Showing posts with label OSHA Compliance. Show all posts
Showing posts with label OSHA Compliance. Show all posts

Wednesday, March 21, 2018

Representatives Seek OSHA Standard on Healthcare Workplace Violence

Lawmakers Seek OSHA Standard on Workplace Violence Prevention in Healthcare

Rep. Ro Khanna (D-CA) and 12 other House Democrats have introduced legislation intended to curb workplace violence in health care facilities.
 Healthcare Compliance Solutions. Inc.
The Health Care Workplace Violence Prevention Act, introduced March 8, would mandate that the federal Occupational Safety and Health Administration (OSHA) develop a national standard on workplace violence prevention that would require health care facilities to develop and implement facility and unit-specific workplace violence prevention plans.

According to the Bureau of Labor Statistics’ Census of Fatal Occupational Injuries, at least 58 hospital workers died as a result of workplace violence between 2011 and 2016. In 2016, the Government Accountability Office found that health care workers were five to 12 times more likely to encounter nonfatal workplace violence than all other workers.
The legislation follows regulation enacted in 2014 in California, which went into effect in 2017, directing Cal/OSHA to craft a workplace violence prevention standard. The law requires all covered health care employers in California to develop and issue – by April 1 – plans to prevent workplace violence and ensure the safety of patients and workers.
The bill introduced by Khanna is similar: Workplaces would create and implement comprehensive violence prevention plans with input from doctors, nurses and custodial workers. The bill stresses prevention, training and worker participation. It defines workplace violence broadly to include not only physical acts of violence, but threats of violence. It emphasizes staffing as a crucial ingredient in preventing violence from occurring and responding quickly when it does.
“Health care workers, doctors and nurses are continuously at risk of workplace violence incidents – strangling, punching, kicking and other physical attacks – that can cause severe injury or death,” Khanna said in a March 8 press release. “This is simply unacceptable. The Health Care Workplace Violence Prevention Act puts a comprehensive plan in place and is a national solution to this widespread problem modeled after the success seen in California.”  

See the Cal/OSHA regulation for details of the standard and what might be expected in the adoption of a National OSHA regulation.
National Nurses United (NNU), the nation’s largest union of registered nurses, applauded the bill.
“Right now, health care facilities are not doing enough to prevent these violent incidents,” NNU Co-President Deborah Burger said in a press release. “Under the proposed federal standard, facilities would need to assess and correct for environmental risk factors, patient specific risk factors, staffing and security system sufficiency.”
“There are a number of interventions that can reduce violence in healthcare. For example, affixing furniture and lighting so they can’t be used as weapons, maintaining clear lines of sight between workers while they are caring for patients, and providing easy access to panic buttons or phones to call for help,” Burger explained. “It is imperative that nurses, doctors, and other health care workers, along with security staff and custodial personnel, are all involved in the development and implementation of these plans.”
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Tuesday, August 2, 2016

OSHA's New Reporting Rule Impacts the Health Care Industry

New OSHA Injury Reporting Rules
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The U.S. Occupational Safety and Health Administration (OSHA) recently issued a final rule that becomes effective January 1, 2017 requiring healthcare industry employers to electronically submit to OSHA injury and illness data from their OSHA logs. This information will then become publicly available on the OSHA website.

As a corollary, and “to ensure the completeness and accuracy of injury and illness data,” the final rule also:
  • Creates an explicit requirement that employees must be informed of their right to report work-related injuries and illnesses free from retaliation;
  • Specifically requires that an employer's procedure for reporting work-related injuries and illnesses must be reasonable and not deter or discourage employees from reporting; and
  • Explicitly prohibits retaliation against employees for reporting work-related injuries or illnesses.
The requirement to report data applies to: (1) work locations with 250 or more employees, and (2) work locations with 20 to 249 employees in specific “high-risk industries” identified in the rule. The rule includes several types of healthcare industries in its definition of high-risk industries. Specific healthcare industries that must comply with this rule if they have 20 or more employees at a particular work location are:
  • Ambulatory healthcare services;
  • General medical and surgical hospitals;
  • Psychiatric and substance abuse hospitals;
  • Specialty (except psychiatric and substance abuse) hospitals;
  • Nursing care facilities;
  • Residential mental retardation, mental health, and substance abuse facilities;
  • Community care facilities for the elderly; and
  • Other residential care facilities.
Businesses with 250 or more employees at a work location in industries covered by the new recordkeeping regulation must submit information from their 2016 Form 300A by July 1, 2017. These employers will also be required to submit information from all 2017 forms (300A, 300, and 301) by July 1, 2018. Starting in 2019, the information must be submitted by March 2 each year. Businesses with 20-249 employees in high-risk industries, including those healthcare industries mentioned above, must submit information from their 2016 Form 300A by July 1, 2017, and their 2017 Form 300A by July 1, 2018. Starting in 2019, the information must be submitted by March 2 each year.

OSHA will make the injury and illness data public. After removing any Personally Identifiable Information that could be used to identify individual employees, OSHA will post the data on its website, and anyone will be able to download it. Employers in the above-referenced high-risk industries (and those with 250 or more employees) should begin planning now to ensure compliance with the January 1, 2017 reporting deadlines.

The new rule also emphasizes that employees who report workplace related injuries and illnesses may not be discriminated against or retaliated against because they have reported such injuries or illnesses. It provides OSHA with the authority to cite an employer for retaliation even in the absence of any employee complaint. The commentary to the rule says:
  • Employers must have a reasonable procedure for employees to report work-related injuries and illnesses.
  • Employers’ reporting procedures cannot deter or discourage reasonable employees from accurately reporting a workplace injury or illness.
  • Blanket or automatic post-accident testing policies are prohibited and will be viewed as taking an adverse action against, retaliating against, or discouraging employees from reporting accidents.
  • Employers need not specifically suspect drug use before testing, but there should be a reasonable possibility that drug use by a reporting employee was a contributing factor to the reported injury or illness in order for an employer to require testing, and, even then, the testing should be limited to only the employee who caused the accident rather than everyone involved.
Although the new rule does not prohibit all post-accident/post-injury drug testing policies, OSHA’s position is that the circumstances of some accidents make it unlikely that drug use was a contributing factor, and therefore testing employees in these situations would be viewed as retaliation. OSHA provides these examples of circumstances where required drug testing would be suspect:
  • After an employee reports a bee sting;
  • When an employee has a repetitive strain injury;
  • After an injury caused by a lack of machine guarding; or
  • When a machine or tool malfunctions.
The rule acknowledges many employers implement post-accident/post-injury drug testing policies because they are located in states that offer workers’ compensation premium reductions for enacting Drug Free Workplace Policies. Compliance with these workers’ compensation programs or other state or federal laws or regulations requiring post-accident/post-injury or reasonable suspicion testing are still permitted.

Employers must also specifically inform employees: (i) they have the right to report work-related injuries and illnesses; and (ii) the employer is prohibited from retaliating against employees for reporting work-related injuries or illnesses. Employers also must establish a reporting procedure that does not deter or discourage an employee from reporting work-related injuries and illnesses. These posting and reporting requirements are effective as of November 1, 2016.

In light of OSHA’s new rule, employers in the health care industry should review drug testing policies as well as accident/injury reporting policies to ensure they do not violate OSHA's new rules.

Also See: Provisions call for employers to electronically submit injury and illness data that they already record.


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Friday, May 13, 2016

Am I a Good Compliance Officer?

 HCSI
What Does It Take To Be A Good Compliance Officer?

What makes a good Compliance Officer?  It’s a question every hiring manager, General Counsel and Board must consider when faced with the need or opportunity to bring that critical person into the business. 
The compliance profession is still in its infancy.  A couple of decades ago it started in the United States in the financial services and health care sectors, growing out of legal and audit and into its own role.  As the UK Bribery Act came into force and more multi-national organizations were stung with fines for failing to comply with all sorts of laws, companies began to hire compliance officers in order address the ever-increasing legal and regulatory expectations placed on them from all angles.  As compliance departments grow throughout Europe, Asia and South America, businesses must evaluate who to hire and how to determine what makes a good compliance officer.

What are the primary roles a compliance officer must undertake?

In many businesses, compliance is in charge of both compliance and ethics.  Compliance tends to deal with the policies and procedures that are put in place in order for the business to ensure compliance with the law.  Ethics revolves around doing the right thing, corporate values and training people to behave in a way that creates a culture of compliance.  While some organizations, particularly in financial services, separate the ethics and compliance elements, for most businesses compliance and ethics go hand-in-hand in one role. 

Compliance Officers are generally charged with three tasks: awareness, advice and reporting.  The Compliance Officer creates the compliance program and ensures that people throughout the organization are aware of it, which includes ensuring understanding of the law, rules and procedures enforced by the company.  Compliance Officers must also be able to advise on legal and compliant ways of conducting business, and then report to the business about program implementation and specific issues requiring resources or response.

What skills does a Compliance Officer need to have?

The most important thing a Compliance Officer needs is a deep understanding of the business.  Without a desire to know the business, the Compliance Officer will not be able to give helpful solutions to problems. 

Communication skills are also vital for a Compliance Officer.  Most Compliance Officers perform training or give updates to the employee population, managers or Board, so clear, compelling communication is essential.  Compliance Officers also need to be terrific listeners so that they can hear and understand the pressure points between the business and the law.  Compliance Officers must be persuasive and able to influence the business, especially when the procedures or policies may be unpopular or difficult but necessary. 

Lastly, Compliance Officers need to be skilled at designing simple and understandable procedures in order to mitigate the risks identified by the business.

How important is independence for a Compliance Officer?

Capacity for independent thought is crucial, as is a strong moral compass.  Although it is very important that the Compliance Officer be able to get along well with others in the business, there will invariably be times when the Compliance Officer must stand up for what is right, and not what is popular.  Ideally the Compliance Officer will have a direct reporting line to the Board and C-suite, so that any highly-contentious issue is dealt with at the highest levels of the business without the dilution of another function speaking for Compliance.  There is a strong trend right now in Financial Services and in U.S. enforcement actions to demand that the Compliance Department function outside the Legal Department.  This trend is likely to continue and is likely to become best practice throughout the world.

What else can a Compliance Officer do to be effective?

The best Compliance Officers are those who can embrace change.  The regulatory environment is an ever-evolving one, and just when a Compliance Officer thinks that the program is perfect, another law will come into force or an enforcement action will require the program to shift.  Compliance Officers need to be naturally curious with a can-do attitude.  If a Compliance Officer learns to say “no” effectively to the business using empathy and giving an explanation, it will go a long way toward building the trust that is critical for the Compliance Officer to maintain with management.

What role does enthusiasm or charisma play in becoming a good compliance officer?

Ideally Compliance Officers come to the job with a belief that what they are doing is important, valuable and helpful to the business.  It’s been said that the Compliance Department’s job is to protect the business in five years.  Therefore, short-term sales goals and actions which may create reputational risk must be eschewed in favour of long-term thinking about what is going to make the business sustainable and profitable in the future.  Compliance Officers who maintain a sense of mission, justice and proportionality will be successful.  A sense of purpose, enthusiasm for the job and natural charisma will draw people within the business to listen to the Compliance Officer, which can be helpful.

The definition of what makes a “good” Compliance Officer different when the person is working in a multi-national business?

Compliance roles inevitably become more complex when the business is multi-national.  Not only does the Compliance Officer have to manage differing, and sometimes competing laws, but there will also be questions of language and culture that can make the job more difficult.  Compliance Officers working in multi-national environments need to be incredibly attuned to the cultural differences within the countries in which their business operates.  A strong desire to learn about the other cultures will make a big difference.  People tend to listen to people who listen to them.  A good Compliance Officer in a multi-national company will be one who is aware that everyone comes with a set of expectations created by their culture of origin, and that listening and being aware is critical to the success of the compliance program in a multi-national environment.

What’s the number one way to determine whether or not you are, or have hired, a good Compliance Officer?

You know you are a good Compliance Officer if members of the business frequently come to you to proactively seek your advice.  If you’re providing smart, helpful counsel and engaging with them so that they trust you, then you are likely doing your job effectively.



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Tuesday, January 19, 2016

The New OSHA Injury and Illness Reporting Requirements

OSHA Launches Serious Event Reporting Online Form


  • Calling OSHA’s free and confidential number at 1-800-321-OSHA (6742).
  • Calling your closest Area Office during normal business hours.
  • Using the new online form.
The online form has only recently become available as a method of reporting. The “Serious Event Reporting Online Form” can now be found at https://www.osha.gov/report.html . States under Federal OSHA jurisdiction and those states with State Plans for the Public Sector can use the form but most states with State Plans for both Public and Private Sectors cannot use the form yet.

When reporting using the form, the first step is a validation check – employers are asked to “Enter State of Event to determine reporting requirements.” After the validation check, the form either opens or state-specific information is provided.

One of the Frequently Asked Questions on OSHA’s webpage is:
Q: If the Area Office is closed, may I report the incident by leaving a message on OSHA’s answering machine, faxing the Area Office, or sending an e-mail?
A:  No, if the Area Office is closed, you must report the fatality, in-patient hospitalization, amputation, or loss of an eye using the 800 number (1-800-321-6742).
Section 1904.39(b)(1) clearly notes that the online reporting form may also be used to report an incident when the Area Office is closed:
[I]f Area Office is closed, you must report the fatality, in-patient hospitalization, amputation, or loss of an eye using either the 800 number or the reporting application located on OSHA’s public Web site at www.osha.gov.
29 C.F.R. §1904.39(b)(1)(emphasis added)

Employers should be aware before starting the online form that they will need to provide some specific information regarding the incident, its location, information about what happened and when it happened, and contact information for the company and for each of the victims. Without answering all the asterisked questions on the form, the submission will be rejected.


For more information on this and other healthcare compliance topics related to HIPAA, OSHA, Medicare and HR, simply email your questions to support@hcsiinc.com, 
visit our website at http://www.hcsiinc.com or post a question on our LinkedIn group at: http://bit.ly/1FWmtq6


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Wednesday, December 23, 2015

OSHA Slams Northridge Hospital for Health and Safety Violations

OSHA COMPLIANCE IS CRITICAL

State workplace safety regulators fined the operator of Northridge Hospital Medical Center about $44,125 for violations that potentially exposed the hospital’s 1,700 employees to non-compliance health hazards.

Dignity Health was cited after Cal/OSHA determined that the hospital failed to record information in over a dozen cases where hospital workers were stuck with needles, and failed to provide closeable containers in emergency rooms that would keep biohazard waste from spilling, according to the state agency.

Northridge Hospital said in a statement that it is working “diligently” to address the agency’s findings.

“We have a longstanding relationship with Cal/OSHA and appreciate the regulatory body working with us to ensure the safety of our employees,” according to the hospital.

Cal/OSHA’s Van Nuys office opened an investigation in June after receiving a complaint, resulting in 13 health code violations, regulators said.

“California’s health and safety requirements are some of the strongest in the nation, and they’re meant to prevent hospital workers from becoming hospital patients,” Cal/OSHA Chief Juliann Sum said.

The findings included violations of bloodborne pathogens precautions, which require employers to protect workers from coming into contact with blood or other disease-carrying body fluids, according to Cal/OSHA.

Cal/OSHA also issued general and regulatory violations because Dignity Health kept broken gurneys in the working area, skipped essential elements of training employees in safe patient handling, and failed to take corrective action after accidents occurred, regulators said.

In summary, there were four serious violations of the bloodborne pathogens standard, which requires employers to protect workers from coming into contact with blood or other disease-carrying body fluids. A serious violation is cited when there is a realistic possibility that death or serious harm could result from the actual hazardous condition. In this case, the serious violations included:

• Failure to gather information required by the Sharps injury log, such as type and brand of needles involved in the 18 injury cases. The employer had no procedure in place to review the log, or to solicit required input from employees about factors contributing to contaminated needle injuries. Well-kept injury logs, and their regular review, help to identify the causes of injuries and prevent future occurrences.

• Failure to provide containers that would prevent spillage or protrusion of contaminated needles in emergency treatment and trauma rooms. Additionally, the employer did not provide readily accessible hand washing facilities for emergency room employees.


• Failure to provide appropriate sizes of gloves for employees using the medication cart in the trauma room and the after-hours intake area.
Cal/OSHA also issued eight general and regulatory violations because Dignity Health kept broken gurneys in the working area, skipped essential elements of training employees in safe patient handling, and failed to take corrective action after accidents occurred. 


Sources: Northridge-Chatsworth stateofreform.com

For more information on this and other healthcare compliance topics related to HIPAA, OSHA, Medicare and HR, simply email your questions to support@hcsiinc.com, 
visit our website at http://www.hcsiinc.com or post a question on our LinkedIn group at: http://bit.ly/1FWmtq6
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Tuesday, December 8, 2015

Protecting Employees from Workplace Violence

Being Aware and Having an Emergency Action Plan

The December 2nd, 2015 shooting in San Bernardino California, where 14 people were shot to death and 21 were injured at an office gathering, is a sobering reminder that violence in the workplace is an issue of concern for all of us. For employers, it is critical to ensure that all employees know the company's safety and violence prevention policies and procedures. In addition, companies can offer additional protections:

Hiring

  • Verify information on all new hires through reference checking.
  • Screen applicants by conducting background checks. Condition offers of employment upon the completion of background checks, drug tests or medical exams.
  • Review workers’ compensation records and illness claims to identify patterns of assault or other workplace violence. Understand industry trends and specific job exposures.

Employment

  • Have a clear, written policy protecting employees from harassment, threats and intimidation. Policies should note that any complaints of harassment or threats will be investigated fully and appropriate steps taken, including discipline and discharge.
  • Establish a complaint/grievance procedure.
  • Establish/communicate how to access employee assistance program (EAP) services.
  • Offer outplacement counseling to employees being laid off or terminated.

Security

  • Consider implementing the following security measures: monitoring systems, limited access key cards, employee identification cards, emergency warning systems, security guards, visitor sign-in policies, security escorts in case of emergencies.

Crisis Plan

Develop a crisis plan that outlines how to report incidents of workplace violence, instructions on who to notify and:

  • How to assess the situation, get help, warn other employees and secure the workplace.
  • When and how to involve the police and gather information to assist an investigation.
  • Follow-up activities like debriefing employees, resuming operations and long-term planning.
All employers should and probably do maintain an evacuation plan, but few employees even drill about the plan.  Moreover, responding to a tornado, hurricane or other natural disaster is far different from responding to a fire, explosion, shooting, or collapse of the electrical grid. 
  •          Have you as an employer even thought about how you should respond to such events and protect your employees? 
  •          Do you maintain an Emergency Ection Plan (EAP) under OSHA regulations? 
  •          Do you even know what triggers the obligation to have an EAP?
There is much talk about workplace violence, but have you assessed your operation to determine where risks are presented?  Do you have employees making deliveries or going to customers’ homes unaccompanied? Have you professionally assessed security for entrance and exits?  Do management and HR know when they should be concerned about potentially dangerous employee behavior and what to do next?

If your answer is to simply point to the binder on a shelf or to be self assured that you have “competent people to take care of such matters,” then perhaps it is time to roll up your sleeves and check.
OSHA Focus on Workplace Violence

If you want additional motivation, OSHA is dead serious about inspecting employers for workplace violence exposures and issuing citations under its general duty powers. 

Special Focus on Workplace Violence in Healthcare

OSHA is also quite serious about conducting health care and hospital inspections which focus on workplace violence and ergonomic concerns.
See Also
Image credit: Chris Kuhlman 

For more information on this and other healthcare compliance topics related to HIPAA, OSHA, Medicare and HR, simply email your questions to support@hcsiinc.com, 
visit our website at http://www.hcsiinc.com or post a question on our LinkedIn group at: http://bit.ly/1FWmtq6

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Tuesday, November 10, 2015

OSHA and the Red Cross renew focus on protecting the safety of health care workers

OSHA and the American Red Cross renew alliance focused on protecting the safety and health of volunteers, employees

The Occupational Safety and Health Administration and the American Red Cross on 11/9/2015 renewed their alliance to continue efforts to reduce workplace incidents and protect workers from hazardous exposures. During this five-year alliance, OSHA and the Red Cross will focus on providing workers and employers with information and training resources on emergency preparedness, disease prevention education and first aid.
“Our alliance with the Red Cross over the past 10 years has allowed us to share safety and health information with workers, particularly those most vulnerable to workplace hazards,” said Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels. “We look forward to continuing this partnership to provide workers with the resources necessary to stay safe and healthy on the job.”
The Red Cross has been helpful in sharing information on updates to OSHA’s injury reporting requirements and also hosted a webinar on bloodborne pathogens and prevention of disease transmission in the workplace.
“This alliance reaffirms our commitment to training and preparation to help save lives,” said Dominick Tolli, Vice President, Preparedness and Health and Safety Services at the Red Cross. “Knowing the correct steps to take in those critical first moments of an emergency can mean the difference between life and death.”
Founded in 1881, the Red Cross helps communities through disaster preparedness and service. Volunteers and staff provide care to people affected by disasters in the United States and support members of the military and their families.  The Red Cross also facilitates blood collection and distribution, health and safety education and training, and international relief and development.
Through its Alliance Program, OSHA works with unions, consulates, trade and professional organizations, faith- and community-based organizations, businesses and educational institutions to prevent workplace fatalities, injuries and illnesses. The purpose of each alliance is to develop compliance assistance tools and resources and to educate workers and employers about their rights and responsibilities. Alliance Program participants do not receive exemptions from OSHA inspections or any other enforcement benefits.
Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces for their employees. OSHA’s role is to ensure these conditions for America’s working men and women by setting and enforcing standards, and providing training, education and assistance. For more information, visit www.osha.gov.

All health care providers are required to complete training anally in OSHA rules and compliance. In busy medical practice settings this can easily be put on the back burner but it is vital that your staff maintain their training requirements. OSHA compliance training is not only required and for the safety of your staff but also for the protection of your patients and visitors to your practice.
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Tuesday, November 3, 2015

OSHA Means Business Going Forward


OSHA Now Targeting The Health Care and Nursing Care Industries
Here’s more evidence your company needs to stay current on safety training: OSHA fines are heading skyward.  

Since 2010, the number of companies facing total OSHA fines above $100,000 has tripled.

This month, OSHA issued three penalties that topped one-million dollars and levied nearly a dozen citations carrying six-figure fines.

There’s more: Outgoing GOP house speaker John Boehner’s final peace offering – negotiating a compromised budget deal that would extend the debt limit and boost spending – took labor officials by surprise after finding that the agreement included a provision to hike OSHA fines nearly 50% in 2016.

The House approved the bill Oct. 28 and the Senate was scheduled to consider it Oct. 29. The bill includes a provision to adjust OSHA penalties annually based on the inflation rate.

Repeat and willful violations – which carry a maximum of $70,000 in penalties – contributed to the high dollar value of these fines. Machine guarding, lockout/tagout, trenching and fall hazards were among the common citations.

Here’s a sampling of October’s enforcement activities:
  • Regulators hit a Nebraska cleaning company with 30 citations and $963,000 in fines after a railcar exploded, killing two employees and injuring a third. OSHA said the company sent the workers to clean a tanker car filled with dangerous fumes despite warnings that the air quality inside the car showed a high risk of explosion.
  • Troubled Midwest furniture giant Ashley Furniture – already facing $1.7 million in OSHA fines from an inspection earlier this year – was hit for lockout/tagout hazards carrying $431,000 in penalties. In February, OSHA leveled 38 violations after inspectors discovered there were more than 1,000-work-related injuries at the plant over a 3 1/2 year period.
  • An Ohio chicken processing facility found itself facing $414,000 in fines after two workers were maimed while attempting to clean unguarded machines. Penalties levied against Case Farms now total over $1.4 million.
  • A commercial laundry company was hit with $305,300 in fines for repeatedly exposing workers to machine hazards. Three years ago, a 24-year old worker was killed when he was crushed by a conveyor belt.
  • osha finesOSHA orders pilot to be reinstated after being fired for refusing to fly unsafe medical transport helicopter
    A pilot working for Air Methods Corp. was illegally terminated for refusing to fly a medical transport helicopter with a faulty emergency locator transmitter. Following an investigation, OSHA ordered the company reinstate the pilot, pay $166,000 in back wages and damages and remove disciplinary information from the pilot’s personnel record. The company must also provide whistleblower rights information to all employees.
The Occupational Safety and Health Administration (“OSHA”) recently intensified its scrutiny of the health care and nursing care industries. On June 25, 2015, the agency announced a new enforcement initiative targeting inpatient health care and nursing care facilities. But this increased scrutiny of the health care and nursing care industries does not end there—OSHA is spreading its enforcement reach to other types of health care entities.
Recently, OSHA cited LifeFleet LLC, an Ohio medical patient transportation company, for training shortfalls and bloodborne pathogen violations. OSHA alleged multiple violations, including several costly willful violations, and is seeking fines totaling nearly $236,000—a notably large amount. Typically, the fines associated with OSHA citations are very low, unless they are associated with fatalities. There were no fatalities in this case.
In discussing the magnitude of the fines against LifeFleet, OSHA’s Cleveland Area Office Director Howard Eberts said, “Failing to protect workers from pathogens that can cause life-threatening diseases is unacceptable. As a medical service provider, LifeFleet should be setting the standard in employee protection – not ignoring it.”
What does this mean to health care and nursing care employers? OSHA is targeting all health care and nursing care facilities, not just inpatient facilities. The agency is sending a clear message to the health care and nursing care industries in issuing citations carrying unusually heavy fines.
Here are a few action steps that employers can take right now to prepare for an OSHA inspection:
  • Conduct an internal OSHA compliance audit. The cost of conducting an internal audit and addressing hazards before an OSHA inspection is trivial by comparison.
  • Review all health and safety training programs. Ensure that all employees have been thoroughly trained—and have received refresher training, when appropriate—on all aspects of the facility’s health and safety policies and that they can demonstrate that they understood the training. It is advisable to conduct a quiz after each training session in order for employees to demonstrate their comprehension of the training and to keep quiz results and training attendee lists on file.
  • Consult with an OSHA attorney regarding preparations for an OSHA inspection. Most health care and nursing care employers have never experienced an OSHA inspection (LifeFleet, for example, had never been inspected before) and may not be aware of strategies that can be used to minimize work disruption during an inspection and reduce the likelihood of receiving an unwarranted citation.
Sources:  - http://www.cfodailynews.com, http://www.oshalawupdate.com/, http://www.dol.gov/ 


For more information on this and other healthcare topics related to HIPAA, OSHA, Medicare and HR compliance please email support@hcsiinc.com or visit our website at http://www.hcsiinc.com 
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