- Musculoskeletal disorders (MSDs) relating to patient or
resident handling,
- Workplace violence (WPV),
- Bloodborne pathogens (BBP),
- Tuberculosis (TB), and
- Slips, trips and falls (STFs).
These focus hazards will be addressed in addition to other
hazards that may be the subject of the inspection or brought to the
attention of the compliance officer during the inspection. The goal
of this policy is to significantly reduce overexposures to these
hazards through a combination of enforcement, compliance
assistance, and outreach.
Background: The U.S. Department of Labor's Bureau of Labor
Statistics (BLS) and OSHA's inspection history with the NH NEP have
shown that inpatient healthcare settings consistently have
exposures to the safety and health hazards noted above.
For example, with regard to MSDs, between April 5, 2012 and
April 5, 2015, OSHA conducted 1,100 inspections of nursing and
residential care facilities under the NH-NEP. Ergonomic stressors
were evaluated in 596 of these inspections, which generated 192
ergonomic hazard alert letters (EHALs) to employers and 11
citations of OSHA's general duty clause for hazardous ergonomic
conditions. Additional information on the incidence of MSDs and the
other focus hazards is provided in Attachment 1.
Scope: This guidance applies to all Federal OSHA inspections,
programmed and unprogrammed, conducted in NAICS Major Groups 622XXX
(hospitals) and 623XXX (nursing and residential care
facilities).
Regions may determine that a Regional or Local Emphasis Program
is justified after reviewing relevant data (e.g. , review of the
number of sites in the region) and as considerations of other
resources demands. The guidance in this memorandum should be
included in any Regional or Local Emphasis Programs developed to
inspect facilities in the aforementioned NAICS.
State Plan Impact: Because these hazards are nationwide, State
Plans are expected to follow the guidance provided in this
memorandum. State Plans may have an existing State Emphasis Program
(SEP), or, similar to OSHA's Regions, determine that an SEP is
warranted after reviewing relevant state data. State Plans must
code inspections conducted in accordance with this guidance as
noted below ("OSHA Information System").
Other Hazards: In addition to the focus hazards listed above,
and hazards that may be the subject of the programmed or
unprogrammed inspection, other hazards that may be encountered in
inpatient healthcare settings include, but are not limited to:
- Exposure to multi-drug resistant organisms (MDROs), such as
Methicillin-resistant Staphylococcusaureus
(MRSA).
- Exposures to hazardous chemicals, such as sanitizers,
disinfectants, anesthetic gases, and hazardous drugs.
As detailed in the FOM (OSHA Instruction {CPL 02-00-160}), when such additional hazards
come to the attention of the compliance officer, the scope of the
inspection may be expanded to include those hazards.
Inspection Procedures: Inspections shall follow the guidance in
the FOM, directives, or State Plan equivalent policies relevant to
the focus hazards and other hazards encountered, with the addition
of the specific guidance provided in Attachment 2. Sample Alleged
Violation Descriptions (AVDs) for MSD and MRSA exposures may be
found in Attachment 3.
Recordkeeping issues must be handled in accordance with OSHA
Instructions, CPL 02-00-135, Recordkeeping Policies and
Procedures Manual, and CPL 02-02-069, Enforcement Procedures for
the Occupational Exposure to Bloodborne Pathogens, other
relevant field guidance, or State Plan equivalent policies. A
partial walkthrough shall be conducted and workers shall be
interviewed in order to verify injury and illness records.
Compliance officers shall follow current OSHA procedures regarding
privacy of patient and resident medical records.
CSHOs are encouraged to contact the Directorate of Technical
Support and Emergency Management's Office of Occupational Medicine
and Nursing (OOMN) to obtain a Medical Access Order, if necessary,
early in the inspection process. OSHA Directive CPL 02-02-072, Rules of Agency practice and
Procedure Concerning OSHA Access to Employee Medical Records
provides guidance when there is a need to gain access to such
personally identifiable employee medical information
Outreach, Compliance Assistance, and Training: The National
Office has developed additional information, such as compliance
assistance tools to support outreach, and training of compliance
safety and health officers (CSHOs) and compliance assistance
specialists (CAS), to address technical issues related to the
focused hazards, including ergonomics and evaluation of MSD
recordkeeping procedures. In 2014, OSHA published a new educational
web resource with extensive materials to help hospitals prevent
worker injuries, assess workplace safety needs, enhance safe
patient handling programs and implement comprehensive safety and
health management systems. This new resource contains a suite of
guidance products, including fact sheets, self-assessments, and
industry-recognized best practices, and is available at http://www.osha.gov/dsg/hospitals/. OSHA
conducted additional outreach efforts in 2014 by sending out
thousands of letters, with enclosed fact sheets, to hospitals
across the country, which provided tools to assist them in their
efforts to reduce worker exposure to hazards that are prevalent
within this industry.
Furthermore, OSHA has well-established webpages, such as Safety
and Health Topics webpages for Nursing Homes and Personal Care
Facilities (http://www.osha.gov/SLTC/nursinghome/index.html)
and Healthcare (http://www.osha.gov/SLTC/healthcarefacilities/index.html).
The Agency published the brochure, Safe Patient Handling:
Preventing Musculoskeletal Disorders in Nursing Homes (https://www.osha.gov/Publications/OSHA3708.pdf),
in 2014. These and additional references may be found in Attachment
4.
OSHA Information System: For all inspections meeting the
definitions of this guidance (for NAICS Codes 622 and 623), code in
OIS "N-03-Nursing-Hosp" for either Federal or State Plan
enforcement activity. Coding for ergonomic enforcement activity
must also be consistent with existing field guidance for OIS
coding.
This policy is effective as of the date of this memorandum. This
memorandum also cancels OSHA Memorandum, Expiration of the
Nursing Home NEP, Effective April 5, 2015, dated April 2,
2015, and it cancels OSHA Instruction, CPL 03-00-016. If you have
questions, please contact Dionne Williams at (202) 693-2140 or
williams.dionne@dol.gov.
Attachments
cc: Directorate of Cooperative and State Programs
{Corrections 08/23/2018 with updated references and
hyperlinks.}
Attachment 1
Background on Focus Hazards in Inpatient Healthcare Settings
General. Inpatient healthcare settings have some of the highest
rates of injury and illness among industries for which nationwide
injury and illness rates were calculated for Calendar Year 2013 (CY
2013). In 2013, U.S. hospitals recorded 244,800 work-related
injuries and illnesses, a total case rate of 6.4 work-related
injuries and illnesses for every 100 full-time employees, almost
twice as high as the rate for private industry as a whole (3.3 per
100 full-time employees for all U.S. industries). Additionally, of
these recorded cases in hospitals, 57,680 cases resulted in lost
workdays. [12, BLS].
Nursing homes and personal care facilities continue to have one
of the highest rates of injury and illness among industries for
which lost workday injury and illness (LWDII) rates are calculated.
According to data from the BLS, in 2013 one in five reported
nonfatal occupational injuries occurred among workers in the health
care and social assistance industry, the highest number of such
injuries reported for all private industries. [16, CDC]. BLS
reported the national average days away, restricted work activity
and job transfer (DART) rate for private industry for CY 2013 was
1.7 per 100 full-time employees. Hospitals, nursing and residential
care facilities, i.e. , employers within NAICS 622 and 623,
experienced average DART rates of 2.6 and 4.5, respectively,
despite the availability of feasible controls to address the
hazards that account for these high rates. This compares to a DART
of 2.2 for construction workers in the private sector. General
medical and surgical hospitals (NAICS codes 6221), Psychiatric and
substance abuse hospitals (6222); and Specialty, except psychiatric
and substance abuse facilities (6223) experienced average DART
rates of 2.5, 3.8, 3.1, respectively, and nursing and residential
care facilities (NAICS 6231, 6232, 6233, and 6239) had rates of
5.0, 3.7, 4.3, and 3.4, respectively. [12, BLS].
The three-year CPL 03-00-016, National Emphasis Program -
Nursing and Residential Care Facilities, (NAICS 623110, 623210,
623311) (NH-NEP), completed in April 2015, addressed the same
primary hazards of MSDs, WPV, BBP, TB and STFs. [6, OSHA]. As of
April 5, 2015, both a qualitative and quantitative review of the
data yielded from those inspections conducted, indicated the need
for the Agency to continue its efforts to materially reduce or
eliminate worker exposure to these focus hazards in residential
care facilities.
Between April 5, 2012, and April 5, 2015, OSHA conducted 1,100
inspections (approximately 75% of which were programmed) of nursing
and residential care facilities under the previous NH-NEP.
Ergonomic stressors were evaluated in 596 of these inspections,
which generated 192 ergonomic hazard alert letters (EHALs) to
employers, and 11 citations of OSHA's general duty clause for
hazardous ergonomic conditions.
According to the Centers for Disease Control and Prevention
(CDC), as published in the Morbidity and Mortality Weekly
Report (MMWR) Vol.64/No.15, the National Institute for
Occupational Safety and Health (NIOSH), with collaborating
partners, created the Occupational Health Safety Network (OHSN) to
collect detailed injury data to help target prevention efforts.
Their data covered 112 U.S. facilities, which reported 10,680
OSHA-recordable injuries from January 1, 2012-September 30, 2014:
patient handling and movement (4,674 injuries); slips, trips, and
falls (3,972 injuries); and workplace violence (2,034 injuries).
Overall incidence rates of OSHA-recordable injuries (average
worker-months = 125,041) per 10,000 worker-months for patient
handling, slips, trips and falls, and workplace violence were 11.3,
9.6, and 4.9, respectively. [16, CDC].
MSDs and Overexertion. BLS data for CY 2013 demonstrates that
almost half (44 percent) of all reported injuries within the
healthcare industry (NAICS 622 and 623) were attributed to
overexertion-related incidents. In comparison, that rate equates to
almost one and a half times the total MSD rate (33 percent) for all
reported injuries for all industries. [13, BLS] [14, BLS]. Nurses
and nursing assistants each accounted for a substantial share of
this total. In 2013, orderlies, nursing assistants, and personal
care aides continued to have some of the highest MSD rates of all
occupations. MSD cases accounted for 53 percent of total reported
cases that occurred to nursing assistants in 2013. Additional BLS
data for CY 2013 provided further evidence of the prevalence of MSD
rates for private industry nursing assistants (202.4), which were
almost six times higher than the average MSD rates reported for all
private industry workers (33.5). [15, BLS]
Workplace Violence (WPV). NIOSH defines WPV as violent acts
(including physical assaults and threats of assaults) directed
toward persons at work or on duty. [20, NIOSH]. WPV is a recognized
hazard in hospitals and nursing and residential care facilities.
Violence accounted for 4 percent of the cases in the private sector
in 2013, with a rate of 4.2 cases per 10,000 full-time workers. In
the health care and social assistance sector, 13 percent of the
injuries and illnesses were the result of violence, and the rate
increased for the second year in a row to 16.2 cases per 10,000
full-time workers, up from 15.1 in 2012. Fifteen percent of the
days-away-from-work cases for nursing assistants were the result of
violence. Less than 10 percent of the overall private sector
days-away-from-work cases were the result of violence. [10, OSHA].
In 2013, BLS data reported that days-away-from-work cases were
caused by approximately 14,440 assaults by persons in hospitals and
nursing and residential care facilities. Hospitals reported
approximately 5,660 assaults and nursing and residential care
facilities reported approximately 8,780 assaults. [14, BLS]. OSHA
Instruction {CPL 02-01-058}, Enforcement Procedures for
Investigating or Inspecting Workplace Violence Incidents,
provides inspection guidance for unprogrammed and programmed
inspections at worksites that are in industries with high
incidences of workplace violence, such as healthcare facilities.
Other sectors in the healthcare industry have WPV concerns as well.
For general information on WPV in healthcare and social services,
see OSHA's Guidelines for Preventing Workplace Violence for
Healthcare and Social Service Workers, located at: www.osha.gov/Publications/osha3148.pdf.
Bloodborne Pathogens (BBP) and Tuberculosis (TB). OSHA
enforcement data from the OIS indicate that one of the most
frequently cited standards in nursing and residential care
facilities is 29 CFR 1910.1030, the Bloodborne Pathogens Standard.
Additionally, employees working in nursing and residential care
facilities have been identified by the CDC as being among the
occupational groups with the highest risk for exposure to TB due to
the case rate of disease among persons ³ 65 years of age. In CY 2013, for
example, the CDC reported an overall TB case rate of 3.0 per
100,000 persons across all age groups. The corresponding case rate
for persons ³ 65
years of age was 4.9 per 100,000 in CY 2013. [17, CDC].
Slips, Trips, and Falls (STFs). Injuries from STFs were also
among the nonfatal occupational injury and illness cases reported
in nursing and residential care facilities. Taken together,
overexertion together with slips, trips, and falls accounted for
68.6% of all reported cases with days away from work within NAICS
622 and 623 for CY 2013 [14, BLS].
Other Hazards. Hazards other than those selected for focus in
this initiative are likely to exist in inpatient healthcare
settings. For example, a commonly recognized hazard in these
settings is exposure to multi-drug resistant organisms (MDROs),
such as methicillin-resistant Staphylococcus aureus
(MRSA). The CDC has identified healthcare settings, such as
hospitals and nursing care facilities, among those at increased
risk for colonization with MRSA, and recommends that employers
institute standard precautions and contact precautions to protect
workers who must provide care and services to residents or patients
colonized with MRSA or other MDROs.
Employee exposures to hazardous chemicals, such as sanitizers,
disinfectants, anesthetic gases, and hazardous drugs (e.g. ,
antineoplastic drugs), are also among the other hazards that are
commonly encountered in inpatient healthcare facilities. A recent
article in the American Journal of Infection Control notes that, in
addition to environmental service workers, many other healthcare
workers routinely use cleaning and disinfecting products. These
chemicals are both irritants and sensitizers, causing a variety of
adverse health effects, including eye irritation, irritant and
allergic contact dermatitis, upper and lower respiratory symptoms,
work-related asthma and chronic bronchitis. Note: Some cleaning and
disinfecting chemicals are known to be mutagens, carcinogens and
reproductive toxins. The article reviews knowledge gaps and
research priorities and calls for a more integrated approach to
both occupational illness prevention and infection control. [Quinn
21].
Attachment 2
Inspection Procedures for Focus Hazards and Other Hazards in
Inpatient Healthcare Settings
- Ergonomics: MSD Risk Factors Relating to Patient/Resident
Handling.
This section provides guidance for conducting inspections
in workplaces in NAICS Codes 622 and 623 as they relate to risk
factors for musculoskeletal disorders (MSDs) associated with
patient/resident handling. These inspections shall be conducted in
accordance with the FOM, and other relevant OSHA reference
documents.- Establishment Evaluation. Inspections of MSD risk factors will
begin with an initial determination of the extent of
patient/resident handling hazards and the manner in which they are
or are not addressed. This will be accomplished by an assessment of
establishment incidence and severity rates and whether the
establishment has implemented a process to address these hazards in
an effective manner.
CSHOs should ask for the maximum census of patients/residents
permitted and the current census during the inspection.
Additionally, CSHOs should inquire about the degree of ambulation
of the patients/residents, as this information may provide some
indication of the level of assistance given to patients/residents
or the degree of hazards that may be present.
Note: If there is indication from injury records, or from
employer or employee interviews that other sources of
ergonomics-related injuries exist (e.g. , MSDs related to office
work, laundry, kitchen, or maintenance duties), the compliance
officer must include the identified work area and affected
employees in the assessment. - Program Evaluation. Compliance officers should evaluate program
elements, such as the following:
- Program Management.
- Is there a system for hazard identification and analysis?
- Is there a system for development of strategies to address
identified hazards?
- Who has the responsibility and authority for administering this
system?
- What are the credentials or experience of the individual
responsible for administering the program?
- What input have employees provided in the development of the
establishment's lifting, transferring, or repositioning
procedures?
- Is there a system for monitoring compliance with the
establishment's policies and procedures and following up on
deficiencies?
- Are there records of recent changes in policies/procedures and
an evaluation of the effect they have had (positive or negative) on
resident handling injuries and illnesses?
- Program Implementation.
- How is patient/resident mobility determined and how is the
mobility determination communicated to staff?
- What is the decision logic for selection and use of lift,
transfer, or repositioning devices?
- When and under what circumstances may manual lift, transfer, or
repositioning occur?
- Who decides how to lift, transfer, or reposition
patients/residents?
- Is there is an adequate quantity and variety of appropriate
lift, transfer, or reposition assistive devices available and
operational? Note that no single lift assist device is appropriate
in all circumstances. Manual pump or crank devices may create
additional hazards.
- Are there adequate numbers of supplies such as: slings,
batteries, and charging stations for lifting devices? (Note: There
should be a minimum of 1 sling per resident that needs the device
and some extras to account for laundering and repair. There should
be adequate numbers of batteries to accomplish all necessary lifts
during a shift). There should be appropriate types and sizes of
slings specific for all patients/residents.
- Are there appropriate quantities and types of the assistive
devices (such as, but not limited to slip sheets, mechanical lifts,
sit-to-stand assists, walk assists, or air-hover transfer pads)
available within close proximity and maintained in a usable and
sanitary condition?
- Are their policies and procedures appropriate to eliminate or
reduce exposure to the manual lifting, transferring, or
repositioning hazards at the establishment?
- Employee Training.
- Have employees (nursing and therapy) been trained in the
recognition of ergonomic hazards associated with manual
patient/resident lifting, transferring, or repositioning, the early
reporting of injuries, and the establishment's process for abating
those hazards?
- Have the employees (nursing and therapy) been trained in proper
techniques and procedures to avoid exposure to ergonomic risk
factors and can they demonstrate competency in performing the lift,
transfer, or repositioning task using the assistive device?
- Occupational Health Management.
Is there a recognized process to ensure that work-related
disorders are identified and treated early to prevent the
development of more serious problems and whether this process
includes restricted or accommodated work assignments?
After evaluating the facility's incidence and severity rates and
the extent of the employer's program, a decision will be made about
the need to continue the ergonomic portion of the inspection. Where
there is a need to address these issues, the AO will follow OSHA
reference documents in determining whether to send an Ergonomic
Hazard Alert Letter (EHAL), other communication, or issue
citations. In all cases, the AO will notify the Regional Ergonomic
Coordinator (REC) of the result of the inspection.
OSHA will contact all employers who receive an ergonomic hazard
alert letter to determine whether the deficiencies identified in
the letter have been addressed. Please refer to CPL 02-00-144, Ergonomic Hazard Alert Letter
Follow-up Policy, for the process for contacting employers who
received an ergonomic hazard alert letter. During this contact,
OSHA may again provide information on available consultation and
compliance assistance. In appropriate cases, OSHA will consider
conducting another compliance inspection.
Some states (e.g. , California, Alaska, Minnesota, Washington,
and Oregon) have existing regulations or codes that can be applied
to ergonomics-related injuries. In these cases, State or local
regulations may support the 5(a)(1) element of industry
recognition. - Citation Guidance.
Refer to the FOM and other OSHA reference
documents prior to proceeding with citation issuance. When
conditions indicate that a General Duty Clause citation relating to
patient/resident handling may be warranted, the Area Office will
contact the REC and collaborate with the Regional Solicitor (RSOL)
on the case prior to issuing a citation. Attachment 3 is provided
only as an example of the language that may be used in an Alleged
Violation Description (AVD) for patient/resident handling-related
incidents.
- Workplace Violence.
OSHA Instruction {CPL 02-01-058}, Enforcement Procedures for
Investigating or Inspecting Workplace Violence Incidents,
establishes agency enforcement policies and provides uniform
procedures which apply when conducting inspections in response to
incidents of workplace violence. This Instruction directs CSHOs,
who conduct programmed inspections at worksites that are in
industries with high incidence of workplace violence, such as
health and residential care facilities, to investigate for the
potential or existence of this hazard.
- Tuberculosis (TB).
For further detailed guidance, CSHOs should
refer to OSHA Instruction CPL 02-02-078, Enforcement Procedures and
Scheduling for Occupational Exposure to Tuberculosis.
NOTE: CSHOs shall note the employer's compliance with
current CDC Guidelines: Centers for Disease Control and Prevention (CDC), Guidelines for Preventing the Transmission of Mycobacterium tuberculosis in Health-Care Settings, 2005, MMWR December 30, 2005/ Vol. 54/ No. RR-17. - Bloodborne Pathogens.
CSHOs should refer to OSHA Instruction CPL 02-02-069, Enforcement Procedures for
Occupational Exposure to Bloodborne Pathogens. - Slip, Trips, and Falls.
If employees are exposed to hazards from
falling while performing various tasks including maintenance from
elevated surfaces, then OSHA Instruction STD 01-01-013, Fall Protection in General
Industry, should be reviewed to determine the applicability of
29 CFR 1910.23(c)(1), 1910.23(c)(3) and 1910.132(a). - Other Hazards.
As detailed in the FOM, {CPL 02-00-160}, when additional hazards come to
the attention of the compliance officer, the scope of the
inspection may be expanded to include those hazards. Although they
are not included in the focus hazards for inspections conducted in
inpatient healthcare settings in NAICS Codes 622 and 623,
unprotected occupational exposures to multi-drug resistant
organisms, or exposure to hazardous chemicals (i.e. , hazard
communication) should be investigated if these or other hazards
come to the attention of the compliance officer during the course
of an inspection.- Methicillin-resistant Staphylococcus aureus (MRSA) and
other multi-drug resistant organisms (MDROs).
Compliance officers are expected to investigate situations where
it is determined during inspections conducted in such workplaces
that employees are not protected from potential transmission of
MDROs, such as MRSA.
Refer to the FOM and other OSHA reference documents prior to
proceeding with citation issuance. Recommendations for standard
precautions and contact precautions to reduce or eliminate exposure
to MRSA and other MDROs are outlined in CDC guidelines, including
the 2007 Guideline for Isolation Precautions: Preventing
Transmission of Infectious Agents in Healthcare Settings. [18,
CDC] Attachment 3 contains information that is provided only as an
example of language that may be used in an Alleged Violation
Description (AVD) for unprotected occupational exposure to MRSA
specific to nursing and residential care facilities.
NOTE: Violations of applicable OSHA standards (e.g. ,
PPE standards) must be documented in accordance with the FOM. In
General Duty Clause citations the recognized hazard must be
described in terms of the danger to which employees are exposed,
e.g., the danger of being infected by MRSA, not the lack of a
particular abatement method. Feasible abatement methods that are
available and likely to correct the hazard must be identified. - Hazard Communication.
Employee exposures to hazardous chemicals, such as sanitizers,
disinfectants, and hazardous drugs may be encountered in inpatient
healthcare settings in NAICS Codes 622 and 623. Employers are
required to implement a written program that meets the requirements
of the Hazard Communication standard (HCS) to provide worker
training, warning labels and access to Safety Data Sheets or SDSs
(which replaced Material safety data sheets (MSDSs) under the HCS
revised in 2012).
NOTE: Inspection and citation guidance are contained in OSHA
Instruction, CPL 02-02-079, Inspection Procedures for the
Hazard Communication Standard (HCS 2012).
Attachment 3
Sample AVDs
- Sample 5(a)(1) AVD for Patient/Resident Handling Hazards:
NOTE: Refer to the FOM and other OSHA reference documents
prior to proceeding with citation issuance. The following is
provided ONLY as an example of the language that may be used in an
Alleged Violation Description (AVD) for resident handling-related
incidents.
The General Duty Clause.Section 5(a)(1) of the Occupational Safety and Health Act of
1970: The employer did not furnish employment and a place of
employment which were free from recognized hazards that were
causing or likely to cause serious physical harm to employees, in
that employees were required to perform lifting tasks resulting in
stressors that have caused or were likely to cause musculoskeletal
disorders (MSDs):
a). Location - Address:
On or about Date employees were exposed to ___________
hazards which were causing or likely to cause ___________ .
Employees were required to transfer non-weight bearing and partial
weight bearing residents manually by lifting or partially lifting
them, exposing employees to lifting-related hazards resulting in
injuries and disorders such as lumbar or back strain/sprain/pain,
herniated/ruptured disk, injury to the L5/S1 disc, and various
shoulder injuries.
Abatement.
Feasible means of abatement include but are not limited to
implementing a safe patient handling and movement policy for
transferring and lifting of non-weight bearing and partial weight
bearing residents. This necessitates the use of mechanical lift
assist and transfer devices. Note: AVD must be adapted to the
specific circumstances noted in each inspection. The AVD above is
an example that will be appropriate in some circumstances. - Sample 5(a)(1) AVD for MRSA Exposure:
NOTE: Refer to the FOM and other OSHA reference documents
prior to proceeding with citation issuance. The following is
provided ONLY as an example of the language that may be used in an
Alleged Violation Description (AVD) for unprotected MRSA
exposure.
General duty clause, Section 5(a)(1) - refer to the CDC
guidelines: Guidelines for Isolation Precautions: Preventing
Transmission of Infectious Agents in Healthcare Settings,
2007, which recommends standard precautions and contact
precautions to reduce or eliminate exposure to MRSA. Abatement
would include handwashing, cohorting of patients/residents, device
and laundry handling.
The General Duty Clause.
Section 5(a)(1) of the Occupational Safety and Health Act of
1970: The employer did not furnish employment and a place of
employment which were free from recognized hazards that were
causing or likely to cause death or serious physical harm to
employees in that employees were exposed to communicable
diseases:
a). Location - Address:
On or about Date employees were exposed to drug-resistant
infections while providing care to residents with infections such
as, but not limited to, Methicillin-Resistant Staphylococcus
aureus (MRSA).
Abatement.
Feasible means of abatement include, but are not limited to: a)
providing training on all routes of transmission of infections, the
proper personal protective equipment to be used, and infection
control practices to be utilized; b) notifying employees about
status of any resident with infection prior to beginning care
assignments for every shift; c) cohorting patients/residents; and
d) using administrative controls, such as limiting access to
patients/residents with MRSA infections by non-essential
personnel.
Attachment 4
References
- OSHA's Healthcare Safety and Health Topics webpage: http://www.osha.gov/SLTC/healthcarefacilities/index.html.
- OSHA Worker Safety in Hospitals webpage: http://www.osha.gov/dsg/hospitals/index.html.
- OSHA Nursing Homes and Personal Care Facilities Safety and
Health Topics webpage: http://www.osha.gov/SLTC/nursinghome/index.html.
- OSHA Nursing Home eTool: http://www.osha.gov/SLTC/etools/nursinghome/index.html.
- OSHA Hospital eTool: http://www.osha.gov/SLTC/etools/hospital/index.html.
- OSHA Instruction CPL 03-00-016, National Emphasis Program -
Nursing and Residential Care Facilities, (NAICS 623110, 623210,
623311), April 5, 2012.
- OSHA Instruction {CPL 02-01-058}, Enforcement Procedures for
Investigating Workplace Violence Incidents, September 8,
2011.
- OSHA Instruction CPL 02-02-069, Enforcement Procedures for
the Occupational Exposure to Bloodborne Pathogens, November
27, 2001.
- OSHA Instruction CPL 02-00-144, Ergonomic Hazard Alert Letter
Follow-up Policy, April 11, 2007.
- OSHA Publication OSHA 3148-04R 2015, Guidelines for
Preventing Workplace Violence for Healthcare and Social Service
Workers, 2015
- 79 Federal Register 56129-56188,
Occupational Injury and Illness Recording and Reporting
Requirements--NAICS Update and Reporting Revisions; Final
Rule, September 18, 2014.
- Bureau of Labor Statistics (BLS), Table 1 and Table 2.
Incidence rates of and Numbers of nonfatal occupations injuries
and illnesses by industry and case types, 2013, www.bls.gov/iif/oshwc/osh/os/ostb3958.pdf; and
www.bls.gov/iif/oshwc/osh/os/ostb3960.pdf.
- BLS, Table 1. Number, median days away from work, and
incidence rate for nonfatal occupational injuries and illnesses
involving days away from work by ownership, industry,
musculoskeletal disorders, and event or exposure, 2013, www.bls.gov/news.release/osh2.t01.htm.
- BLS, Table R4. Number of nonfatal occupational injuries and
illnesses involving days away from work by industry and selected
events or exposures leading to injury or illness, private industry,
2013, www.bls.gov/iif/oshwc/osh/case/ostb3985.pdf.
- BLS, Table 18. Number, incidence rate, and median days away
from work for nonfatal occupational injuries and illnesses
involving days away from work and musculoskeletal disorders by
selected worker occupation and ownership, 2013, http://www.bls.gov/news.release/osh2.t18.htm.
- Centers for Disease Control and Prevention, Occupational
Traumatic Injuries Among Workers in Health Care Facilities - United
States, 2012-2014, MMWR Vol.64/No.15, April 24, 2015, pp.
405-410, www.cdc.gov/mmwr/pdf/wk/mm6415.pdf.
- Centers for Disease Control and Prevention, Reported
Tuberculosis in the United States, 2013. Atlanta, GA:
U.S. Department of Health and Human Services, CDC, October, 2014,
www.cdc.gov/tb/statistics/reports/2013/pdf/report2013.pdf.
- Centers for Disease Control and Prevention, 2007 Guideline
for Isolation Precautions: Preventing Transmission of Infectious
Agents in Healthcare Settings,www.cdc.gov/hicpac/pdf/isolation/Isolation2007.pdf
.
- Centers for Disease Control and Prevention, Slip, Trip, and
Fall Prevention for Health Care Workers, DHHS (NIOSH)
Publication Number 2011-123, http://www.cdc.gov/niosh/docs/2011-123/pdfs/2011-123.pdf.
- NIOSH 2002, Department of Health and Human Services, Centers
for Disease Control and Prevention, National Institute for
Occupational Safety and Health. Violence: Occupational Hazards
in Hospitals, DHHS (NIOSH) Publication No. 2002-101, (2002).
http://www.cdc.gov/niosh/docs/2002-101/. June
17, 2015.
- Quinn MM, Henneberger PK et al. Cleaning and disinfecting
environmental surfaces in health care: Toward an integrated
framework for infection and occupational illness prevention.
American Journal of Infection Control, 2015; 43:424-434. http://www.sciencedirect.com/science/article/pii/S0196655315000759.
