Did you know OSHA issued a memorandum to its regions on June 25, 2015, providing further inspection guidance for inpatient healthcare settings? Are you prepared? This applies to North American Industry Classification System (NAICS) Major Groups 622 (hospitals) and 623 (nursing and residential care facilities).

OSHA is indicating that regardless of how they may come to inspect a hospital or nursing home they will focus on hazards included in the recently-concluded National Emphasis Program - Nursing and Residential Care Facilities, CPL 03-00-016 (NH-NEP). This can include a scheduled inspection, an employee complaint about another issue, a report of a serious injury, a referral by another agency, or other resources. Those hazards include:

• Musculoskeletal disorders (MSDs) relating to patient or resident handling. 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.
• Workplace violence (WPV), these industries have four times the rate of incidents compared to other industries. MEMIC policyholders can click here to register for a free webinar entitled “Workplace Violence in Acute Care Settings” at 10:00 a.m. on October 15, 2015.
• Bloodborne pathogens (BBP), one of the most frequently cited standards in nursing and residential care facilities is 29 CFR 1910.1030, the Bloodborne Pathogens Standard.
• Tuberculosis (TB), 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 65 years of age.
• Slips, trips and falls (STFs). Overexertion together with slips, trips, and falls accounted for 68.6% of all reported cases with days away for CY 2013 in this industry.

In addition to the focus hazards listed above, 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 Staphylococcus aureus (MRSA).
• Exposures to hazardous chemicals, such as sanitizers, disinfectants, anesthetic gases, and hazardous drugs.

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. Additional information regarding inspections can be found on the OSHA website.

The goal of this policy is to significantly reduce overexposures to these hazards through a combination of enforcement, compliance assistance, and outreach.

Posted ByRob Sylvester, MBA, CSP, CSPHA, CEHT, WCP®