Our Insights

Part 1: Traditional Hazards
by Bryan Connors, M.S., C.I.H., H.E.M.

This article is the first of a two-part series discussing current strategies for ensuring Occupational Safety and Health Administration (OSHA) compliance in the healthcare environment. This first article focuses on traditional hazards including electrical safety, lockout/tagout, and asbestos.

Ensuring OSHA compliance in a hospital setting is complex and can be a daunting task.  This is largely due to the wide range of activities and work environment settings within hospitals.  But there are other reasons including the constant need to do more with less,  prescriptive  training and recordkeeping requirements, and difficulty in integrating compliance into routine work.  In addition to ensuring employee and patient safety and well-being, maintaining OSHA compliance is also vital to lowering worker’s compensation costs and reducing risks to hospital brand.

When Might You See OSHA in Your Hospital?

An OSHA inspector may pay your hospital a visit for several reasons.  The most common reason today is a Programmed (i.e., Planned) Inspection, which accounts for over 60% of all inspections. Typical triggers of a Programmed Inspection are high injury and illness statistics (either for the whole sector or by employer within a sector), a specific event, or when a specific hazard is targeted.  OSHA may also inspect your hospital in response to a complaint (usually filed by an employee) or more commonly as part of a construction contractor investigation.  You can minimize the risk of an OSHA inspection by paying careful attention to the requirements for recordable injuries and illness. First, ensure you’re not over-reporting (or under-reporting) by including non-reportable incidents in your logs, and then compare your report to industry norms.  If your averages are higher than the national average, then you should proactively investigate and put in place a plan for improvement. Though ergonomic injuries can be a major contributor to recordable injuries and illnesses, there are several other important classes of injuries that you must determine through careful analysis of your injury and illness logs to improve your rates. A careful analysis of your injury and illness rates and characteristics often yields several trends that can be followed up on.

OSHA has begun a more targeted and aggressive enforcement according to an April 22, 2010, OSHA press release, “For many employers, investing in job safety only happens when they have adequate incentives to comply with OSHA requirements. Higher penalties and more aggressive, targeted enforcement will provide a greater deterrent…” It’s important for your hospital to understand where your OSHA vulnerabilities lie to assure you address those vulnerabilities. While  bloodborne pathogens heads the list of cited OSHA standards, many hospitals seem to struggle with so-called “traditional hazards” which apply to engineering and maintenance departments as well as support services and construction and are common top OSHA violations for fiscal year 2009. The table below illustrates the top OSHA citations by number of citations.

Traditional Hazards in a Healthcare Setting

The traditional hazards listed by OSHA and common to most hospitals are listed below along with a brief description of how they apply.

Electrical Safety & Lockout/Tagout – These are the second and third most common citation categories in hospitals.  They are considered a high priority for OSHA inspectors due to the seriousness of injury and fatalities.  Compliance requires labeling, training, written lockout/tagout plans and procedures, and likely use of insulated tools and personal protection equipment (PPE).

Fall Protection – This category applies to roof work (including servicing roof top equipment such as security cameras, light, and heating, ventilating and air-conditioning [HVAC] equipment) and window washing.  Compliance requires a fall risk assessment; training; hazard control systems that are properly designed, specified, and installed; and may require personal fall arrest systems.

Confined Space – Confined spaces are defined as those that: 1) are large enough and configured that an employee can bodily enter and perform assigned work, 2) have limited or restricted means for entry or exit (for example, tanks vessels, storage bins, vaults, and pits) or 3) are not designed for continuous employee occupancy.  Compliance requires an inventory, signage, training, written entry and rescue procedures, and atmospheric testing in some cases.  Your hospital is responsible for contractor and vendor entry as well.

Asbestos – Employee exposure to asbestos containing material (ACM) during construction and renovation projects typically constitutes the high fines from OSHA.  Asbestos compliance involves an inventory of ACM in the hospital, a written asbestos management plan, a hazard/exposure assessment, labeling, employee training, and may require medical surveillance.

Machine Guarding – Mechanical rooms and maintenance shops are rife with moving parts on carpentry and maintenance equipment, elevator pulleys, HVAC equipment, pumps, and pneumatic equipment. Other departments such as food services, environmental services, and radiology often have guarding issues as well.

There are many other OSHA compliance concerns for hospitals including bloodborne pathogens, hazard communication, personal protective equipment and respiratory protection which will be discussed in part 2 of this OSHA compliance in hospital series.

Compliance Strategies

We recommend a hazard and risk assessment as the first step toward ensuring OSHA compliance for traditional hazards. Don’t assume that your Hazard Surveillance Rounds will spot these types of issues – dedicate a separate survey that involves hospital personnel actually performing work during both typical and high hazard tasks.  Based on our experience conducting OSHA compliance gap analyses for hospitals, we recommend the following to ensure OSHA compliance:

• Review your training programs carefully.  They should be of high quality and contain input from staff on site-specific conditions and hazards.  Ensure training records are complete and current, as this is the first thing an OSHA inspector will review.
• Many standards have very prescriptive requirements for written policies. Ensure the necessary policies in your hospital are in place and current.
• Ensure you have a system of defined responsibilities in place to maintain compliance.  Almost invariably, when programs do not have “program owners” there are lapses in safety and/or compliance.
• Don’t depend on occasional hazard assessments to point out deficiencies, but rather put this responsibility in the hands of several people who have operation responsibilities. Ask for regular reports from these people (with metrics if applicable).
• Assure you use topical experts when developing safety procedures.

OSHA compliance can often be a problem in hospitals because of the wide range of activities taking place (including those by outside contractors) across many departments.  A dedicated effort is often necessary to ensure continuous compliance, but the effort can help prevent a serious injury, reduce workers’ compensation costs, and reduce risk to brand name.  Fortunately, many of the review and improvement mechanisms already exist in hospitals to ensure Joint Commission compliance, and with a little additional effort and a trained eye they can be applied to ensuring OSHA compliance as well.

Achieving a safer workplace and OSHA compliance may seem like a formidable task, but if tackled methodically using the results of the hazard and risk assessment it is very doable. The high cost of employee injury and illnesses, non-compliance, and staff and patient well being is more than worth the effort to improve safety performance.

Bryan Connors, M.S., C.I.H., H.E.M., is a Senior Scientist / Healthcare Practice Leader at EH&E. He has extensive program management experience in environmental health and safety programs in the healthcare and biotechnology sectors, including nearly 10 years of direct program management responsibilities in several tertiary care hospitals. For more information, contact Bryan at bconnors@eheinc.com.