PRESENTED BY APRIL 18, The University of Texas MD Anderson Cancer Center Houston, Texas

Transcription

1 PRESENTED BY APRIL 18, 2018 The University of Texas MD Anderson Cancer Center Houston, Texas

2 Jim Shelton, CAS Houston North Area Office

3 OSHA and Healthcare Healthcare encompasses several NAICS codes and today we re looking at: 622 Hospitals A rough count shows about 461 inspections in NAICS 622 in FY % were complaints and 16% were referrals, which make up about 75% of the OSHA activity Estimated FY 17 OSHA Inspections Complaints Referral Planned Other 3

4 Healthcare vs Other Industries Total Case Incident Rate Comparison (TCIR) NAICS 622 Hospitals NAICS 23 Construction NAICS Manufacturing

5 Healthcare vs Other Industries Days Away, Restricted, Transferred (DART) NAICS 622 Hospitals NAICS 23 Construction NAICS Manufacturing 5

6 Top 10 Violations Healthcare Facilities Federal OSHA FY 15 FY 17 Bloodborne Pathogens ( ) Hazard Communication ( ) Personal Protective Equipment General Requirements ( ) Electrical General Requirements ( ) Electrical Wiring Methods ( ) Respiratory Protection ( ) Exit Routes: Maintenance, Safeguards, and Operational Features ( ) Reporting fatalities, hospitalizations, amputations, and losses of an eye to OSHA ( ) Lockout/Tagout ( ) Medical Services and First Aid ( ) 6

7 1) Bloodborne Pathogens (c)(1)(i) (107 violations) Exposure control plan (g)(2)(i) (82 violations) Training employees with occupational exposure (c)(1)(iv) (75 violations) Review and update of exposure control plan (d)(2)(i) (64 violations) Engineering and work practice controls (f)(1)(i) (57 violations) Hepatitis B vaccination and post exposure evaluation 7

8 2) Hazard Communication (e)(1) (122 violations) Written hazard communication program (h)(1) (109 violations) Employee information and training (g)(8) (38 violations) Maintaining copies of Safety Data Sheets in the workplace and ensuring they are readily available (h)(3)(iv) (35 violations) Training on details of employer s hazard communication program (g)(1) (25 violations) Having Safety Data Sheets in the workplace for each hazardous chemical 8

9 3) Personal Protective Equipment (d)(1) (37 violations) Hazard assessment (a) (32 violations) When PPE must be provided (d)(2) (27 violations) Written certification of hazard assessment (d)(1)(i) (8 violations) Selection and use of PPE to protect against hazards identified in hazard assessment (f)(1) (8 violations) Training of employees required to use PPE 9

10 4) Electrical: General Requirements (b)(2) (38 violations) Installing and using listed or labeled equipment in accordance with instructions included in the listing or labeling (g)(1) (20 violations) Sufficient access and working space about electrical equipment (600 volts, nominal, or less to ground) (g)(2)(i) (11 violations) Guarding live parts (600 volts, nominal, or less to ground) (g)(1)(ii) (9 violations) No use of working space for storage, and guarding working space (f)(2) (8 violations) Marking service, feeder, and branch circuits at their disconnecting means or overcurrent device 10

11 5) Electrical Wiring Methods (g)(1)(iv)(A) (21 violations) Not using flexible cords and cables as a substitute for the fixed wiring of a structure (b)(1)(ii) (15 violations) Closing unused openings in cabinets, boxes, and fittings (g)(2)(iii) (12 violations) Connecting flexible cords and cables to devices and fittings so that strain relief is provided that will prevent pull from being directly transmitted to joints or terminal screws (b)(2)(i) (11 violations) Providing pull boxes, junction boxes, and fittings with covers identified for the purpose (g)(1)(iv)(B) (7 violations) Not using flexible cords and cables where run through holes in walls, ceilings, or floors 11

12 6) Respiratory Protection (c)(1) (11 violations) Written respiratory protection program (f)(2) (11 violations) Fit testing for employees using a tight fitting facepiece respirator: testing frequency (e)(1) (8 violations) Medical evaluation to determine employee s ability to use a respirator (d)(1)(iii) (7 violations) Respirator selection: evaluation of respiratory hazards in workplace (c)(2)(i) (6 violations) Providing respirators at request of employees or permitting employees to use their own respirators 12

13 7) Exit Routes: Maintenance, Safeguards, and Operational Features (b)(2) (28 violations) Exits must be visible and marked with EXIT sign (a)(3) (18 violations) Exit routes must be free and unobstructed (b)(4) (10 violations) Direction of travel to the exit or exit discharge (b)(5) (7 violations) Marking of doorways or passages along an exit access that could be mistaken for an exit (b)(6) (7 violations) Illumination of exit signs 13

14 8) Reporting Incidents OSHA (a)(2) (65 violations) Reporting to OSHA within 24 hours of hospitalization, amputation, or loss of eye (a) (5 violations) Basic reporting requirement (a)(1) (2 violations) Reporting to OSHA within 8 hours of work related death (a)(3) (2 violations) Methods for reporting (b)(7) (2 violations) Procedure if don t learn of reportable incident right away 14

15 9) Lockout/Tagout (c)(4)(i) (17 violations) Developing, documenting, and utilizing energy control procedures (c)(6)(i) (17 violations) Periodic inspection of energy control procedure at least annually (c)(7)(i) (8 violations) Training on the energy control program (c)(4)(ii) (4 violations) Elements of energy control procedure (d) (2 violations) Elements of lockout/tagout procedures 15

16 10) Medical Services and First Aid (c) (62 violations) Eye and body wash facilities 16

17 Houston NAICS 622 Hospitals There has been three fatalities reported in hospitals since FY 2009: An employee tripped over a linen laundry bag and fell fracturing his arm; during surgical repair he developed an infection and after a second surgery to treat the infection he died of complications Worker became trapped by a sliding glass door that separates the therapy area and the operating booth where employees operate radiation equipment Employee fell off golf cart while being transported to another building 17

18 Houston Serious Incident Reports (SIRs) In 2016 hospitals nationally had the sixth highest number of reported SIRs In FY in the Houston area there were 17 reported in NAICS 622 NAICS 622 FY 2016 (11) FY 2017 (6) 18

19 Houston Serious Incident Reports (SIRs) Eight of the nine falls were on the same level 19

20 Reporting 1904 Regulation Occupational Injury and Illness Recording and Reporting Requirements NAICS Update and Reporting Revisions Two parts: Requires the reporting of any in patient hospitalization and any amputation Updates the list of industries partially exempt from the requirement to keep work related injury and illness records due to lower rates Effective January 1,

21 Reporting 1904 Regulation How does OSHA define in patient hospitalization? OSHA defines in patient hospitalization as a formal admission to the in patient service of a hospital or clinic for care or treatment 21

22 Reporting 1904 Regulation How does OSHA define amputation? An amputation is the traumatic loss of a limb or other external body part Amputations include a part, such as a limb or appendage, that has been severed, cut off, amputated (either completely or partially); fingertip amputations with or without bone loss; medical amputations resulting from irreparable damage; amputations of body parts that have since been reattached Amputations do not include avulsions (tissue torn away from the body), enucleations (removal of the eyeball), deglovings (skin torn away from the underlying tissue), scalpings (removal of the scalp), severed ears, or broken or chipped teeth 22

23 ereporting Establishments in designated high hazard industries with workers during the submittal year are required to electronically submit their OSHA 300A Summary of Work Related Injuries and Illnesses to OSHA electronically each year NAICS Description 6219 Other ambulatory health care services 6221 General medical and surgical hospitals 6222 Psychiatric and substance abuse hospitals 6223 Specialty (except psychiatric & substance abuse) hospitals 6231 Nursing care facilities 6232 Residential mental retardation, mental health and substance abuse facilities 6233 Community care facilities for the elderly 6239 Other residential care facilities 6242 Community food and housing, and emergency and other relief services 6243 Vocational rehabilitation services NAICS 62 Designated High Hazard Industries 23

24 ereporting The electronic reporting requirements are based on the size of the establishment, not the firm. The OSHA injury and illness records are maintained at the establishment level. An establishment is defined as a single physical location where business is conducted or where services or industrial operations are performed. A firm may be comprised of one or more establishments. 24

25 ereporting Establishments with 250+ workers during the submittal year (large establishments) are also required to submit their OSHA 300A to OSHA electronically each year* Submittal deadline is July 1, 2018 this year 25

26 ereporting Failure to submit records Failed to submit but immediately abates during inspection by providing paper copy of records to CSHO O.T.S. with no penalty Failed to submit 2016 data but has already submitted the 2017 data O.T.S. with no penalty Records aren t produced O.T.S. with penalty 26

27 Recordkeeping and Reporting Recording Death Days away from work Restricted work activity Transfer to another job Medical treatment beyond first aid Loss of consciousness Significant injury or illness diagnosed by a PLHCP Reporting Fatalities Hospitalizations Amputations Loss of an eye ereporting (select industries) 27

28 Healthcare as an Emphasis Area Programmed and unprogrammed inspections in NAICS 622 (hospitals) and 623 (nursing and residential care facilities) will cover focus hazards: Musculoskeletal disorders (MSDs) relating to patient or resident handling Workplace violence (WPV) Bloodborne pathogens (BBP) Tuberculosis (TB) Slips, trips, and falls (STFs) 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 28

29 Workplace Violence OSHA RFI in regards to prevention of workplace violence in the healthcare industry CPL Enforcement Procedures and Scheduling for Occupational Exposure to Workplace Violence Covers responding to a complaint, referral, or a fatality or catastrophic event and conducting a programmed inspection where a reasonably foreseeable workplace violence hazard has been identified An inspection shall be considered particularly when it stems from a workplace in an industry identified by OSHA as having a potential for workplace violence pdf 29

30 Safety and Health Program Management Proactive approach: traditional approaches are often reactive The SHPM guidelines recognize that finding and fixing hazards before they cause injury or illness is far more effective 30

31 Safety and Health Program Management Recommended Practices for Safety and Health Programs OSHA Leading a Culture of Safety: A Blueprint for Success American College of Healthcare Executives 31

32 Safe + Sound Week What is Safe + Sound Week? A nationwide event to raise awareness and understanding of the value of safety and health programs in workplaces When is it? August 13 th 19 th 2018 Who is encouraged to participate? Organizations of any size or in any industry that want to show their commitment to safety 32

33 Questions? Houston North Area Office Joann Figueroa, Area Director Jim Shelton, CAS 690 S. Loop 336 W., Suite 400 Conroe, TX Keep up to date with the Houston North Area Office list; contact Jim Shelton at the above 33

34 Disclaimer Serious Incident Reports (SIRs) and fatality cases and incidents are an estimate and should not be considered a exact count or a statistical study or referenced in that way Incidents are generally categorized by event and focus four factors in broad categories and may include related activities This information has been developed by an OSHA Compliance Assistance Specialist and is intended to assist employers, workers, and others as they strive to improve workplace health and safety. While we attempt to thoroughly address specific topics [or hazards], it is not possible to include discussion of everything necessary to ensure a healthy and safe working environment in a presentation of this nature. Thus, this information must be understood as a tool for addressing workplace hazards, rather than an exhaustive statement of an employer s legal obligations, which are defined by statute, regulations, and standards. Likewise, to the extent that this information references practices or procedures that may enhance health or safety, but which are not required by a statute, regulation, or standard, it cannot, and does not, create additional legal obligations. Finally, over time, OSHA may modify rules and interpretations in light of new technology, information, or circumstances; to keep apprised of such developments, or to review information on a wide range of occupational safety and health topics, you can visit OSHA s website at 34