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A supplement to Medical Environment Update Checking In on Safety and Health Ten Essential OSHA Checklists for Medical, Dental, and Other Ambulatory Care Settings

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A supplement to Medical Environment Update

Checking In on Safety and Health

Ten Essential OSHA Checklists for Medical, Dental, and Other

Ambulatory Care Settings

Checking In on Safety and Health: Ten Essential OSHA Checklists2 Checking In on Safety and Health: Ten Essential OSHA Checklists2

Dear Reader,

The self-assessment checklist on p. 6 of each Medical Environment Update has proven to be one of

the most popular features of the newsletter by providing a quick and easy way to check how your practice

measures up on important occupational safety and health matters.

With this in mind, I have decided to offer as a special report 10 essential checklists aimed at helping your

practice stay in compliance with OSHA standards.

I hope you find this special report a useful resource to the safety and health program in your workplace.

Should you have a question not covered in this document, don’t hesitate to call or e-mail me through the

contact information below.

Sincerely,

David A. LaHoda

Managing Editor

Phone: 781/639-1872, Ext. 3510

E-mail: [email protected]

• Give your exposure control plan a midyear checkup . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .3• OSHA is keen on your hazard communication plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .4• Scrambling for a respiratory protection plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5• Staying compliant with PPE standards . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .6• Exit route compliance is safety officer’s responsibility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7• Take action on your emergency action plan. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .8• Poorly located sharps disposal containers cause ‘sticky’ injuries . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .9• Preventing the shock of electrical accidents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10• Educating workers in preventing and responding to workplace violence . . . . . . . . . . . . . . . . . . . . . . . . 11

• Good workstation ergonomics: A prescription for a healthy workplace . . . . . . . . . . . . . . . . . . . . . . . . . 12

Table of contents

This special report is published by HCPro, Inc., 200 Hoods Lane, Marblehead, MA 01945. • Copyright 2009 HCPro, Inc. All rights reserved. Printed in the USA. Except where specifically encouraged, no part of this publication may be reproduced, in any form or by any means, without prior written consent of HCPro, Inc., or the Copyright Clearance Center at 978/750-8400. Please notify us immediately if you have received an unauthorized copy. • For editorial comments or questions, call 781/639-1872 or fax 781/639-2982. For renewal or subscription information, call customer service at 800/650-6787, fax 800/639-8511, or e-mail: customerservice@ hcpro.com • Opinions expressed are not necessarily those of the editors. Mention of products and services does not constitute endorsement. Advice given is general, and readers should consult professional counsel for specific legal, ethical, or clinical questions. HCPro, Inc., is not affiliated in any way with The Joint Commission, which owns the JCAHO and Joint Commission trademarks.

11/09 SR5609

November 2009 3

Give your exposure control plan a midyear checkup

Quick self-inspection checklist: Keeping your exposure control plan up to dateo4 o You have a written exposure control plan

o The written plan addresses topics required by OSHA:

o Determination of employee exposure

o Implementation of various methods of exposure control, including universal precautions, engineer-ing and work practice controls, personal protective equipment, and housekeeping

o Hepatitis B vaccination

o Postexposure evaluation and follow-up

o Training, including communication of hazards to employees

o Recordkeeping

o Procedures for evaluating circumstances surrounding exposure incidents

o Your employees have been educated on the contents of the plan and know where to access it

o Employees know that they can request a copy of the plan

o You provide a copy of the plan to an employee, fam-ily member, or legal representative within 15 days of a request

o You annually review the entire plan, and the plan contains your initials and the date of the review

o You change, initial, and date the plan with the intro-duction of new or modified tasks and procedures con-cerning bloodborne pathogen exposure

o You change, initial, and date the plan with the intro- duction of new or modified job classifications with ex-posure to bloodborne pathogens

o You change, initial, and date the plan to reflect changes in technology (e.g., safety needles and sharps) that eliminate or reduce exposures to bloodborne pathogens

o You record input of nonmanagerial employees respon-sible for direct patient care in the identification, evalu-ation, and selection of safety devices

Source: OSHA Regulatory Manual for Healthcare.

Self-inspection notes

Exposure control plan citations make up the most frequent and most expensive citations when OSHA inspects facilities in the “offices and clinics of doctors of medicine” category. The numerical code for this category in the Standard Industrial

Classification (SIC) system is 8011 and includes all physician practices, community clinics, and ambulatory surgery centers.The exposure control plan is the heart of Bloodborne Pathogens standard compliance, and it is the document that an OSHA

inspector is sure to request from you during an inspection. It is also easy for an inspector to detect whether the plan is deficient or not kept up to date.

According to a report obtained by Medical Environment Update for OSHA inspections from July to December 2007, exposure control violations were the reason for 24% of all citations issued to the SIC 8011 facilities. Further, exposure control plan noncom-pliance constituted 35% of all the initial fines issued by OSHA to these types of facilities.

The most common exposure control plan violations from the report period were:•Not having a written exposure control plan•Failing to review and update the exposure control plan•Not documenting in the exposure control plan annual consideration and implementation of medical devices designed to

eliminate or minimize occupational exposure

The average fine for each of the violations listed above was $554, according to the report.Reviewing the exposure control plan frequently, updating it for changes specific to your workplace, and initialing and dating

the changes are good ways to steer clear of problems.Review the quick self-assessment checklist below to determine how well you have maintained your exposure control plan so

far this year.

Checking In on Safety and Health: Ten Essential OSHA Checklists4

OSHA is keen on your hazard communication plan

Self-inspection notes

The hazard communication standard consistently ranks among those most frequently cited during healthcare facility inspections. Last year, nursing homes received by far the most hazard communication violations in the healthcare market. Medical practices

beat out both hospitals and laboratories to claim second place in hazard communication infractions. No written hazard communication plan, no list of hazardous chemicals, no or inadequate employee training, and missing

material safety data sheets (MSDS) were the most common hazard communication citations that OSHA found in healthcare facilities, according to a report published in the February Medical Environment Update.

OSHA’s approach to hazard communication includes labeling, using MSDSs, and training. “An OSHA inspector will expect you, as the safety officer, to explain the development and management of these three components specific to your facility,” says Kenneth Weinberg, PhD, president of Safdoc Systems in Stoughton, MA.

Weinberg says that in addition to reviewing your written plan and documentation, an OSHA inspector will want to interview your employees to assess the effectiveness of your training program. The following are four questions that an inspector is likely to pose: •Doemployeesknowhowtorespondinthecaseofachemicalexposure?•Donewhiresreceivetrainingbeforeassignmenttoareasinwhichthereisapotentialforexposure?•Doemployeesreceiveadditionaltrainingwiththeintroductionofnewchemicalhazardsorengineeringcontrolsinthe workplace?

•CanemployeesretrieveMSDSs,especiallyifusingelectronicorcomputerfiles,incompliancewiththestandard?

Safety officers may use the checklist below to help assess their facility’s level of compliance with the hazard communication standard.

Quick self-inspection checklist: Hazard communication compliance

o Has the practice prepared a list of all hazardous chemicalsintheworkplaceandkeptitupdated?

o Has the practice obtained an MSDS for each hazardous chemical?

o Has the practice developed a system to ensure that all incoming hazardous chemicals are checked for properlabelsandMSDSs?

o Are procedures in place to ensure the presence of labels or warning signs for containers that hold hazardouschemicals?

o Are employees aware of the specific information and training requirements of the hazard communication standard?

o Are employees familiar with various types of chemicals andtheirassociatedhazards?

o Do employees understand how to detect the release ofhazardouschemicalsintheworkplace?

o Are employees trained in proper work practices and personalprotectiveequipment?

o Does the training program provide information about first aid, emergency procedures, and the symptoms of overexposure?

o Does the training program include an explanation of thelabelsandwarnings?

o Does the training describe where to obtain MSDSs andhowemployeesmayusethem?

o Is there a system to ensure that new employees receivetrainingbeforebeginningwork?

o Is there a system to identify new hazardous chemicals beforetheiruse?

o Is a system in place to inform employees of new hazardsassociatedwithachemical?

Source: Adapted from OSHA Regulatory Manual for Healthcare, published by HCPro, Inc.

o4

November 2009 5

Quick self-inspection checklist: Readiness and your respiratory protection plano4Check on the following items if you require employees to

wear respirators in your workplace: o Doyouhaveawrittenrespiratoryprotectionplan? o Does the plan identify a program administrator who

has the appropriate experience to recognize, evaluate, andcontrolthehazardsintheworkplace?

o Does the plan address: o The appropriate selection of respirators based on potentialairborneinfectiousagents?

o Theoperatingcharacteristicsoftherespirator? o The behaviors of the healthcare workers using it, andcertificationbyNIOSH?

o Aremedicalevaluationspartoftheplan?Employersmust evaluate whether employees are able to wear res-pirators by a questionnaire or medical examination.

o Are employees fit tested before being issued respira-torsforuseduringwork?OSHArequiresfittestinginitially and annually on employees required to wear respirators with tight-fitting facepieces.

o Does the plan cover user checks for leaks in the seals orvalvesthatcouldcompromiseworkerprotection?Conditions that can interfere with seals or valves in-clude facial hair, facial scars, jewelry or headgear, missing dentures, corrective glasses or goggles, or other personal protective equipment.

o Does the plan include the means for maintenance and careofrespirators?Employersmustproviderespiratorsthat are clean, sanitary, and in good working order to ensure that the equipment protects as designed.

o Is cleaning and disinfection of respirators, if appli-cable,partoftheplan?Reusableequipmentmustbe

regularly cleaned and disinfected according to speci-fied procedures of the standard or manufacturer speci-fications that are of equivalent effectiveness.

o Doestheplanaddressstorageofrespirators?Employ-ers must store respirators in a manner that protects them from contamination and prevents facepiece or valve deformation.

o Are there worker instruction and education provisions intheplan?Beforerequiringrespiratoruseduringwork, employers must provide training in:

o Respirator necessity and how improper fit, usage, and maintenance can make it ineffective

o The limitations and capabilities of the respirator o How to inspect, put on and remove, and check the

seals of the respirator o Respirator maintenance and storage procedures o The general requirements of the respiratory protection

standard o Does the plan call for training and documentation

initially, annually and whenever there are changes in workplace conditions or respirator selection, or when-everthereisevidenceofimproperrespiratoruse?

o If employees are not required to wear a respirator but want to voluntarily wear one, do you provide them with Appendix D of the respiratory protection standard, “Information for Employees Using Respirators WhenNotRequiredUnderStandard”?

Source: Adapted from Pandemic Influenza Guidance for Healthcare Workers and Healthcare Employers.

Scrambling for a respiratory protection plan

If it didn’t take you long to start thinking about your respiratory protection plan after the first reports of influenza A (H1N1), swine flu, you were not alone. OSHA warned against waiting until the last min-

ute to plan, including considering the need for respirator use among workers, in its 2007 Pandemic Influenza Guidance for Healthcare Workers and Healthcare Employers.

Federal (29 CFR 1910.134) and state OSHA regulations require employers to establish and maintain a written respiratory protection program to protect their respirator-wearing employees.

However, by the end of the first week of the pandemic, California had already relaxed those regulations. (See “In California, act first on swine flu; train later” at OSHA Healthcare Advisor (www.oshahealthcareadvisor.com), explaining that the absence of a plan should not deter the issuing of respirators and that employers should do the training and documentation as soon as possible.)

Whether you are still trying to develop a policy or catching up on actions already implemented, see the pandemic influenza plan in your OSHA compliance manual. Also, OSHA Healthcare Advisor has a video clip from Respirator Safety for Healthcare Workers to help educate you and your staff on pandemic hazards. In the meantime, use the checklist below, adapted from OSHA, to assess the compliance of your plan with the respiratory protection standard.

Self-inspection notes

Checking In on Safety and Health: Ten Essential OSHA Checklists6

Self-inspection notes

Staying compliant with PPE standards

Employers are responsible for providing, and ensuring that employees wear, personal protective equipment (PPE) where needed to prevent exposure to physical, chemical, or biological agents that may cause harm through inhalation, absorption, or other

physical contact, according to OSHA standards.In the healthcare environment, PPE may be needed to prevent worker exposure to hazards such as sterilants and disinfectants,

radiation, electrical equipment and wiring, contaminated laundry, infectious disease, hazardous drugs, medical waste, and asbestos.

Required PPE may include items such as gloves, masks, gowns, protective eyewear, face shields, and respirators.Standards that apply in healthcare settings such as bloodborne pathogens and respiratory protection address PPE as part of

the regulation. But OSHA’s industrywide PPE standard (1910.132) also comes into play. The standard’s major provisions require employers to do the following:•Conductahazardassessmenttoidentifyworkplacehazards•SelectandrequireemployeestousePPEthatprovidessuitableprotectionagainstthosehazards•Trainemployeesintheproperuse,fit,maintenance,limitations,anddisposalofPPE

In the past six months, OSHA citations against medical practices for nonadherence of PPE standards have included:•Protectiveequipmentnotprovidedornotmaintainedinasanitaryandreliablecondition•Employernotverifyingthattherequiredworkplacehazardassessmenthasbeenperformedthroughawrittencertification•EmployernotprovidingtrainingtoeachemployeewhoisrequiredtousePPE•PPEtrainingincompletebecauseitdidnotspecificallyaddresswhenPPEisnecessary;whatPPEisnecessary;howtoproperly

don, doff, adjust, and wear PPE; and the limitations of PPE•Missingorincompletetrainingdocumentation

Remember, PPE may not be used as a substitute for feasible engineering, work-practice, or administrative controls (although its use may be relied upon during periods when engineering controls are being installed). Rather, it should be relied upon in conjunction with these controls to provide for employee safety and health in the workplace.

The checklist below is from OSHA’s Assessing the Need for Personal Protective Equipment. Use it to compare the status of your PPE program against a possible OSHA inspection.

o4 Quick self-inspection checklist: Establishing a PPE program

o Identify steps taken to assess potential hazards in every employee’s work space and in workplace operating procedures

o Identify appropriate PPE selection criteria

o Identify how you will train employees about the use of PPE, including: – What PPE is necessary – When PPE is necessary – How to properly inspect PPE for wear or damage – How to properly put on and adjust the fit of PPE – How to properly take off PPE – The limitations of PPE – How to properly care for and store PPE

o Identify how you will assess employee understanding of PPE training

o Identify how you will enforce proper PPE use

o Identify how you will provide for any required medical examinations

o Identify how and when to evaluate the PPE program

November 2009 7

Exit route compliance is safety officer’s responsibility

Quick self-inspection checklist: Emergency exit routeso4 o Your facility has at least two exit routes remote from

one another. Small facilities may have one exit route if it is adequate for all employees to escape safely.

o Exit routes are free of explosive or highly flammable furnishings and other decorations.

o Exit routes direct employees away from high-hazard areas, or the path of travel is effectively shielded from the high-hazard area.

o Exit routes are unobstructed by materials, equipment, locked doors, or dead-end corridors.

o Lighting for exit routes is adequate for employees with normal vision.

o Exit route doors are free of decorations or signs that obscure the visibility of the doors and their designation as exit routes.

o Signs are posted along the exit access indicating the direction of travel to the nearest exit and exit dis-charge if that direction is not immediately apparent.

o The line of sight to an exit sign is clearly visible at all times.

o Doors or passages along an exit route that could be mistaken for an exit are marked “Not an Exit” or with a sign identifying its use (e.g., “Closet”).

o Exit signs are in plainly legible letters.

o Exit signs are illuminated by a reliable light source or are distinctly self-luminous.

o Exit routes are maintained during construction, repairs, or alterations.

o Your facility has an emergency alarm system to alert employees, unless employees can promptly see or smell a fire or other hazard in time to provide ade-quate warning to them.

o A diagram of the exit route(s) is posted in a central and accessible location in the workplace.

Source: Emergency Exit Routes, OSHA Fact Sheet, 2003. Reprinted with permission.

Self-inspection notes

The ability to safely exit a facility during an emergency is a basic tenet of workplace safety for any business.OSHA standard 1910.36 establishes the design and construction requirements for exit routes. This includes the kinds, numbers,

locations, and capacities appropriate to the individual building or structure and, as such, usually involves the expertise of architects, builders, and construction contractors.

Normally, a workplace must have at least two exit routes “to permit prompt evacuation of employees and other building occu-pants during an emergency,” according to an OSHA fact sheet. One exit is permitted if “the number of employees, the size of the building, its occupancy, or the arrangement of the workplace allows all employees to evacuate safely during an emergency.”

OSHA standard 1910.37 addresses the maintenance, safeguards, and operational features for exit routes. Compliance with this standard is well within the purview of the facility safety officer.

According to a report obtained by Medical Environment Update, OSHA imposed the following exit violations and fines on phy-sician practices in the past six months:•Violation: Exit routes not free and unobstructed from permanent or temporary materials or equipment, or exit access passes

through a room that can be locked, such as a bathroom. Fine: $300.•Violation: Exit not clearly visible and marked by a sign reading “Exit.” Fine: $275.•Violation: Doorway or passage along an exit route that could be mistaken for an exit is not marked “Not an Exit” or not

identified by a sign indicating its actual use (e.g., “Closet”). Fine: $675.

Review the quick self-assessment checklist below to see how well your facility complies with OSHA’s standards on exit routes.

Checking In on Safety and Health: Ten Essential OSHA Checklists8

Quick self-inspection checklist: Emergency action plans o4General issues

o Does the plan consider all potential natural or man-madeemergenciesthatcoulddisruptyourworkplace?

o Does the plan consider all potential internal sources of emergenciesthatcoulddisruptyourworkplace?

o Does the plan consider the effect of these internal and external emergencies on the workplace’s operations, andistheresponsetailoredtotheworkplace?

o Does the plan contain a list of key personnel with contact information, as well as contact information for localemergencyrespondersandagencies?

o Does the plan address rescue operations and medical assistance?

o Does the plan identify how or where personal informa-tiononemployeescanbeobtainedinanemergency?

Evacuation policy and procedure o Does the plan identify the conditions under which an

evacuationwouldbenecessary? o Does the plan identify a clear chain of command and

designate a person authorized to order an evacuation orshutdownofoperations?

o Does the plan address the types of actions expected of individual employees for the various types of potential emergencies?

o Does the plan designate who, if anyone, will stay to shutdowncriticaloperationsduringanevacuation?

o Does the plan outline specific evacuation routes and exits, and are these posted in the workplace where theyareeasilyaccessibletoallemployees?

o Does the plan address procedures for assisting people during evacuations, particularly those with disabilities orwhodonotspeakEnglish?

o Does the plan identify one or more assembly areas (as necessary for different types of emergencies) where employees will gather and a method for accounting for allemployees?

o Does the plan address how visitors will be assisted in evacuationandaccountedfor?

Reporting emergencies and alerting employees o Does the plan identify a preferred method for reporting

firesandotheremergencies? o Does the plan describe the method to be used to alert

employees,includingdisabledworkers,toevacuate?

Employee training and drills o Does the plan identify how and when employees will

be trained so they understand their responsibilities andactionsasoutlinedintheplan?

o Doestheplanaddressretraining? o Doestheplanaddressdrills?

Source: OSHA’s “Evacuation Plans and Procedures” e-tool.

Take action on your emergency action plan

Self-inspection notes

Nearly every U.S. workplace is required to have an emergency action plan (EAP), according to OSHA’s evacuation plan and procedures Web page.

Fire is the most common reason to initiate the EAP, but not the only one. OSHA says that your EAP should address any reasonably anticipated emergency. This could include severe weather, bomb threats, chemical gas or radiation spills and leaks, and civil unrest or outside disturbances. Your OSHA manual contains sample plans for several of these emergencies, but you should assess which scenarios are most likely to occur in your workplace and customize them accordingly.

An employer with 10 or fewer employees can simply communicate the plan verbally to staff members, but having more than 10 employees requires a written plan. Whether verbal or written, the plan must include: • Means of reporting fires and other emergencies • Evacuationproceduresandemergencyescaperouteassignments• Procedurestobefollowedbyemployeeswhoremaintooperatecriticalplantoperationsbeforetheyevacuate• Procedurestoaccountforallemployeesafteranemergencyevacuationhasbeencompleted• Rescueandmedicaldutiesforthoseemployeeswhoaretoperformthem

OSHA makes it easy to create a custom plan for your workplace by using the “Evacuation Plans and Procedures” e-tool. Search for it by its title at www.osha.gov. If you’re not sure how your current plan stacks up to OSHA compliance, review the checklist below, taken from the e-tool.

November 2009 9

Self-inspection notes

Poorly located sharps disposal containers cause ‘sticky’ injuries

Quick self-inspection checklist: Sharps disposal container locationso4 o Container placement, along with work practices, allows

sharps disposal as soon as possible—preferably without needing to put the device down and pick it up again.

o Containers are within arms’ reach and below eye level at their point of use.

o Wall-mounted containers allow workers access or view of the opening of the container.

o No furniture or other objects create obstacles between the worker’s path and the container.

o Container placement does not cause unnecessary move-ment when holding the sharp during disposal. The fol-lowing locations are avoided for container placement:

– In the corners of rooms – On the backs of room doors – Near light switches or room environmental controls – In areas in which people might sit or lie beneath the container

– Under cabinets

– On the insides of cabinet doors – Under sinks – Where the container is subject to impact and dis-lodgement by pedestrian traffic, moving equipment, gurneys, wheelchairs, or swinging doors

o Placement due to security and safety precautions such as pediatric, geriatric, mental health, and correctional settings does not impair safe access by workers.

o Installation height of containers is within an ergonomi-cally acceptable range (i.e., 52–56 inches for standing disposal; 38–42 inches for seated disposal).

o Containers are visible through placement, color, and signage.

o Container fill status is visible under current lighting con-ditions and before sharps are placed in the container.

o Container safety features, security measures, and design aesthetics do not impair container recognition, fill status, warning labels, disposal opening, or access.

What are the three qualities that sharps disposal containers have in common with a choice pieceofrealestate?Location,location,location.

Disposal is one of the prime times for needlesticks to occur, according to the CDC’s Workbook for Designing, Implementing, and Evaluating a Sharps Injury Prevention Program.

Not engaging the device’s safety feature, putting down the device and then picking it up, walking out of the exam room with a sharp, difficulty in reaching the container or seeing the opening, or simply having the false sense of security that the most hazard-prone part of the procedure is done are just some of the safety missteps that can occur when disposing of contaminated sharps.

Wall-mounted sharps containers should be installed 52–56 inches above the floor to accommodate 95% of the adult population, according to NIOSH’s Selecting, Evaluating, and Using Sharps Disposal Containers.

For an amusing take on incorrect sharps container height installation on medical TV shows, read “For safety’s sake, follow House and Scrubs on the tube; not in your practice” at OSHA Healthcare Advisor (www.oshahealthcareadvisor.com).

Installing at the proper height alone won’t remove all sharps disposal container location hazards. Distance to containers, obstacles in the path, concealed placement for security or aesthetic reasons, and even poor lighting conditions contribute to sharps injuries during disposal.

OSHA Bloodborne Pathogens standard 1910.1030(d)(4)(iii)(A)(2)(i) requires sharps disposal containers to be “easily accessible to personnel and located as close as is feasible to the immediate area where sharps are used.” Recent initial fines for this type of violation in healthcare facilities averaged $829. In addition to OSHA, container location could be subject to compliance with state regulations and facility certification or accreditation requirements.

The OSHA Healthcare Advisor has a video clip from the Needlestick Prevention Training Video to help educate you and your staff members on hazards during sharps disposal.

Additionally, you can use the checklist below to assess how safely you have positioned the sharps disposal containers in your facility.

Checking In on Safety and Health: Ten Essential OSHA Checklists10

Preventing the shock of electrical accidents

Quick self-inspection checklist: Preventing electrical accidentso4 o You require compliance with OSHA standards for all

contract electrical work. o Your workplace is free from clutter, which can add

to the potential for electrical accidents from spills and leaks.

o Sufficient access and working space is provided and maintained around all electrical equipment to permit ready and safe operations and maintenance.

o You keep liquid away from all equipment connected to electricity and dispose of any cups or cans that are left near electrical equipment.

o Unsafe or poorly maintained electrical equipment is replaced or disposed of. This includes equipment brought into the workplace by employees.

o When unplugging equipment, staff members do not pull on the cord; they pull by the plug instead.

o Your workplace prohibits permanently running extension cords across walkways or through door openings.

o You only use three-wire extension cords with a ground-fault circuit interrupter (GFCI).

o You prohibit the use of multiple extensions cords (i.e., daisy chaining).

o You prohibit overloading electrical circuits, such as using adapters to connect multiple appliances.

o Each multiple-outlet box or surge protector is plugged directly into a wall outlet, not to an extension cord.

o Your workplace prohibits the use of multiple-outlet boxes for space heaters, hot plates, coffeepots, or other high-current loads.

o GFCIs are installed where receptacles on countertops are within 6 ft. of a sink.

o Circuit breakers and panels are easily accessible (i.e., not locked) and have a 3-ft. clearance from supplies and other equipment.

o Staff members are instructed not to insert fingers or metal objects into working parts of office machines when clear-ing jams or malfunctions.

o When repairing or maintaining electrical equipment, workers comply with the OSHA lockout/tagout standard.

o Employees are required to report any obvious electrical hazard as soon as possible.

o Any employee who experiences an electrical shock is treated by a healthcare professional as soon as possible.

o You conduct an incident analysis of serious and poten-tially lethal electrical incidents, including near misses.

Editor’s note: To order HCPro’s Complete Guide to Labora tory Safety, Second Edition, go to www.hcmarketplace.com or call 800/650-6787.

Self-inspection notes

Computer surge protectors plugged into other surge protectors, a series of extension cords snaking their way to power an out-of-the-way appliance, boxes of supplies covering the circuit breaker panels in the electric closet, and that avocado-colored

toaster oven from the 1970s with its familiar frayed cord in the break room. If you have encountered similar things in your safety walk-through inspection, it’s time to get serious about workplace electrical

safety. Nearly all workers are exposed to electrical energy as part of their jobs, says NIOSH, but “many workers are unaware of the potential electrical hazards present in their work environment, which makes them more vulnerable to the danger of electrocution.”

Electrocution, fatal exposure to electric current, is only one of four injuries resulting from electrical accidents. The other injuries associated with electrical energy contact are electric shock, burns, and falls.

OSHA’s standards for protecting employees from fires and hazards from electrical current exposure regularly appear among the top 10 most frequent violations in the healthcare industry. The National Fire Protection Association, the American Na tional Standards Institute, and the American Society of Heating, Refrigerating and Air-Conditioning Engineers also have standards or guidelines for protecting workers.

Further, states and municipalities have specific electrical codes that may vary from national standards. It is advisable to check on the local level to familiarize yourself with electrical codes.

Review the quick self-assessment checklist below, adapted from Complete Guide to Laboratory Safety, Second Edition, to assess how your workplace measures up to OSHA electrical safety.

November 2009 11

Educating workers in preventing and responding to workplace violence

Self-inspection notes

Quick self-inspection checklist: Workplace violence prevention training

o Does the violence prevention program require training for all employees and supervisors when they are hired andwhenjobresponsibilitieschange?

o Do agency workers or contract physicians and house staff members receive the same training that permanent staffmembersreceive?

o Are workers trained in how to handle difficult clients orpatients?

o Are employees and supervisors trained to behave compassionately toward coworkers when an incident occurs?

o Does the security staff receive specialized training for thehealthcareenvironment?

o Is the training tailored to specific units, patient popula-tions, and job tasks, including any tasks conducted in thefield?

o Do employees learn progressive behavior control techniquesandsafemethodstoapplyrestraints?

o Do workers believe that the training is effective in handlingescalatingviolenceorviolentincidents?

o Are drills conducted to test the response of health-carefacilitypersonnel?

o Are workers trained in how to report violent incidents, threats, or abuse and obtain medical care, counseling, workers’ compensation, or legal assistance after a violentepisodeorinjury?

o Does the training include instruction about the loca-tion and operation of safety devices such as alarm systems, along with the required maintenance sched-ulesandprocedures?

Source: Guidelines for Preventing Workplace Violence for Healthcare and Social Service Workers.

o4

OSHA identifies violence in the workplace as a serious safety and health issue and recognizes that healthcare workers facea risk of job-related violence that is greater than in the general workforce.

The national average for all occupations was 12.6 violent acts per 1,000 workers, according to the Department of Justice’s National Crime Victimization Survey, which covers incidents reported between 1993 and 1999. The reported rate of violent incidents in healthcare occupations were:•16.2per1,000physicians•21.9per1,000nurses•68.2per1,000mentalhealthworkers•69.2per1,000mentalhealthcustodialworkers

OSHA’s Guidelines for Preventing Workplace Violence for Healthcare and Social Service Workers (available online at www.osha.gov/publications/osha3148.pdf) provides advice on how to create a comprehensive violence prevention program with: •Managementcommitmentandemployeeinvolvement•Worksiteanalysisofexistingandpotentialrisks•Hazardpreventionandcontrol•Safetyandhealthtraining

A key part of the training component is universal precautions for violence prevention. The concept is similar to the universal precaution practiced in infection control in which all human blood and certain human body fluids are treated as if known to be infectious. In this case, approach all patients as though they have the potential for violence.

“You don’t want staff to be scared of everyone they deal with,” says Steven MacArthur, safety consultant at The Greeley Company, a division of HCPro, Inc., in Marblehead, MA. “However, manage each encounter with the thought that, until you’ve ruled it out, each person has the potential for violent or disruptive behavior.”

The guidelines recommend that employees receive formal training in the specific hazards associated with job duties before assignment. Although the guidelines are not mandatory, they reference the agency’s general duty clause, which states that employers must provide a workplace that is safe for employees. Review the quick self-assessment checklist below to determine how your workplace violence prevention training measures up to the OSHA guidelines.

Checking In on Safety and Health: Ten Essential OSHA Checklists1212

Good workstation ergonomics: A prescription for a healthy workplace

Quick self-inspection checklist: Workstation ergonomicso4When sitting

o Chair height allows feet to rest comfortably flat on the floor with your knees just slightly lower than your hips.

o Seat pan depth provides for a 2–4-inch gap between the back of your knees and the front edge of the seat pan.

o Chair back fits into the deepest part of the curve in your lower back.

o The back of the chair is upright or tilted back for comfort.

o Armrests and chair mobility do not interfere with access to typing, the mouse, or writing surfaces.

When typing o The home row of keys is at the same height as your

elbows or slightly below your elbows with your shoul-ders relaxed and your fingers curved.

When positioning the cursor with a pointing device o The pointing device is positioned close to the keyboard.

When organizing the workspace o You are able to use your work surface and equipment

without overreaching or using awkward postures.

When viewing the monitor o The top line of print is at or just below eye level—or even

lower if you wear bifocal or progressive lenses—and you are able to scan the screen using only eye movements.

o You can sit against the back of your chair and read the monitor from a comfortable distance without experiencing eye fatigue, blurred vision, or headaches.

o The monitor is free of glare.

When reading a document o The paper document is the same distance away from

you as the monitor.

When using new software o You have received training on the software you are

using. Studies have shown that training can pay off in preventing injuries, being able to work without discom-fort or pain, reducing unnecessary movements, saving time, and getting work done more efficiently.

Editor’s note: For ergonomic training for physician offices and ambulatory settings, see Medical Environ ment Update’s Healthcare Ergonomics Training Video at www. hcmarketplace.com or call customer service at 800/650-6787.

Self-inspection notes

Lifting and moving patients are not the only hazards that make healthcare workers susceptible to musculoskeletal disorders. Office staff and clinical/lab personnel who work with computers risk injury by working in an ergonomically unsafe environment. According to Easy Ergonomics for Desktop Computer Users (www.dir.ca.gov/dosh/dosh_publications/ComputerErgo.pdf) by

the California Department of Industrial Relations, risk factors associated with computer use include the following:•Typingforlongperiodsoftimewithoutbreaksorrest•Usingforcewhenstrikingthekeyboardorwhengrippingthemouse•Workingwithawkwardneck,shoulder,elbow,wrist,orbackpostures•Remaininginthesamepositionforalongperiodoftimewithlittleornomovement•Continuallyleaningonthewristrest,worksurfaceedge,orarmrestwiththewrists,forearms,orelbows•Continuouspressureagainstthefrontedgeofthechairwiththebackofthelegs

California is the only state that has an ergonomics standard, whereas federal OSHA has voluntary guidelines. Nevertheless, in some extreme cases, enforcement through the general duty clause is one method to quickly and effectively address musculoskeletal disorders in the workplace, according to the agency’s ergonomics Web page (www.osha.gov/SLTC/ergonomics/index.html). Review the quick self-inspection checklist below, adapted from Easy Ergonomics for Desktop Computer Users, to assess whether your facility makes workstations ergonomically safe and effective for maximum worker productivity.