Would Your Healthcare Facility Fail an OSHA Inspection? (Part I)
Recent OSHA Violations in Healthcare Focus on Specific Areas of Investigation (I)
Think OSHA would never inspect your healthcare facility? Think twice. In April 2012, OSHA announced it would be targeting nursing homes and residential care facilities for the next 3 years. Other healthcare facilities are not immune. In the past year, OSHA has inspected medical and dental practices and surgical centers.
In all, proposed fines for nongovernment healthcare facilities ranged from $8700 to $89,000.
The reported focus of its investigations included:
- Exposure to communicable diseases, such as tuberculosis
- Exposure control plans for bloodborne pathogens (BBP)
- Safety-engineered controls and safer devices
- Ergonomic stressors related to lifting patients
- Workplace violence
- Slips, trips and falls
Read on to see what these OSHA investigations revealed — and begin to assess whether or not your healthcare facility might be at risk of noncompliance.
Exposure to Communicable Disease, Such as Tuberculosis
OSHA requires respiratory protection for healthcare workers who are exposed to patients with known or suspected tuberculosis. In addition, OSHA standards require:
- Fit testing of respirators according to mandatory procedures
- User respiratory seal check procedures
- Respirator cleaning procedures
- OSHA respirator medical evaluation questionnaires
- Information for employees using respirators when not required
In August 2012, a health center reportedly did not protect its workers from tuberculosis. The health center was fined $17,600. Its infractions included:
- Failure to have a plan in place that promptly identifies, masks, and isolates patients with suspected tuberculosis
- Failure to provide workers who were exposed to suspected or known tuberculosis with training about tuberculosis and a respiratory protection program
The center was also cited for not having a hazard communication program and hazardous chemical training.
Exposure Control Plan for Blood and Potentially Infectious Materials
Your BBP exposure control plan must include an exposure determination for employees and methods that prevent workplace exposure to blood and potentially infectious materials.
Among other key elements, your exposure control plan must detail how you will:
- Use a combination of engineering and work practice controls to prevent needlesticks and other sharps injuries
- Apply methods of compliance with the Standard such as the use of personal protective equipment
- Communicate hazards
- Provide hepatitis B vaccination
- Supply post-exposure prophylaxis
Not only must you have an exposure control plan, but you must also document your annual reevaluation of that plan. This includes documentation regarding the evaluation and implementation of effective devices to prevent bloodborne pathogens transmission. (These devices will be the focus of Part II of this blog.)
Failing to review and update an exposure control plan annually is considered a serious violation. A citation of $4900 was proposed for a medical provider that was a first-time offender of this violation. In all, the provider’s violations totaled a whopping $47,000.
Additionally, proposed penalties of $89,000 fell to a single nursing home for a combination of related violations. These included:
- Failure to document annual evaluation of the exposure control plan and to implement safer needle devices as part of this evaluation
- Failure to list tasks and procedures in which exposure to biological hazards for some employees may occur
- Failure to keep a log of sharps injuries
The first two infractions were considered repeat offenses because the company that owned the facility had been cited for the same violation at two of its 43 facilities. In other words, if you have multiple sites, an infraction at one facility can be considered a repeat violation at another — even if the inspections are years apart.
For a medical practice, $16,800 of its total $44,800 in proposed penalties included the following infractions:
- Lack of bloodborne pathogens training
- Lack of an exposure control plan
- Improperly sized personal protective equipment
- Failure to offer employees hepatitis B vaccination
- Overfilled sharps disposal containers
- Recapping of contaminated needles
Needlesticks can expose your workers to bloodborne pathogens, such as hepatitis B virus (HBV), hepatitis C virus (HCV), human immunodeficiency virus (HIV), and others. The Centers for Disease Control and Prevention (CDC) estimates 600,000 sharps injuries, such as needlesticks, annually among healthcare workers.
A surgical center was fined $68,000 for failing to protect workers exposed to bloodborne pathogens hazards. OSHA described problems with the facility’s post-exposure protocol:
- Failure to counsel an employee who endured a needlestick with a contaminated needle
- Failure to test the employee’s blood in a timely manner
- Failure to provide the appropriate medicine to prevent contracting a potential disease
Seventeen violations — 13 serious violations of the bloodborne pathogens standard — resulted in proposed penalties of $46,000 for a nursing and rehabilitation center. Some of the noteworthy violations included:
- Lack of a confidential medical evaluation after a needlestick
- Failure to maintain confidentiality of an employee’s medical record
- Failure to provide the hepatitis B vaccination to employees
- Failure to consider safer needle devices in the annual review of its exposure control plan
Avoiding the Risk of OSHA Fines
In sum, bloodborne pathogens and other workplace hazards pose a substantial risk of morbidity and mortality for healthcare workers. As a result, OSHA has added increased focus and hefty fines for violations.
Stericycle certified occupational safety specialists provide in-person, annual site evaluations and training that focuses on OSHA compliance with the bloodborne pathogens standard. The NO FINE. NO FAIL. Guarantee™ ensures that you’ll be 100% compliant with your BBP and medical waste management practices when you follow our Steri-Safe Preferred Program and recommendations — or we’ll pay your OSHA-related fines.
This service along with the award-winning online bloodborne pathogens training helps our Steri-Safe Preferred Program customers protect their teams from bloodborne pathogens.
In Part II, you'll explore the importance of safety-engineered controls and safer devices, ergonomic stressors, workplace violence, and slips, trips and falls.