protective measures recommended by NIOSH include :
Good housekeeping practices in the workplace to minimize dust that contains latex
Employee education and training on latex allergy
Periodic screening for high-risk employees
Employer evaluation of prevention strategies
Employers should take all measures to find the kind of glove that may be worn safely by employees without exposing them to the external hazards of harmful material or the internal hazards of a reaction to the equipment providing protection .
Employee training and education are emphasized throughout the OSHA standards. Employers should consider the following components when developing a training program :
Designate a person responsible for conducting the training
Design a specific format for the training program (e.g., audiovisuals on classroom instructions)
Identify the important elements of the training program
Develop and implement procedures to train new employees at the time of their initial assignments
When OSHA visits a facility, it expects the facility to be able to produce a written training program that addresses all aspects of safety, including fire safety, hazard communication, and disaster plans. OSHA will additionally expect employers to provide proof of employee education (e.g., lesson plans, inservice dates, sign-in sheets, and education evaluations). The Bloodborne Pathogens Standard requires employee education to occur immediately upon hire. Documentation should reflect that this has occurred .
In today's litigious society, any facility is at risk for lawsuits. If an employee is injured on the job and able to show that a lack of safety equipment or training or unsafe conditions caused the injury, the facility is at risk for litigation. Lack of proper treatment of the injury and continuing unsafe conditions might also contribute to an employer's risk for litigation.
Attorneys who investigate incidents of employee injury will expect to be able to examine available documentation, including incident reports, medical records that include treatment of the employee, and training and education records. Safety conditions that might have caused the injury, any perceived unsafe conditions that exist, the safety committee minutes that show how the facility has addressed the condition, and further actions to correct the condition may also be reviewed.
Knowing what the standards prescribe for a particular facility and properly documenting all programs (e.g., written plans, the education program, or follow-up of existing conditions) will provide the employer with the best protection possible. Employers should carefully read the standards and provide training seminars and other relevant employee resources to ensure that their facilities are in compliance.
The General Duty Clause mandates employers to furnish employees with a workplace that is free from recognized hazards that may cause death or serious physical harm. To avoid citations, employers should comply with standards. This may be accomplished by employing an internal safety staff or by employing an outside private consultant. Free consultations are available to small businesses with no more than 250 employees at one site and no more than 500 employees total at all sites . Consultation may be invaluable for small, rural facilities.
Requests for the OSHA consultation service may be made in person, over the telephone, or in writing. The consultation will include an opening conference and an inspection to examine building structure, air and noise monitoring procedures, PPE, job training, safety and health programs, injury and illness records, and hazard communication procedures .
After the inspection has been completed, a closing conference will occur during which potential problems will be discussed. If the consultant has deemed a condition to be an "imminent danger," the employer should take immediate action to correct the condition. If a condition is deemed to be a "serious violation" (according to OSHA regulations), the consultant and employer will together devise a corrective action plan. The consultant may also recommend increased training and monitoring, safety promotion, and accountability procedures .
Employers may benefit from a one-year exemption from inspection (not including inspections prompted by employee complaints or fatalities) if all identified hazards have been corrected and the employer has instituted a comprehensive safety program. The consultant will not issue citations, impose penalties, routinely report violations to OSHA, or guarantee that a worksite will pass an OSHA inspection .
An OSHA inspector will visit a facility to conduct either a programmed inspection or an unprogrammed inspection. A programmed inspection is generally scheduled due to OSHA's selection criteria, such as injury/death rates, toxic substance exposure, and a high number of lost workdays for the industry type. An unprogrammed inspection occurs when an employee formally complains to OSHA about either a potentially unsafe working condition or an imminent danger at the workplace .
Employers should understand the limits of the OSHA inspection. For example, employers may voluntarily consent to an inspection but they are not required, according to the Fourth Amendment to the U.S. Constitution, to admit inspectors who do not present a warrant. Although the additional time it takes OSHA to secure a warrant may allow the employer to resolve immediate and critical compliance issues, employers who proactively create and use area-specific self-inspection checklists may help minimize hazards and avoid compliance violations .
During the opening conference, the OSHA inspector will explain the purpose of the visit, provide OSHA pamphlets, request identification of trade secrets, and review the employer's records. Employers are not required to provide records that are not specified by the warrant. Records and programs that are usually specified include the written hazard communication and safety programs, the injury/illness log, and hazard exposure records. The results of the records review determine whether a comprehensive workplace inspection is needed. A short tour of the facility may also be conducted .
The OSHA inspector and any accompanying representatives determine the route and duration of the tour; however, the inspector should always be accompanied a representative of the employer. If the inspector wishes to see a specific part of the facility, the employer's representative should escort the inspector directly there. During the tour the inspector may talk with employees or meet with them in private (with their permission), take notes, make instrument readings, and take photos or videos. If the inspector takes notes or measurements or uses a camera, the employer should do the same and should also record everything that has happened during the tour, noting the time and date. If the inspector has identified potential problems (even when the employer agrees and immediately corrects the problems), the inspector will likely issue citations and fines .
The purpose of the closing conference is to :
Advise the employer about conditions observed in the facility
Obtain further information
Relate possible citations, appeal rights, and associated time limits
Answer the employer's questions
If violations are voluntarily and immediately corrected, the employer should make certain that the inspector acknowledges this before leaving the facility. This should be confirmed in the presence of a witness, with the date and time noted.
The U.S. Department of Labor will notify the employer, in writing, about any citations or penalties. The employer then has 15 working days to either pay the penalties or to contest the citations, penalties, or both. If the employer fails to contest the citations, the penalties are final .
The violations, and their associated penalties, that have been structured for the workplace include :
Other than serious citation: Given when violations are not likely to cause death or serious harm (e.g., lack of labeling a biohazard). The fine may be up to $7,000.
Serious violation: Given when the employer is aware of a hazard that may result in death or serious physical harm (e.g., not locking out or tagging out equipment). The fine may be up to $7,000 for each violation.
Willful violation: Given when the employer intentionally and knowingly commits a violation. The penalty may be up to $70,000 per violation. A willful violation that causes an employee's death may result in imprisonment.
Repeat violation: Given when a violation has not been corrected. The fine may be as much as $70,000, plus $7,000 per day until the violation is corrected.
To plan for an OSHA inspection, employers should understand the law (consult Code of Federal Regulations, title 29, sec. 1910), know what the inspector is likely to do, develop and implement a self-inspection program, and ensure that safety and health training programs are in place.
|AIDS: Acquired immunodeficiency syndrome|
|APIC: Association for Practitioners in Infection Control and Epidemiology|
|BRI: Building-related illness|
|CDC: Centers for Disease Control and Prevention|
|CFR: Code of Federal Regulations|
|HBV: Hepatitis B virus|
|HCV: Hepatitis C virus|
|HEPA: High-efficiency particulate air|
|HHE: Health Hazard Evaluation|
|HIV: Human immunodeficiency virus|
|HVAC: Heating, ventilating, and air conditioning|
|IEQ: Indoor environmental quality|
|MRI: Magnetic resonance imaging|
|MSDS: Material Safety Data Sheets|
|NIOSH: National Institute for Occupational Safety and Health|
|NRC: Nuclear Regulatory Commission|
|OSHA: Occupational Safety and Health Administration|
|OSH Act: Occupational Safety and Health Act|
|OSHRC: Occupational Safety and Health Review Commission|
|PPE: Personal protective equipment|
|RACE: Rescue, alert, confine, extinguish|
|RMW: Regulated medical waste|
|SBS: Sick building syndrome|
|STS: Standard threshold shift|
|UP: Universal Precautions|
|VDT: Video display terminals|
The most important resource is the Code of Federal Regulations, title 29, sec. 1910. Additional resources include:
|Association for Professionals in Infection Control and Epidemiology, Inc.|
|1275 K Street, NW, Suite 1000|
|Washington, DC 20005|
|National Institute for Occupational Safety and Health (NIOSH)|
|1600 Clifton Road|
|Atlanta, GA 30333|
|National Institute of Environmental Health Sciences (NIEHS)|
|P.O. Box 12233, MD K3-16|
|Research Triangle Park, NC 27709|
|U.S. Department of Labor, Bureau of Labor Statistics|
|Postal Square Building|
|2 Massachusetts Avenue, NE|
|Washington, DC 20212|
|U.S. Department of Labor, Occupational Safety and Health Administration|
|200 Constitution Avenue NW|
|Washington, DC 20210|
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