1

OSHA 2012 for AAPC: I2P2

Provided by M. Ann Bachman,MT(ASCP), (CLC)AMT) AAPOL OSHA Specialist

What Is OSHA?   Occupational Safety and Health Act of 1970   Occupational Safety and Health Administration   State Programs (see list on next slide)   For the protection of EMPLOYEES only

2

2

State OSHA Programs   Alaska   Arizona   California   Connecticut   Hawaii   Indiana   Iowa   Kentucky   Maryland   Michigan

  Minnesota   Nevada   New Jersey   New Mexico   New York   North Carolina   Oregon   Puerto Rico   South Carolina   Tennessee

3

  Utah   Vermont   Virgin Islands   Virginia   Washington   Wyoming

4

Employee Rights and Responsibilities

  Responsibilities:   Comply with the OSHA

regulations   Participate in the

employer’s safety program   Attend training   Report hazards   Suggest controls

  Report occupational illnesses and injuries

  Rights:   A safe and healthy

workplace   Hazard controls   Information and training   Medical treatment   Decline medical treatment   Access personal medical

records   Request OSHA inspection   Protection from job

discrimination

3

General Duty Clause

  Each employer (1.) shall furnish to each of his employees employment

and a place of employment which are free from recognized hazards causing or are likely to cause death or serious physical harm to his employees.

(2.) shall comply with occupational safety and health standards promulgated under this Act.

5

What’s New?

  I2P2: Illness and Injury Protection Program   Implement systematic approach to further reduce illnesses and

injuries

  Looking at several existing programs to use as models   Cal/OSHA   OSHA’s Voluntary Protection Program (VPP), Safety and Health

Achievement Recognition Program (SHARP), OHSAS 18001 (from the British Standards Institute), other State programs

6

4

I2P2 Goals   Increase workplace

engagement through   Leadership   Health and Safety

Committees   Continuous Improvement

  Establish-Implement-Maintain   Citation for failure to

maintain (book on the shelf)

I2P2 Core Elements   Management duties   Employee participation   Hazard identification and

assessment   Hazard prevention and

control   Education and training   Program evaluation and

improvement

7

Assignment of Responsibilities

  Appoint Safety Coordinator   Authority   Resources

  Outline responsibilities   Accountability for everyone   Consequences

  Verbal warning   Written warning   Suspension   Termination

8

5

9

OSHA Inspections   Enforcement

 Unannounced (except in specialized situations)  Based on priorities

  Imminent danger to employees   Fatality/catastrophe   Employee complaint   Referral from other government agency   Follow-up   Programmed inspections/Special emphasis programs

  OSHA Consultation Services   Scheduled   Free: No fees, no fines

10

Handling an Inspection

  Inspector will:   present credentials   explain proceedings   honor patient confidentiality   review written

documentation   inspect workplace   interview employees   give exit briefing

  Office should:   accompany the inspector   be cordial and cooperative   not send employees home

unless directed by the inspector

  record whatever s/he records

  recognize that an OSHA inspection is not a privacy violation!

6

11

Penalties

  Could be per incident, not per standard   Max $7,000 for serious violation, $1,000 for

non-serious; $5,000 up to $70,000 for willful or repeated violations

  Up to $7,000 per day for failure to abate   Based on complicated factors and formulas   Reduced based on several factors

 Number of employees  Past history  Good faith effort

12

Citations

  Received in writing several days later   Must be posted for 3 business days

 Visible to employees   May be appealed

 Employers must initiate proceedings in writing within 15 days to appeal citations or penalties

 Employees must initiate appeal within 10 days to contest abatement date

7

13

Hazard Analysis

  Document  Presence of hazard and current controls  Suggestions for better controls

  Include employee input   Repeat as needed

 Required only one time   Controls, written program, and training are

based on findings of hazard analysis   If the hazard is absent, controls are unnecessary

14

Injury and Illness Prevention Written Program for Coders and Auditors

  General Safety   Emergency Action

Plan   Ergonomics

  Workplace Violence   Training   Record Keeping

8

15

Employer Documentation

  Customize the manual   Document commitment of management

  Must also be in practice

  Document annual review of Exposure Control Plan

  Site-specific Information   Safety Committee

General Safety

  Fire Safety  Prevention  Alarm  Extinguishers  Evacuation

  Electrical Safety

  Walking and Working Surfaces

  Indoor Air Quality

16

9

Electricity

  Electrical Safety   Don’t use worn cords or place cords where they

will become worn or become tripping hazards   Have ground fault circuit interrupters where outlets

are near water   Know the location of your breaker panels and be

sure they are not blocked  OSHA requires a 3-foot clearance

17

18

Emergency Action Plan

 Training is imperative!  Reasons to evacuate  Emergency Action Plan  Means of Egress  Portable Fire Extinguishers

10

19

Evacuation Procedures

  Fire, gas leak, chemical spill, bomb threat   Notify all employees   Call emergency agency (911)   Assist co-workers as needed   Exit through nearest unobstructed exit   Meet at designated place   Check in with Safety Coordinator; stay put!

20

Extinguishing the Fire

  Remove the extinguisher from the bracket   Break the seal and remove the pin   Aim the nozzle at the base of the fire, starting

8-10 feet back and using sweeping motion   Visually examine fire extinguisher monthly and document   Have extinguishers serviced professionally each year

11

21

Ergonomics

 Definition  Purpose  Governmental Actions  Examples  Suggested Controls

22

Ergonomics

  “The science of fitting jobs to people”  Purpose: to reduce musculoskeletal

disorders  Examples: back injury, carpal tunnel

syndrome, neck and back pain  Standard: revoked and abandoned

12

23

Ergonomics Program

  Hazard analysis   Observe strained positions, repetitive

motions, excessive force   Include employee input   Take a common-sense approach

 Rearrange workstations

Back Injury

 Use good body mechanics.  Lift with your legs, not your back  Keep weight as close to your body as possible  Don’t twist or turn while supporting extra

weight: Pivot!

24

13

Neck And/or Shoulder Pain

  Too much time with receiver wedged between ear and shoulder  Shoulder rest  Headset

  Be careful with cordless phones; may compromise confidentiality

25

Carpal Tunnel Syndrome

  Improper keyboarding or position   Use an ergonomic keyboard or add a wrist

rest   Do ergonomic exercises every two hours   Vary duties   Drink lots of water!

26

14

27

Computer Workstations  Body positioning:

  Feet, thighs, forearms parallel to floor   Calves, upper arms, back perpendicular to floor   Wrists and head straight   Shoulders relaxed

 Terminal positioning:   Straight in front of head   At eye level

 Document positioning:   At same level as terminal or   Just below the terminal

What’s New in Workplace Violence   On September 8, 2011, OSHA released its CPL

02-01-052, “Enforcement Procedures for Investigating or Inspecting Workplace Violence”

  Not a standard, but an instructional document designed to provide policies and procedures for investigations and inspections

28

15

29

Workplace Violence Statistics   Average annual total reported assaults for

2000-2009: 590   Ten percent of those were in health care   Assault is one of the top four causes of fatalities

in the workplace   Assault is the most common cause for workplace

deaths among women   OSHA considers health care workers at high risk

Categories of WPV   Type 1—Criminal intent, often robbery   Type 2—Customer/Clients/Patients: Health

care is in this classification   Type 3—Co-worker, current or former

employee, supervisor, or manager   Type 4—Personal: Someone who does not

work there but knows or has a relationship with an employee

30

16

Workplace Violence Prevention

 Commitment of management  Assignment of responsibilities  Hazard assessment

  Location - High crime area?   Facility - Parking arrangements, landscaping,

locks, guards, waiting area   Clients/Services

31

 Written program  Education and training

  Include reporting processes   Assure no repercussions for reporting

32

Workplace Violence Prevention, Continued

17

33

Techniques   Do’s

  Stay calm   Use neutral words, tone of

voice, body language   Acknowledge others’

distress   Offer to get manager   Get help when needed   Report to supervisor   Document immediately

  Don’ts   Ignore the person or the

problem   Threaten the individual   Make promises you cannot

keep   Exacerbate the situation by

being confrontational   Body language   Words   Tone of voice

34

Post-incident Response   Employer should provide comprehensive

treatment for victimized or traumatized employees:  Trauma crisis counseling  Critical incident stress debriefing  Assistance programs

In the absence of a formal standard, OSHA may use the General Duty Clause with these new guidelines to compel employers to protect employees against workplace violence.

18

35

OSHA Training   Who

 Everyone at risk for exposure to the hazard(s)   What

 Cover all hazards, including site-specific info  Time for questions

  When  Upon hire  When duties change, new hazard introduced  Each 12 months  During normal duty hours

36

Training Documentation

 Date of training  Name and job titles of attendees  Topics covered (outline)  Name and qualifications of trainer

  Must be knowledgeable; no certificate required

 Keep for three years   Some states may require longer record

retention

19

Record Keeping Summary

  Hazard Analysis   One time

  Commitment of Management   One time

  Training   Annually

37

38

Record Keeping

  Reporting to OSHA   OSHA Log of Work-Related Injuries and Illnesses

  Outpatient healthcare facilities partially exempt in some states   OSHA may require any employer to complete this and return it to

them the next year   Post 300A February 1-April 30.

  OSHA 301 replaces old 101   May use Workers Compensation First Report of Injury instead

20

39

Reporting to OSHA  Report occupationally related

fatalities within 8 hours.  Report incidents that result in

hospitalization (in-house) of 3 or more employees within 8 hours.

 Submit OSHA 300/300A form if required by OSHA.   You will get written instructions.

40

Wrap-up

 Questions?

Thank you!

21

41

Seminar Special

  Training Video Special   Good this week only!   Ask me for the order form

 WE MAKE HOUSE CALLS   800-470-9605   www.doctors-management.com/aapol

42

BE SAFE!

www.doctors-management.com/aapol