OSHA has been surveying post-acute care facilities through the pandemic :
● 310 OSHA surveys have taken place in 23 states as of Jan . 14 , 2021
● 912 tags have been issued resulting in more than $ 4 million in fines
● New York had 64 surveys with 172 tags and New Jersey had 101 surveys with 324 tags
The tags issued were similar among the 310 surveys ( some facilities had multiple surveys done ); they included PPE and reporting .
●1910.134 ( e ) Medical evaluation : specifies the minimum requirements for medical evaluation that employers must implement to determine the employee ’ s ability to use a respirator
●1910.134 ( e )( 1 ) General : employer shall provide a medical evaluation to determine the employee ’ s ability to use a respirator , before the employee is fit tested or required to use the respirator in the workplace .
●1910.134 ( f )( 1 ) Fit Testing : Fit testing is required prior to initial use , whenever a different respirator facepiece is used , and at least annually thereafter .
●1910.134 ( g )( 1 )( i )( A ) The employer shall not permit respirators with
tight-fitting facepieces to be worn by employees who have facial hair that comes between the sealing surface of the facepiece and the face or that interferes with valve function ;
●1904.29 ( a ) Basic requirement . OSHA 300 , 300-A , and 301 forms , or equivalent forms , for recordable injuries and illnesses must be used . The OSHA 300 form is called the Log of Work-Related Injuries and Illnesses , the 300-A is the Summary of Work-Related Injuries and Illnesses , and the OSHA 301 form is called the Injury and Illness Incident Report . (
https :// www . osha . gov / recordkeeping / forms )
●1904.39 ( a )( 1 ) Within eight ( 8 ) hours after the death of any employee as a result of a work-related incident , you must report the fatality to the Occupational Safety and Health Administration ( OSHA ), U . S . Department of Labor .
●1904.39 ( a )( 2 ) Within twenty-four ( 24 ) hours after the in-patient hospitalization of one or more employees or an employee ’ s amputation or an employee ’ s loss of an eye , as a result of a work-related incident , you must report the in-patient hospitalization , amputation , or loss of an eye to OSHA .
●1904.39 ( a )( 3 ) You must report the fatality , inpatient hospitalization , amputation , or loss of an eye
In reviewing complaints to OSHA regarding essential industries ( healthcare , retail trade , grocery stores , construction , general warehousing , restaurants / eating establishments and auto repair ) healthcare had 45 percent of the complaints issued .
The take-away from all this data are some questions that we need to ask ourselves regarding our facility and OSHA responsibilities :
● Do we have a complete BBP plan that is reviewed annually ?
● Are we providing the training on the BBP plan and do we make it available to our employees ?
● Are providing the appropriate PPE and providing fit testing when employees use N95 respirators ?
● Are we gathering input from our employees and using that data to edit and improve our plan ?
● Are we documenting and retaining that documentation for the time period indicated ?
● Are we using the OSHA forms 300 , 300A , and 301 and posting
300A from Feb . 1 to April 30 each year ?
● How satisfied are our employees with the efforts we are expending to keep them safe ?
Are we ready for a visit from OSHA ? Can we afford to be unprepared for the sake of our residents / clients and staff ? If you haven ’ t given OSHA much attention in the past , it might be time to sit down and do a thorough review of the facility BBP plan , supplies / equipment and reporting process .
Cindy Fronning , RN , GERO-BC , IP-BC , AS-BC , RAC-CT , CDONA , FACDONA is a master trainer and director of education for the National Association of Directors of Nursing Administration in Long-Term Care ( NADONA ).
References :
1 . https :// www . osha . gov / aboutosha 2 . https :// www . osha . gov / bloodborne-pathogens / hazards
Resources :
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