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Dear HCPro Customer: Enclosed is your latest supplement to the OSHA Program Manual for Dental Facilities. This supplement is designed to keep your product up to date. Your next supplement will be in November 2015. If you have any questions about your subscription, please contact our Customer Service department at 800-650-6787 or e-mail [email protected]. At HCPro, customer comments and suggestions are very important to us—let us know how we can serve you better. Please insert these new and revised pages as indicated, and keep these filing instructions at the front of your book. FILING INSTRUCTIONS Rev. 9/15 OPMFDF Supplement to OSHA Program Manual for Dental Facilities VISIT www.hcmarketplace.com for the latest compliance and training information. Remove Insert Reason for Change Title page Title page updated v/vi v/vi Master List of Program Items for Customization—updated xi/xii xi/xii OSHA Program Manual Contents—updated Tab 3 Contents Tab 3 Contents updated 3-25 through 3-36 3-25 through 3-35 Tab 3: General Facility Safety—updated workplace violence section September 2015 Revisions

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Page 1: OSHA Program Manual for Dental Facilities 9/15 supplementcontent.hcpro.com/manuals/meu/DOSPM2_SUPPLEMENT_15I.pdf · First Aid Kit Identify items included in your facility’s first

Dear HCPro Customer:

Enclosed is your latest supplement to the OSHA Program Manual for Dental Facilities. This supplement is designed to keepyour product up to date. Your next supplement will be in November 2015.

If you have any questions about your subscription, please contact our Customer Service department at 800-650-6787 ore-mail [email protected]. At HCPro, customer comments and suggestions are very important to us—let usknow how we can serve you better.

Please insert these new and revised pages as indicated, and keep these filing instructions at the front of your book.

FILING INSTRUCTIONS

Rev. 9/15 OPMFDF Supplement to OSHA Program Manual for Dental Facilities

VISIT www.hcmarketplace.com for the latest compliance and training information.

Remove Insert Reason for Change

Title page Title page updated

v/vi v/vi Master List of Program Items for Customization—updated

xi/xii xi/xii OSHA Program Manual Contents—updated

Tab 3 Contents Tab 3 Contents updated

3-25 through 3-36 3-25 through 3-35 Tab 3: General Facility Safety—updated workplace violence section

September 2015 Revisions

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About the AuthorMarge McFarlane, PhD, MT (ASCP), CHSP, CHFM, CJCP, HEM, MEP, CHEP, is an independent safety consultant with more than 38 years of healthcare experience. She has provided education, emergency management and safety plan review, life safety, and infection prevention facility surveys for healthcare and businesses in Wisconsin and across the nation since 2005. She is the author of The Compliance Guide to the OSHA GHS Standard for Hazardous Chemical Labeling, 2014 and the OSHA Training Handbook for Healthcare Facilities, Second Edition, 2014. 15I

©2005–2015. HCPro, a division of BLR. All rights reserved, including right of reproduction. The author(s) and their

agent(s) have made every reasonable effort in the preparation of this publication to ensure the accuracy of the information.

However, the information in this book is sold without warranty, either expressed or implied. The authors, the editors, their

agents, and the publishers will not be liable for any damages caused or alleged to be caused directly, indirectly, incidentally,

or consequentially by the information in this publication. This publication cannot and does not provide specific information

for a user’s exact situation. Users of this publication should exercise their own judgment and, where appropriate, seek the

assistance of legal counsel regarding their particular situation.

HCPro, a division of BLR75 Sylvan Street, Suite A-101

Danvers, MA 01923Tel: 800/650-6787Fax: 800/639-8511

www.hcmarketplace.com

OSHAPROGRAMMANUALfor Dental Facilities

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OSHA Program Manual for Dental Facilities is published by HCPro, a division of BLR.

Copyright © 2015 HCPro, a division of BLR.

All rights reserved. Printed in the United States of America. 5 4 3 2 1

ISBN: 978-1-60146-744-7

No part of this publication may be reproduced, in any form or by any means, without prior written consent of

HCPro, a division of BLR, or the Copyright Clearance Center (978-750-8400). Please notify us immediately

if you have received an unauthorized copy.

HCPro, a division of BLR, provides information resources for the healthcare industry.

HCPro, a division of BLR, is not affiliated in any way with The Joint Commission, which owns the JCAHO

and Joint Commission trademarks.

Marge McFarlane, PhD, MT (ASCP), CHSP, CHFM, CJCP, HEM, MEP, CHEP, Author

Sheila Dunn, DA, MT (ASCP), Contributing Editor

John Palmer, Managing Editor

Mike Mirabello, Fulfillment Specialist

Glenn Stefanovics, Content Management Specialist

Matt Sharpe, Senior Manager of Production

Elizabeth Petersen, Vice President

Advice given is general. Readers should consult professional counsel for specific legal, ethical, or

clinical questions.

Arrangements can be made for quantity discounts. For more information, contact:

HCPro, a division of BLR

75 Sylvan Street, Suite A-101

Danvers, MA 01923

Telephone: 800-650-6787 or 781-639-1872

Fax: 800-639-8511

E-mail: [email protected]

Visit HCPro online at: www.hcpro.com and www.hcmarketplace.com

9/15

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v

Master List of Program Items for Customization

Throughout this OSHA Program Manual, blanks are included for you to fill in information specific to your facility.

The following pages contain “blanks” for you to customize. Enter your initials and the date you made the entry in the far right columns. This way when you do your annual review you can quickly tell if you need to update old information.

Page Item Information Needed Initials Date

2­2 Key Contacts for the OSHA Safety Program

Safety officer name, employer name, phone numbers, safety manual location

2­8 Workplace Hazards Record other hazards found in facility

2­22 Annual Review Safety officer to record reviews of safety program

3­2 Emergency Phone List Fill in emergency contact phone numbers

3­15 Systems Failure Record names and numbers to call in the event of a systems failure

3­16 Evacuation Procedures Determine and record evacuation procedures

3­18 Evacuation Route Draw floor plan of your facility noting exits and fire safety equipment

3­20 Emergency Preparedness Supplies

Determine emergency supplies you will keep on hand and record their location

3­24 Severe Weather Record safest location in building (Note: 3 blanks)

3-31–3­32.10 Violence Prevention Details of your Violence Prevention Plan (Note:

5 blanks and 7 lists that require checkmarks)3­333­34 First Aid Kit Identify items included in your facility’s

first aid kit

3­37 3­41

Drug­Free Workplace Program

Details of your Drug­Free Workplace Program (Note: if no options selected on 3-37, other customizations not necessary)

3-44– 3­47 Holiday Decorations Details of your combustibles decoration policy

(Note: this is not a required policy)3-51– 3­53

Slips Trips and Falls Risk Assessment

Review of slip, trip and fall hazards in your facility

5­9 Exposure Prone Procedures

Note procedures performed in your facility that could expose employees

5­11Form 7 BBP Determination List Record all employees who have definite risk

of exposure (class I)5­13

Form 8 BBP Determination List Record all employees who have possible risk of exposure (class I)

5­14 Restricted Access Areas Record restricted access areas

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vi

Page Item Information Needed Initials Date5­16 Handwashing Locations Record handwashing locations5­20 Sharps Recapping Record instances when recapping is allowed

5­20 Safety Sharps Record instances when safety sharps are not used

5­22 Bleach Contact Time If you use bleach for decontamination, check and document state specific contact time

5­23 Housekeeping Schedule Record your facility’s cleaning methods and frequency

5­30 Eyewash Stations Record eyewash locations and types

5­31 Biohazardous Waste Record name of company and phone for your facility’s biohazardous waste pick-up

5­33 Laundry Note how biohazardous laundry is cleaned or whether you use only disposables at your facility

5­34 PPE Locations Record PPE provided in your facility and its location

5­39 When to Wear PPE Read PPE required at your facility and add additional PPE in space provided

5­42 Hepatitis Vaccinations Record name of provider and location for HBV vaccine

5­52 BBP Post Exposure Testing Record name of provider for medical evaluation and lab testing in case of an employee exposure

6­23 Chemical Exposure Record facility name and phone for exposure medical follow­up

7­5 Form 21 TB Risk Assessment Gather information and record TB Risk Assessment

7­7 Early TB Identification Record procedures to ID active TB patients and where they are referred for treatment

7­9 Managing TB Patients Record location where suspected TB patients will wait and facility they will be transferred to

7­10

N­95 Masks Medical Powered Air Purifying Respirators (PAPRs)

Note whether your facility provides N­95 masks Note whether your facility provides PAPRs

7­13 Form 22 TST Record Record each employee’s TST details

7­15 Employee TB Infections Record name of facility where employees with positive TST or symptoms of TB will be referred

7­16 Form 24 TB Exposure Log Record names of employees only if exposed to TB

7­18 Pre­pandemic PlanningRecord name and title of individual to be designated as Response Coordinator. Also record name and contact information of key agencies

7­19 Pre­pandemic Planning (con’t)

Record communication plan, name of person responsible for PR and Educational Coordinator.

7­21 Influenza Staff Shortage Calculate and record number of staff needed during a shortage and record who will cover

7­21 Influenza Reporting Note the frequency of reporting during a pandemic and record who will review reports

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xi

Contents

TAB 3: General Facility SafetyKeeping Employees Safe ............................................................................. 3-1

Important Phone Numbers & Contacts ................................................................................ 3­1Emergency Phone List ........................................................................................................ 3­2

Fire Safety ...................................................................................................... 3-3Automatic Sprinkler Systems .............................................................................................. 3­3Fire Alarms .......................................................................................................................... 3­3Fire Procedures: Immediate Actions .................................................................................... 3­3Building Evacuation ............................................................................................................. 3­4Fire Extinguishers ................................................................................................................ 3­4

Purchase the Right Extinguisher ................................................................................. 3­5How Many Fire Extinguishers to Have & Where to Put Them ..................................... 3­6To Use a Fire Extinguisher: Think “PASS” ................................................................... 3­6When to Extinguish Fires with a Portable Fire Extinguisher ........................................ 3­6

Fire extinguisher supplement ..................................................................... SupplementWhen NOT to Extinguish Fires and to Evacuate ......................................................... 3­7Fire Extinguisher Inspections ...................................................................................... 3­7Fire Extinguisher Maintenance .................................................................................... 3­7

Fire Drills .............................................................................................................................. 3­7

Electrical Safety ............................................................................................ 3-8Physical Characteristics of a Safe Dental Facility ..................................... 3-8

Air Quality ............................................................................................................................ 3­8Mold ............................................................................................................................. 3­9

Mold Remediation ................................................................................................ 3­10Aisles ................................................................................................................................... 3­11Emergency Lighting ............................................................................................................. 3­11Employee Dress Code ......................................................................................................... 3­11Exits, Means of Egress ........................................................................................................ 3­12Exit Doors ............................................................................................................................ 3­13Exit Signs ............................................................................................................................. 3­13Floors ................................................................................................................................... 3­13Lighting ................................................................................................................................. 3­13Noise .................................................................................................................................... 3­13Portable Space Heaters ....................................................................................................... 3­14Restricted Access Areas ...................................................................................................... 3­14Sinks .................................................................................................................................... 3­14Storage ................................................................................................................................ 3­14Dental Lab Equipment ......................................................................................................... 3­15Air Compressors .................................................................................................................. 3­15

Systems Failure ............................................................................................ 3-15Evacuation Plan ............................................................................................ 3-16

Evacuation Procedures ........................................................................................................ 3­16Evacuation Route ................................................................................................................. 3­18

Emergency Preparedness Supplies ........................................................... 3-20

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Contents

Emergency Action Procedures ................................................................... 3-20Bioterrorism: Suspicious Letters or Packages ..................................................................... 3­20

What is a “Suspicious Package”? ................................................................................ 3­20Bomb Threat ........................................................................................................................ 3­21

If You Discover a Bomb or a Suspicious Item ............................................................. 3­22Explosion ..................................................................................................................... 3­22

Civil Disturbance .................................................................................................................. 3­22Earthquake .......................................................................................................................... 3­23

If a Tremor Occurs when You Are Inside ..................................................................... 3­23After the Tremor Is Over .............................................................................................. 3­23

Severe Weather ................................................................................................................... 3­24Flood ........................................................................................................................... 3­24Hurricane ..................................................................................................................... 3­24Severe Thunderstorm or Tornado Warning ................................................................. 3­24Tornado Safety Tips .................................................................................................... 3­25Severe Thunderstorm or Tornado Watch .................................................................... 3­25Toxic External Atmosphere .......................................................................................... 3­25

Violence ............................................................................................................................... 3­25OSHA’s Jurisdiction Over Workplace Violence ........................................................... 3­25Prevalence of Violence ............................................................................................... 3­26Identifying Situations with the Potential for Violence .................................................... 3­27Violence Prevention Plan Introduction ........................................................................ 3­28Overview of Violence Prevention Plan Components ................................................... 3­28 Part 1 .................................................................................................................... 3­28

Workplace Violence Program Checklists .................................................... 3­30Part 2 .................................................................................................................. 3­32.9

More Sources for Prevention of Workplace Violence ................................................... 3­32.10

First Aid ......................................................................................................... 3-33First Aid Kit .......................................................................................................................... 3­33Basic First Aid for Common Emergencies ........................................................................... 3­34Crash Kit/Cart Components ................................................................................................ 3­35

Drug-Free Workplace Program .................................................................... 3-37Service Animals ............................................................................................ 3-42Holiday Decorations ..................................................................................... 3-44

Sample Checklist: Spot Check Your Facility’s Holiday Decorations .................................... 3­44

Safe Decorations and Displays Policy ........................................................ 3-46Slip, Trip, and Fall Prevention ...................................................................... 3-48

Contaminants on the Floor .................................................................................................. 3­48Poor Drainage: Pipes and Drains ........................................................................................ 3­48Indoor Walking Surface Irregularities ................................................................................... 3­48Outdoor Walking Surface Irregularities ............................................................................... 3­49Weather Conditions: Ice and Snow ..................................................................................... 3­49Inadequate Lighting ............................................................................................................. 3­49Stairs and Handrails ............................................................................................................. 3­49Stepstools and Ladders ....................................................................................................... 3­49Tripping Hazards: Clutter, Including Loose Cords, Hoses, Wires, Medical Tubing ............. 3­50Improper Use of Floor Mats and Runners ........................................................................... 3­50Healthcare Facility Slip, Trip, and Fall Hazard Checklist ..................................................... 3­51

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TAB 3: GENERAL FACILITY SAFETY

Contents

Keeping Employees Safe ................................................................................. 3-1Important Phone Numbers & Contacts .................................................................................. 3-1Emergency Phone List ........................................................................................................... 3-2

Fire Safety ......................................................................................................... 3-3Automatic Sprinkler Systems ................................................................................................. 3-3Fire Alarms ............................................................................................................................. 3-3Fire Procedures: Immediate Actions ....................................................................................... 3-3Building Evacuation ............................................................................................................... 3-4Fire Extinguishers .................................................................................................................. 3-4

Purchase the Right Extinguisher .................................................................................... 3-5How Many Fire Extinguishers to Have & Where to Put Them ........................................ 3-6To Use a Fire Extinguisher: Think “PASS” ...................................................................... 3-6When to Extinguish Fires with a Portable Fire Extinguisher ........................................... 3-6

Fire extinguisher supplement ........................................................................ SupplementWhen NOT to Extinguish Fires and to Evacuate ........................................................... 3-7Fire Extinguisher Inspections ......................................................................................... 3-7Fire Extinguisher Maintenance ...................................................................................... 3-7

Fire Drills ................................................................................................................................. 3-7

Electrical Safety ................................................................................................ 3-8Physical Characteristics of a Safe Dental Facility ........................................ 3-8

Air Quality .............................................................................................................................. 3-8Mold ................................................................................................................................ 3-9

Mold Remediation ................................................................................................... 3-10Aisles ..................................................................................................................................... 3-11Emergency Lighting ............................................................................................................... 3-11Employee Dress Code ............................................................................................................ 3-11Exits, Means of Egress .......................................................................................................... 3-12Exit Doors .............................................................................................................................. 3-13Exit Signs ................................................................................................................................ 3-13Floors ...................................................................................................................................... 3-13Lighting ................................................................................................................................... 3-13Noise ....................................................................................................................................... 3-13Portable Space Heaters .......................................................................................................... 3-14Restricted Access Areas ........................................................................................................ 3-14

Page

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Sinks ...................................................................................................................................... 3-14Storage .................................................................................................................................. 3-14Dental Lab Equipment ........................................................................................................... 3-15Air Compressors .................................................................................................................... 3-15

Systems Failure ............................................................................................... 3-15Evacuation Plan ................................................................................................ 3-16

Evacuation Procedures ........................................................................................................... 3-16Evacuation Route ................................................................................................................... 3-18

Emergency Preparedness Supplies .............................................................. 3-20Emergency Action Procedures ...................................................................... 3-20

Bioterrorism: Suspicious Letters or Packages ....................................................................... 3-20What is a “Suspicious Package”? ................................................................................... 3-20

Bomb Threat .......................................................................................................................... 3-21If You Discover a Bomb or a Suspicious Item ................................................................ 3-22Explosion ....................................................................................................................... 3-22

Civil Disturbance ..................................................................................................................... 3-22Earthquake ............................................................................................................................ 3-23

If a Tremor Occurs when You Are Inside ........................................................................ 3-23After the Tremor Is Over ................................................................................................ 3-23

Severe Weather ...................................................................................................................... 3-24Flood .............................................................................................................................. 3-24Hurricane ....................................................................................................................... 3-24Severe Thunderstorm or Tornado Warning .................................................................... 3-24Tornado Safety Tips ....................................................................................................... 3-25Severe Thunderstorm or Tornado Watch ....................................................................... 3-25Toxic External Atmosphere ............................................................................................ 3-25

Violence ................................................................................................................................. 3-25OSHA’s Jurisdiction Over Workplace Violence .............................................................. 3-25Prevalence of Violence .................................................................................................. 3-26Identifying Situations with the Potential for Violence ...................................................... 3-27Violence Prevention Plan Introduction ........................................................................... 3-28Overview of Violence Prevention Plan Components ..................................................... 3-28 Part 1 ...................................................................................................................... 3-28

Workplace Violence Program Checklists ....................................................... 3-30Part 2 ...................................................................................................................... 3-32.9

More Sources for Prevention of Workplace Violence ..................................................... 3-32.10

First Aid ............................................................................................................ 3-33First Aid Kit ............................................................................................................................. 3-33Basic First Aid for Common Emergencies ............................................................................. 3-34Crash Kit/Cart Components ................................................................................................... 3-35

Drug-Free Workplace Program ....................................................................... 3-37Service Animals ............................................................................................... 3-42

Contents

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Holiday Decorations ......................................................................................... 3-44Sample Checklist: Spot Check Your Facility’s Holiday Decorations ...................................... 3-44

Safe Decorations and Displays Policy ........................................................... 3-46Slip, Trip, and Fall Prevention ......................................................................... 3-48

Contaminants on the Floor .................................................................................................... 3-48Poor Drainage: Pipes and Drains .......................................................................................... 3-48Indoor Walking Surface Irregularities ...................................................................................... 3-48Outdoor Walking Surface Irregularities .................................................................................. 3-49Weather Conditions: Ice and Snow ....................................................................................... 3-49Inadequate Lighting ............................................................................................................... 3-49Stairs and Handrails ............................................................................................................... 3-49Stepstools and Ladders ......................................................................................................... 3-49Tripping Hazards: Clutter, Including Loose Cords, Hoses, Wires, Medical Tubing ................ 3-50Improper Use of Floor Mats and Runners ............................................................................. 3-50Healthcare Facility Slip, Trip, and Fall Hazard Checklist ....................................................... 3-51

Contents

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OSHA Program Manual for Dental Facilities

Tornado Safety TipsThe best shelter from a tornado is a basement. Alternatively, go to an inside room without

windows on the lowest level of the building, such as a closet, bathroom or interior hall. Protect your body with a heavy blanket or something similar.

Avoid windows. Do not open windows; go find shelter instead. If you are caught in an open space or open large building, get into the restroom, if

possible, which is usually made of concrete block and will offer more protection. If there is no time to relocate, try to get up against something that will support or deflect

falling debris. Protect your head with your hands and arms. If you are in your car, get out if you can find shelter. An underpass of a bridge, a culvert or

ditch can all provide shelter if a substantial building is not nearby.

Severe Thunderstorm or Tornado Watch If a Severe Thunderstorm or Tornado Watch is announced, the OSHA Safety Officer

should keep apprised of local atmospheric conditions and monitor, via the media (radio or television), to determine if weather conditions are deteriorating.

If advised by the OSHA Safety Officer, staff must be prepared to move all individuals to a safe area and move unsecured equipment and hazardous chemicals to a safe area (if time allows). Do not stand near window glass during high wind conditions.

Toxic External AtmosphereUpon receipt of information of an external toxic atmospheric condition, the OSHA Safety

Officer will announce the condition to patients, visitors and staff.Keep doors and windows shut and locked during the condition. Shut down all air

handlers. Follow instructions given by civil authorities. Upon notification by civil authorities

that the condition no longer exists, the OSHA Safety Officer will issue an “All Clear” announcement.

The OSHA Safety Officer will determine if patient services may resume or need to be rescheduled.

Violence

OSHA’s Jurisdiction Over Workplace Violence

Healthcare and social service workers face significant risks of job-related violence and it is OSHA’s mission to help employers address these serious hazards. In 2015, OSHA released an update to their voluntary guidelines for preventing workplace violence in healthcare and social service workers. The Guidelines for Preventing Workplace Violence in Healthcare and Social Service Workers updates OSHA’s 1996 and 2004 voluntary guidelines. It is based on industry best practices and provides recommendations for developing policies and procedures to eliminate or reduce workplace violence in a range of healthcare settings. These guidelines

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OSHA Program Manual for Dental Facilities

are intended to cover a broad spectrum of workers, including those in psychiatric facilities and hospital emergency rooms, as well as neighborhood clinics and mental health centers. The publication can be found at www.osha.gov/Publications/osha3148.pdf.

According to Enforcement Procedures for Investigating or Inspecting Incidents of Workplace Violence, CPL 02-01-052, which the agency issued September, 2011, citations could be issued under Section 5(a)(1), General Duty Clause; 29 CFR 1904, Recording and Reporting Occupational Injuries and Illnesses; and 29 CFR 1910.151, Medical Services and First Aid.

According to the Enforcement Procedures, inspections concerning workplace violence hazards must be considered where there is a complaint, referral, or report of a fatality and/or catastrophic event involving an incident of workplace violence, especially when it occurs in the high-hazard workplaces identified by OSHA. An inspection can also be initiated during a programmed inspection when the OSHA agent identifies potential for violence in that work setting. Employers should use these guidelines to develop appropriate workplace violence prevention programs and engage workers to ensure their perspective is recognized and their needs are incorporated into the program.

Prevalence of Violence

Workplace violence, such as physical assault or the threat of physical assault, represents a serious occupational risk. According to OSHA and the Bureau of Labor Statistics, 27 out of the 100 fatalities in healthcare and social service settings that occurred in 2013 were due to assaults and violent acts. According to the FBI, work-place violence is any action that may threaten the safety of an employee, affect the employee’s physical or psychological well-being, or cause damage to company property.

Workplace violence is any physical assault, threatening behavior, or verbal abuse occurring in the work setting. A workplace includes the buildings and the surrounding perimeters, including the parking lots, field locations, patients’ or clients’ homes, and traveling between work assignments.

For healthcare workers and social workers, the number of workplace assaults between 2011 and 2013 ranged from 23,540 and 25,630 annually. Assaults on healthcare workers account for 10-11% of workplace injuries involving days away from work as compared to 3% of injuries for all private sector employees. Assaults, hostage taking, rapes, robbery and other violent actions are reported at healthcare and community settings. Research has found that workplace violence is under reported—suggesting that the actual rates may be much higher.

Healthcare settings that are particularly vulnerable are psychiatric facilities, hospital emergency departments, community mental health clinics, drug abuse treatment clinics, pharmacies, community-care facilities, residential facilities and long-term care facilities.

At-risk workers include physicians, registered nurses, pharmacists, nurse practitioners, physicians’ assistants, nurses’ aides, therapists, technicians, public health nurses, home healthcare workers, social and welfare workers, security personnel, maintenance personnel maintenance, and emergency medical care personnel.

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OSHA Program Manual for Dental Facilities

Workplace violence is defined as any act or threat which creates a hostile work environment. Workplace Violence includes:

Swearing Obscene phone callsName calling Harassment with intimidationShouting Suicides and near-suicidesGestures or expressions that communicate a threat

Wrestling, pushing, restraining, slapping and biting

Discourteous conduct Assaults (aggressive physical actions)Stalking Suicides and near-suicidesThreats to inflict bodily harm Bullying

Identifying Situations with the Potential for Violence

Some common factors that increase risk for workplace violence are:Working directly with volatile patients, especially if they are under the influence of drugs

or alcohol or have a history of violent or psychotic behaviorWorking when understaffed or alone (lunch or break time, after hours)Overcrowded, uncomfortable waiting rooms, poor environmental design including

unrestricted movement of the public.Poorly lit corridors, rooms or parking lots Inadequate security Lack of staff training and policies for preventing and managing crisesTransporting patients Long waits for service

The following signs may help in early identification of a violent individual:Talks and complains loudly; uses profanity, or makes sexual commentsContinually uses excuses and/or blames othersDemands unnecessary servicesStates that he or she is going to lose controlPaces rapidly, excessive sweating or flushed face, twitching face, shallow breathing,

keeping head down, furrowed browsChallenges authorityAppears tense and angryAppears intoxicated or under the influence of drugsHas a history of violenceHas had multiple life stressors, such as divorce, death in the family, or financial problems

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OSHA Program Manual for Dental Facilities

Violence Prevention Plan Introduction

Workplace violence can and does occur, in even the best of workplaces. The best approach to workplace violence is to stop it before it happens by dealing effectively with acts of aggression that can snowball into full-fledged violence. You should understand the following: The most effective line of defense against workplace violence is a well-prepared workforce. Your employer maintains a “zero tolerance” for workplace violence and provides additional

training to help you become prepared to recognize and prevent it. You can best prepare by gaining confidence in your abilities to do so.

This facility is committed to providing a safe and healthful workplace for the entire staff. This violence prevention plan, which follows the Enforcement Procedures for Investigating or Inspecting Incidents of Workplace Violence and Guidelines for Preventing Workplace Violence for Health Care & Social Service Workers, OSHA Publication 3148, 2015, is provided to eliminate or minimize occupational exposure to hostile work environments and violent acts.

Overview of Violence Prevention Plan Components

The following violence prevention plan is separated into two parts. The first part includes an introduction and steps to take promote a violence-free workplace. The second part outlines actions that will be taken in case a violent act occurs at this facility.

PART 1:

A written program for workplace violence prevention, incorporated into the overall safety and health program, offers an effective approach to reduce or eliminate the risk of violence in the workplace. The building blocks for developing an effective workplace violence prevention program include:

1. Management commitment and employee participation; 2. Worksite analysis and hazard identification; 3. Hazard prevention and control; 4. Safety and health training; and 5. Recordkeeping and program evaluation.

The workplace violence prevention program should have clear goals and objectives for preventing workplace violence, be suitable for the size and complexity of the facility, and be adaptable. Facilities should also check for applicable state requirements. Several states have passed legislation and developed requirements that address workplace violence.

According to the FBI, there are four general classifications of workplace violence:

TYPE 1: Violent acts by criminals who have no other connection with the facility but enter to commit robbery or another crime

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TYPE 2: Violence directed at employees or providers by patients and their families or others to whom services is provided

TYPE 3: Violence against coworkers, supervisors, or managers by a present or former employee

TYPE 4: Violence committed in the workplace by someone who doesn’t work there, but has a personal relationship with an employee—an abusive spouse or domestic partner

Violence Prevention Program

STEP 1. Management Commitment and Worker Participation

Management commitment and worker participation are essential elements of an effective violence prevention program. Appropriate authority and resources must be allocated to all responsible parties to include access to information, personnel, time, training, tools and equipment. A system of accountability must be maintained for managers, supervisors and staff. Establish a comprehensive program of medical and psychological counseling and debriefing for workers who have experienced or witnessed assaults and other violent incidents. Establish policies that ensure the reporting, recording and monitoring of Incident and near misses no reprisals are made against anyone who does so in good faith.

Staff should participate in the development, implementation, evaluation and modification for the workplace violence prevention program. Ensure that the perspective of front line staff are included in the policies. Identify the daily activities that staff, including contract workers, believe to put them most at risk for workplace violence. Include procedures to ensure that staff are not retaliated against for voicing concerns or reporting injuries. Conduct training and continuing education programs.

Once you have customized this plan, disseminate it to managers, supervisors, and coworkers. Post a sign notifying clients, patients, and visitors that this facility maintains a zero-tolerance for workplace violence, verbal and nonverbal threats, and related actions.

STEP 2. Worksite Analysis and Hazard Identification

A worksite analysis involves a mutual step-by-step assessment to find existing or potential hazards that may lead to incidents of workplace violence. Cooperation between staff and employers in identifying and assessing hazards is the foundation of a successful violence prevention program. Although management is responsible for controlling hazards, staff have a critical role to play in helping to identify and assess workplace hazed because of their knowledge and familiarity with facility operations, process activities and potential threats. The assessment should include a review of incident reports and near miss events. This assessment will serve as the basis for training and education. Some facilities will determine that a comprehensive annual worksite analysis should be conducted but require that an investigative analysis occur after every incident or near miss.

Complete the Risk Factors for Workplace Violence Checklist. This checklist was adapted by OSHA from the California Department of Human Resource workplace violence prevention program.

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Occupational Safety and Health Administration3 0

■ Keeping up-to-date records of administrative and work practice changes to prevent workplace violence to evaluate how well they work;

■ Surveying workers before and after making job or worksite changes or installing security measures or new systems to determine their effectiveness;

■ Tracking recommendations through to completion;

■ Keeping abreast of new strategies available to prevent and respond to violence in the healthcare and social service fields as they develop;

■ Surveying workers periodically to learn if they experience hostile situations in performing their jobs;

■ Complying with OSHA and state requirements for recording and reporting injuries, illnesses, and fatalities; and

■ Requesting periodic law enforcement or outside consultant review of the worksite for recommendations on improving worker safety.

Workplace Violence Program Checklists

These checklists can help you or your workplace violence/crime prevention committee evaluate the workplace and job tasks to identify situations that may place workers at risk of assault. It is not designed for a specific industry or occupation, and may be used for any workplace. Adapt the checklist to fit your own needs. It is very comprehensive and not every question will apply to your workplace—if the question does not apply, either delete or write “N/A” in the NOTES column. Add any other questions that may be relevant to your worksite.

1 . RISK FACTORS FOR WORKPLACE VIOLENCE

Cal/OSHA and NIOSH have identified the following risk factors that may contribute to violence in the workplace. If you have one or more of these risk factors in your workplace, there may be a potential for violence.

Guidelines for Preventing Workplace Violence for Healthcare and Social Service Workers3 1

YES NO Notes/Follow-up Action

Do employees have contact with the public?

Do they exchange money with the public?

Do they work alone?

Do they work late at night or during early morning hours?

Is the workplace often understaffed?

Is the workplace located in an area with a high crime rate?

Do employees enter areas with a high crime rate?

Do they have a mobile workplace (patrol vehicle, work van, etc.)?

Do they deliver passengers or goods?

Do employees perform jobs that might put them in conflict with others?

Do they ever perform duties that could upset people (deny benefits, confiscate property, terminate child custody, etc.)?

Do they deal with people known or suspected of having a history of violence?

Do any employees or supervisors have a history of assault, verbal abuse, harassment, or other threatening behavior?

Other risk factors – please describe:

2 . INSPECTING WORK AREAS

■ Who is responsible for building security?

■ Are workers told or can they identify who is responsible for security? Yes No

You or your workplace violence/crime prevention committee should now begin a “walkaround” inspection to identify potential security hazards. This inspection can tell you which hazards are already well controlled, and what control measures need to be added. Not all of the following questions may be answered through simple observation. You may also need to talk to workers or investigate in other ways.

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Guidelines for Preventing Workplace Violence for Healthcare and Social Service Workers3 1

YES NO Notes/Follow-up Action

Do employees have contact with the public?

Do they exchange money with the public?

Do they work alone?

Do they work late at night or during early morning hours?

Is the workplace often understaffed?

Is the workplace located in an area with a high crime rate?

Do employees enter areas with a high crime rate?

Do they have a mobile workplace (patrol vehicle, work van, etc.)?

Do they deliver passengers or goods?

Do employees perform jobs that might put them in conflict with others?

Do they ever perform duties that could upset people (deny benefits, confiscate property, terminate child custody, etc.)?

Do they deal with people known or suspected of having a history of violence?

Do any employees or supervisors have a history of assault, verbal abuse, harassment, or other threatening behavior?

Other risk factors – please describe:

2 . INSPECTING WORK AREAS

■ Who is responsible for building security?

■ Are workers told or can they identify who is responsible for security? Yes No

You or your workplace violence/crime prevention committee should now begin a “walkaround” inspection to identify potential security hazards. This inspection can tell you which hazards are already well controlled, and what control measures need to be added. Not all of the following questions may be answered through simple observation. You may also need to talk to workers or investigate in other ways.

Occupational Safety and Health Administration3 2

All Areas

Some Areas

Few Areas

No Areas

NOTES/FOLLOW-UP ACTION

Are nametags or ID cards required for employees (omitting personal information such as last name and home address)?

Are workers notified of past violent acts in the workplace?

Are trained security and counseling personnel accessible to workers in a timely manner?

Do security and counseling personnel have sufficient authority to take all necessary action to ensure worker safety?

Is there an established liaison with state police and/or local police and counseling agencies?

Are bullet-resistant windows or similar barriers used when money is exchanged with the public?

Are areas where money is exchanged visible to others who could help in an emergency? (For example, can you see cash register areas from outside?)

Is a limited amount of cash kept on hand, with appropriate signs posted?

Could someone hear a worker who calls for help?

Can employees observe patients or clients in waiting areas?

Do areas used for patient or client interviews allow co-workers to observe any problems?

Are waiting areas and work areas free of objects that could be used as weapons?

Are chairs and furniture secured to prevent their use as weapons?

Is furniture in waiting areas and work areas arranged to prevent entrapment of workers?

Are patient or client waiting areas designed to maximize comfort and minimize stress?

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Occupational Safety and Health Administration3 2

All Areas

Some Areas

Few Areas

No Areas

NOTES/FOLLOW-UP ACTION

Are nametags or ID cards required for employees (omitting personal information such as last name and home address)?

Are workers notified of past violent acts in the workplace?

Are trained security and counseling personnel accessible to workers in a timely manner?

Do security and counseling personnel have sufficient authority to take all necessary action to ensure worker safety?

Is there an established liaison with state police and/or local police and counseling agencies?

Are bullet-resistant windows or similar barriers used when money is exchanged with the public?

Are areas where money is exchanged visible to others who could help in an emergency? (For example, can you see cash register areas from outside?)

Is a limited amount of cash kept on hand, with appropriate signs posted?

Could someone hear a worker who calls for help?

Can employees observe patients or clients in waiting areas?

Do areas used for patient or client interviews allow co-workers to observe any problems?

Are waiting areas and work areas free of objects that could be used as weapons?

Are chairs and furniture secured to prevent their use as weapons?

Is furniture in waiting areas and work areas arranged to prevent entrapment of workers?

Are patient or client waiting areas designed to maximize comfort and minimize stress?

Occupational Safety and Health Administration3 2

All Areas

Some Areas

Few Areas

No Areas

NOTES/FOLLOW-UP ACTION

Are nametags or ID cards required for employees (omitting personal information such as last name and home address)?

Are workers notified of past violent acts in the workplace?

Are trained security and counseling personnel accessible to workers in a timely manner?

Do security and counseling personnel have sufficient authority to take all necessary action to ensure worker safety?

Is there an established liaison with state police and/or local police and counseling agencies?

Are bullet-resistant windows or similar barriers used when money is exchanged with the public?

Are areas where money is exchanged visible to others who could help in an emergency? (For example, can you see cash register areas from outside?)

Is a limited amount of cash kept on hand, with appropriate signs posted?

Could someone hear a worker who calls for help?

Can employees observe patients or clients in waiting areas?

Do areas used for patient or client interviews allow co-workers to observe any problems?

Are waiting areas and work areas free of objects that could be used as weapons?

Are chairs and furniture secured to prevent their use as weapons?

Is furniture in waiting areas and work areas arranged to prevent entrapment of workers?

Are patient or client waiting areas designed to maximize comfort and minimize stress?

Guidelines for Preventing Workplace Violence for Healthcare and Social Service Workers3 3

All Areas

Some Areas

Few Areas

No Areas

NOTES/FOLLOW-UP ACTION

Are patients or clients in waiting areas clearly informed how to use the department’s services so they will not become frustrated?

Are waiting times for patient or client services kept short to prevent frustration?

Are private, locked restrooms available for employees?

Is there a secure place for workers to store personal belongings?

3 . INSPECTING EXTERIOR BUILDING AREAS

Yes No NOTES/FOLLOW-UP ACTION

Do workers feel safe walking to and from the workplace?

Are the entrances to the building clearly visible from the street?

Is the area surrounding the building free of bushes or other hiding places?

Is lighting bright and effective in outside areas?

Are security personnel provided outside the building?

Is video surveillance provided outside the building?

Are remote areas secured during off shifts?

Is a buddy escort system required to remote areas during off shifts?

Are all exterior walkways visible to security personnel?

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Guidelines for Preventing Workplace Violence for Healthcare and Social Service Workers3 3

All Areas

Some Areas

Few Areas

No Areas

NOTES/FOLLOW-UP ACTION

Are patients or clients in waiting areas clearly informed how to use the department’s services so they will not become frustrated?

Are waiting times for patient or client services kept short to prevent frustration?

Are private, locked restrooms available for employees?

Is there a secure place for workers to store personal belongings?

3 . INSPECTING EXTERIOR BUILDING AREAS

Yes No NOTES/FOLLOW-UP ACTION

Do workers feel safe walking to and from the workplace?

Are the entrances to the building clearly visible from the street?

Is the area surrounding the building free of bushes or other hiding places?

Is lighting bright and effective in outside areas?

Are security personnel provided outside the building?

Is video surveillance provided outside the building?

Are remote areas secured during off shifts?

Is a buddy escort system required to remote areas during off shifts?

Are all exterior walkways visible to security personnel?

Occupational Safety and Health Administration3 4

4 . INSPECTING PARKING AREAS

Yes No NOTES/FOLLOW-UP ACTION

Is there a nearby parking lot reserved for employees only?

Is the parking lot attended or otherwise secured?

Is the parking lot free of blind spots and is landscaping trimmed back to prevent hiding places?

Is there enough lighting to see clearly in the parking lot and when walking to the building?

Are security escorts available to employees walking to and from the parking lot?

5 . SECURITY MEASURES

Does the workplace have: In

PlaceShould

AddDoesn’t Apply NOTES/FOLLOW-UP ACTION

Physical barriers (plexiglass partitions, bullet-resistant customer window, etc.)?

Security cameras or closed-circuit TV in high-risk areas?

Panic buttons?

Alarm systems?

Metal detectors?

Security screening device?

Door locks?

Internal telephone system to contact emergency assistance?

Telephones with an outside line programmed for 911?

Two-way radios, pagers, or cellular telephones?

Security mirrors (e.g., convex mirrors)?

Secured entry (e.g., “buzzers”)?

Personal alarm devices?

“Drop safes” to limit the amount of cash on hand?

Broken windows repaired promptly?

Security systems, locks, etc. tested on a regular basis and repaired promptly when necessary?

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Occupational Safety and Health Administration3 4

4 . INSPECTING PARKING AREAS

Yes No NOTES/FOLLOW-UP ACTION

Is there a nearby parking lot reserved for employees only?

Is the parking lot attended or otherwise secured?

Is the parking lot free of blind spots and is landscaping trimmed back to prevent hiding places?

Is there enough lighting to see clearly in the parking lot and when walking to the building?

Are security escorts available to employees walking to and from the parking lot?

5 . SECURITY MEASURES

Does the workplace have: In

PlaceShould

AddDoesn’t Apply NOTES/FOLLOW-UP ACTION

Physical barriers (plexiglass partitions, bullet-resistant customer window, etc.)?

Security cameras or closed-circuit TV in high-risk areas?

Panic buttons?

Alarm systems?

Metal detectors?

Security screening device?

Door locks?

Internal telephone system to contact emergency assistance?

Telephones with an outside line programmed for 911?

Two-way radios, pagers, or cellular telephones?

Security mirrors (e.g., convex mirrors)?

Secured entry (e.g., “buzzers”)?

Personal alarm devices?

“Drop safes” to limit the amount of cash on hand?

Broken windows repaired promptly?

Security systems, locks, etc. tested on a regular basis and repaired promptly when necessary?

Guidelines for Preventing Workplace Violence for Healthcare and Social Service Workers3 5

6 . COMMENTS

Checklist completed by: Date:

Department/Location:

Phone Number:

Workplace Violence Prevention Program Assessment Checklist

Use this checklist as part of a regular safety and health inspection or audit to be conducted by the Health and Safety, Crime/Workplace Violence Prevention Coordinator, or joint labor/management committee. If a question does not apply to the workplace, then write “N/A” (not applicable) in the notes column. Add any other questions that may be appropriate.

Yes No NOTES

STAFFING

Is there someone responsible for building security?

Who is it?

Are workers told who is responsible for security?

Is adequate and trained staffing available to protect workers who are in potentially dangerous situations?

Are there trained security personnel accessible to workers in a timely manner?

Do security personnel have sufficient authority to take all necessary action to ensure worker safety?

Are security personnel provided outside the building?

Is the parking lot attended or otherwise secure?

Are security escorts available to walk employees to and from the parking lot?

Source: Occupational Safety and Health Administration.

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A periodic inspection of the workplace should evaluate new or revised tasks in order to identify hazards, conditions, activities and situations that could lead to potential violence. Information is often collected through injury and incident report analysis, job hazard analysis, employee surveys, and patient surveys.

Records Analysis and Tracking

Medical records and incident report reviews are important to identify patterns of assaults or near misses that could be prevented or reduced through the implementation of appropriate controls. Include medical, safety, specific threat assessments, workers’ compensation, and insurance records. Incident and near miss reports provide valuable trending information that might be missed in the day-to-day activities of a busy facility.

Job Hazard Analysis

A job hazard analysis focuses on job tasks to identify hazards.It examines the relationship between the staff, the task, tolls and work environment. Priority analysis should be given to: Jobs with high assault rates due to workplace violence Jobs that are new to the facility or have undergone procedural changes that may increase

the potential for workplace violence Jobs that require written instructions, such as procedure for administering medication and

steps for transferring patients

After an incident or near miss, the analysis should focus on:Analyzing those positions that were affected; Identifying if existing procedure and operations were followed, and if not, who not (in

some instances, not following procedures could result in more effective protections); Identifying if staff were adequately qualified and /or trained for the tasks required; andDeveloping, if necessary, new procedures and operations to improve staff safety and

security.

Staff Surveys

Staff surveys or questionnaires are effective ways for employers to identify potential hazards that may lead to violent incidents, identify the types of problems faced by workers and asses the effects of change in the work processes. Baseline surveys can help pinpoint tasks that put workers at risk. Periodic surveys conducted annually or whenever takes change or there is an incident, could help identify new or previously unnoticed risk factors and deficiencies or failure in work practices.

Sample questions might include:What daily activities, if any, expose you to the greatest risk of violence?What, if any, work activates make you feel unprepared to respond to a violent action?Can you recommend any changes or additions to the workplace violence training

you received?

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STEP 3: Hazard Prevention and Control

After completing the systematic worksite analysis, the employer should take appropriate steps to prevent or control the hazards that were identified.

Substitution

The best way to eliminate a hazard is to substitute a safer work practice. While this may be challenging, referring or transferring a patient to a more appropriate setting might be an example.

Engineering Controls and workplace adaptations to minimize risk

Engineering controls are physical changes that either remove the hazard from the work- place or create a barrier between the worker and the hazard. Engineering controls include: Using a physical barrier (such as enclosures or guards) or door locks to reduce employee

exposure to the hazardMetal detectorsPanic buttonsBetter or additional buttonsMore accessible exits (where appropriate)

The measures taken should be site specific and based on the hazards identified in the worksite analysis. If any modifications are planned for a facility, assess any plans to eliminate or reduce security hazards.

Check off which of the following facility guidelines have been implemented to reduce violence. Base decisions to adopt some or all of these activities/protocols/techniques based on actual or perceived risk:

___ Use closed-circuit video continuous recordings for high-risk areas ___ Routinely test and maintain mechanical devices utilized for security and safety to

ensure effectiveness. ___ Lock all unused doors to limit access (from the outside), in accordance with fire

code regulations.___ Install bright and effective lighting systems indoors and outdoors.___ Provide employee “safe rooms” for use in emergency situations.___ Place curved mirrors or cameras at hallway intersections or concealed areas, and

ensure bright lighting.___ Install deep service areas and/or enclosed nurses’ stations, using bullet-resistant,

shatterproof glass in reception areas, triage, or client service rooms.___ Install silent alarms. If this is cost-prohibitive, consider emergency signaling or

monitoring systems.___ Provide metal detectors–either installed or hand-held–to identify weapons.___ Provide panic buttons, hand-held alarms, cellular phones, and private radio channels so

employees can get help when they need it in emergency situations.

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___ Rearrange furniture and other objects to minimize their use as weapons so that individuals are not trapped or hurt in potentially violent situations.

___ Use drop safes to minimize cash on hand.___ Post signs announcing that limited (or no) cash is on hand.___ Provide comfortable waiting rooms (client or patient) designed to minimize stress.___ Design the triage area and other public areas to minimize the risk of assault.___ Provide lockable and secure bathrooms for staff members separate from patient/client

and visitor facilities.___ Establish “time-out” or seclusion areas with high ceilings without grids for patients who

“act out.” ___ Ensure that counseling or patient care rooms have two exits.___ Ensure cabinets and syringe drawers have working locks.___ Pad or replace sharp edged objects (such as metal table frames)

Smooth down or cover any sharp surfaces. ___ Consider changing or adding materials to reduce noise in certain areas. ___ Replace all burned out lights immediately.

Administrative and work practice controls

Administrative and work practice controls are appropriate when engineering controls are not feasible or completely protective. These controls affect the way staff perform jobs and tasks. Changes in work practices and administrative procedures can help prevent violent incidents.

Check off which of the following administrative actions have been implemented to avoid violence, or tailor some of these prevention techniques for your particular workplace situation and needs:

___ Prohibit weapons from the facility.___ Clearly stating to patients, visitor and staff that violence is not permitted and will not be

tolerated. Such a policy makes it clear to staff that assaults are not considered part of the job or acceptable behavior.

___ Have facility security (or police) routinely check on workers and escort them to the parking area after dark.

___ Instruct employees to remain vigilant and to report anything unusual.___ Work with local police to establish liaison and response mechanisms for police

assistance when calls are made for help.___ Recognize and act on legitimate complaints regarding overbearing physicians,

managers and supervisors.___ Consider potentially volatile interoffice occurrences with employees, supervisors or

employers when designing specific prevention techniques. ___ Train employees in restraining techniques. ___ Train employees in developing sensitivity to racial/ethnic issues and differences that

may have causal connections with violent behavior.

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___ Provide regular dialogue on workplace violence during staff meetings and other forums to communicate feelings, gain support and share innovative ideas. Survey employees to determine perceived risk factors present in the workplace.

___ Provide group therapy for staff with particularly difficult patients or a significant event.___ Provide adequate staffing, particularly during times of increased patient activities or

during restraining procedures.___ Escort patients to and from waiting rooms. Do not permit patients to move about

unsupervised.___ Instruct employees to carry only small amounts of cash.___ Design staffing patterns to prevent personnel from working alone.___ Make it clear that employees should not enter any location where they feel unsafe.___ Provide sensitive and timely information to people waiting in line or in waiting rooms.

Adopt measures to decrease waiting time.___ Establish a list of “restricted visitors” for patients with a history of violence or gang activity. ___ ___

Discourage employees from wearing necklaces or chains to help prevent possible strangulation in confrontational situations.

___ Establish polices and procedure for secured areas and emergency evacuations.___ Use a “buddy system”, especially when person safety may be threatened.___ Advise workers of facility’s procedures for requesting police assistance or filing

charges when assaulted and assist them in doing so, if necessary.___ Provide management support during emergencies. Respond promptly to all complaints.___ Emergency action plans should be developed to ensure that staff know how to call for

help or medical assistance.___ Survey the facility periodically to remove tools or possessions left by visitors or staff

could be used inappropriately by patients.___ Keep desks and work areas free of items, including extra pens and pencils, glass

photo frames, etc.

STEP 4. Training

The Training can:Help raise the overall safety and health knowledge across the facility.Provide employees with the tools needed to identify workplace safety and security

hazards.Address potential problems before they arise and ultimately reduce the likelihood of staff

being assaulted.

The training program should involve all staff, including contracted workers, supervisors and managers. Staff who may face safety and security hazards should receive formal instruction on any specific or potential hazards associated with the job of the facility. Such training may include information on the types of injuries or risks identified during the workplace violence assessment and the methods for controlling specific hazards.

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Every staff member should understand the concept of “universal precautions for violence”, that is, that violence should be expected but can be avoided or mitigated through preparation. Staff should understand the importance of a culture of respect, dignity, and active mutual engagement in preventing workplace violence.

The Guide for Prevention of Workplace Violence (2015) states that new and reassigned staff receive an initial orientation and that every worker receive required training annually. Visiting staff, including physicians, should receive the same training as permanent staff and contract workers.

Provide safety education for employees:Provide in-service education sessions or other opportunities for employees to practice

and improve their skills and confidence. Local police departments often provide free training on how to recognize avoid or diffuse

potentially violent situations.

The following topics provide an outline for baseline training for staff in workplace violence prevention:The workplace violence prevention policyRisk factors that cause or contribute to assaultsPolicies and procedures for documenting patients’ change in behaviorThe location, operation and coverage of safety devices such as alarm system along with

the required maintenance schedules and proceduresEarly recognition of escalating behavior or recognition of warning signs or situations that

may lead to assaultsWays to recognize, prevent tor diffuse volatile situation or aggressive behavior, manage

anger and appropriate use mediationsWays to deal with hostile people other than patients such as relatives and visitorsProper use of safe rooms or areas where staff can find shelter from a violent incidentA standard response action plan for violent situations including the availability of

assistance, response to alarm systems and communication proceduresWays to protect oneself and coworkers, including use of the “buddy system”Policies and procedure for reporting and recordkeepingPolicies and procedures for obtaining medical care, counseling, workers compensation or

legal assistance after a violent episode or injury

Supervisors and managers must be trained to recognize high risk situations so they can ensure that staff are not place in assignments that compromise their safety. Such training should include encouraging workers to report incident and to see the appropriate care after experience a violent incident.

STEP 5. Recordkeeping and program evaluation

Recordkeeping and evaluation of the violence prevention program are necessary to determine its overall effectiveness and identify any deficiencies or changes that should be made. Accurate records of injuries, illnesses, incidents, assaults, hazards, corrective actions, patient histories

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and training can help employers determine the severity of the problem, the effectiveness of the plan and identify training needs. Document findings in safety committee meetings. Record hazard analysis and corrective actions recommended and taken. Record all training programs, attendees and qualification of the trainers.

Violence Prevention Techniques for Medical Facilities

Have employees practice identifying the potential and actual causes of workplace violence and stress. Work on conflict resolution and nonviolent responses. Use role-playing for practice with assessing and managing violent individuals and their victims. Note that typical work activities may arouse anger or fear in some patients and result in acts of violence. Long waits and inability to obtain needed services also contribute to the problem of violence.

What Employees Should do to De-escalate a Potentially Violent Situation

Position yourself so that you have immediate access to an exit. Stand at a right angle rather than directly in front of the person. Don’t invade his or her personal space. A good distance is 3 to 6 feet away.

Project calmness. Move and speak slowly, quietly, and confidently. Don’t use communication styles that produce hostility (hands on hips, arms crossed,

pointing fingers), apathy, coldness, condescending language or inflexibility. Be an empathetic listener. Encourage the person to talk, and listen patiently. Indicate that

you can see he or she is upset.Don’t make sudden movements that can be interpreted as threatening. Don’t challenge, threaten, or dare the individual; don’t belittle the person or make him or

her feel foolish. Don’t criticize or act impatiently toward the agitated individual. Ask for small, specific favors such as asking the person to move to a quieter area

(preferably where there are no objects that can be used as weapons). Don’t attempt to bargain with a threatening person. Establish ground rules if unreasonable behavior persists. Calmly describe the

consequences of any violent behavior. Use delaying tactics to give the person time to calm down; for example, offer a drink

of water.Don’t try to impart a lot of technical or complicated information when emotions are

running high. Don’t take sides or agree with distortions.Repeat back to him what you feel he or she is requesting of you. Don’t make false

statements or promises you can’t keep. Be aware of anything in the room that can be used as a weapon.

If a Violent Situation Cannot be Defused Quickly:

Remove yourself from the situation—get to a safe place.Call for help.Report violent incidents to management.

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PART 2:

If a Violent Incident Occurs

STEP 1. Make calls for help as needed using 911, or according to other emergency protocols made by your facility

This facility’s emergency protocol is _______________________________________________________________________________________________________________

STEP 2. Encourage employees to promptly report all incidents of aggressive behavior (e.g., pushing, threatening, etc.) to _____________________________________, even if there were no injuries.Document all incidents and threats of workplace violence and promptly report violent

incidents to the local police department.Require records of incidents or near-incidents to assess risk and to measure progress. Investigate all violent incidents and threats. Monitor trends in violent incidents by type or

circumstance. Institute corrective actions to reduce or eliminate future risks.

STEP 3. Inform victims of workplace violence of their legal right to prosecute perpetrators.Provide assistance in making a report to the appropriate law enforcement agency. Employees may not be discouraged or coerced when making reports or filing worker’s

compensation claims.

STEP 4. Provide prompt medical evaluation and treatment for employees whenever an assault takes place regardless of severity.

STEP 5. Maintain records concerning the assault, including the type of activity (e.g., unprovoked sudden attack, patient-to-patient altercation), and management of assaultive behavior. Include:Who was assaulted and circumstances of the incident, without focusing on any alleged

wrongdoing of the staff person. A description of the environment, location or any contributing factors, corrective measures

identified, including building design, or other measures needed.

STEP 6. Define your organization’s response to the perpetrator, visitors or patients: ______________________________________________________________________Employee: _____________________________________________________________

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STEP 7. Arrange critical incident stress-debriefing sessions and/or post-trauma counseling services to help workers recover from a violent incident. Healthcare workers, who have been abused by patients, particularly if the attack comes without warning, have reported a full range of problems, including:

Death or severe and life-threatening injuries

Impaired relationships with co-workers and family

Shock Self-blame Post-traumatic stress Disbelief Anger Fear of returning to work Anxiety Disturbed sleep patterns Irritability Headaches Depression Short- and long-term psychological

trauma

Counseling services will be provided by ____________________________________.

STEP 8. Report any act of violence that is recordable and which results in a fatality or in any employee being hospitalized to OSHA by telephone (800-321-OSHA) within 8 hours of the incident.

More Sources for Prevention of Workplace Violence

NIOSH Tips For Developing A Violence Prevention Programwww.cdc.gov/niosh/violpurp.html

OSHA Publication, “Guidelines for Preventing Workplace Violence for Healthcare and Social Service Workers”. www.osha.gov/Publications/osha3148.pdf

Enforcement Procedures for Investigating or Inspecting Incidents of Workplace Violence, CPL 02-01-052, September, 2011www.osha.gov/OshDoc/Directive_pdf/CPL_02-01-052.pdf

Federal Bureau of Investigation Statisticshttp://www.fbi.gov/stats-services/publications/law-enforcement-bulletin/january2011/january-2011-leb.pdf

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First AidMost dental offices have one emergency kit to be used for both employees and patients. Store your first aid kit in a convenient area for emergency access and include the following (your workplace could have additional hazards that necessitate extra components):

First Aid KitRequired Equipment: Absorbent Compress, 32 sq. in. with no side smaller than 4 in. (1)Adhesive Bandages, 1 x 3 in. (16)Adhesive Tape, 2-5 yds. (1)Antiseptic, 0.5 g (0.14 fl. oz.) application (10)Burn Treatment, 0.5 g (.014 fl. oz.) application (6)Medical Exam Gloves (4)Sterile Pad, 3 x 3 in. (4)Triangular Bandage, 40 x 40 x 56 in. (1)Directions for requesting emergency assistance (if a caregiver is not available)/

First Aid Guide

Recommended Contents (Not required but should be considered) Analgesic/Pain Reliever (i.e. acetaminophen, Aspirin, individually packaged and of

non-drowsy formulation) (16)Antibiotic Treatment 1/32 oz (6)Bandage Compress 2” x 36” (4)Bandage Compress 3” x 36” (2)Bandage Compress 4” x 36” (1)Burn Dressing 4” x 4” (1)Cold Pack (1)Eye Covering, 2.9 sq Inches per eye (2)Eye Wash 1 oz (1)Roller Bandage 4” x 6 yd (1)Roller Bandage 2” x 6 yd (1)Surgical Scissors (1)Emergency Blanket (1)Tweezers (1)Elastic Wraps (2)Splint (1)Automated External Defibrillator (AED)

Source: American National Standards Institute (ANSI). 308.1-2009

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Keep first aid items in a weatherproof container with individual sealed packages for each type of item. Check the contents of the kit monthly to make sure expended or expired items are replaced.

In 29 CFR 1910.151(b), OSHA requires that employers have medical personnel “readily available” for advice and consultation. If there is no nearby (within a 15 minute drive) infirmary, clinic, or hospital that is used for treating all injured employees, then one or more person on every shift in every facility must be adequately trained to render first aid. Persons who render first aid must have a “valid” certificate in first-aid training from the American Red Cross, or equivalent documented training.

Basic First Aid for Common EmergenciesEach type of emergency has its own first aid procedure. Some common situations employees might encounter are:

Bleeding: If someone is bleeding heavily, stop the flow until medical help arrives by applying pressure to pushing on the wound with a cloth or your hand. For deeper cuts, elevate the wound while maintaining pressure.

Broken Bones: Don’t move someone who may have broken bones unless it’s absolutely necessary. Keep the person still and wait for experts to arrive.

Eye Injuries: If chemicals were splashed in the eye, immediately flush with water for at least 15 minutes. Then close the eyes, cover them with a clean cloth, and get medical help. If something is stuck in the eye, keep the person calm until help arrives.

Electrical Shock: Don’t touch a person in contact with a live electric current. Turn off the main electric switch or fuse, or get an electrician to do it if possible. If you must move the person from a live wire, stand on something

dry and use a dry stick or board to push the person off the wire. Never use anything metal, wet, or damp. After the person is removed from the electricity, check for heartbeat and breathing. If necessary and if you are able, administer artificial respiration or CPR.

First Response for anEmployee Injury

Stay calm but act fast. Consult emergency numbers, which should be posted near all phones, for your local ambulance service or call for employees with first-aid training.

Know where first-aid kits are kept.

If you’re unsure of what to do, call for medical help immediately and explain the kind of injury and the location of the victim. Wait with the injured individual.

Don’t move an injured person unless it’s necessary to save his or her life.

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Choking: Ask the person loudly, “Are you choking?” If he or she cannot respond, perform the abdominal thrusts and back blows as recommended by the American Red Cross. If the abdominal thrusts and back blows do not work and the person is unconscious, use your index and middle fingers to try to remove the object from the throat.

Or, place the person on his or her back and push in and up sharply on the abdomen below the rib cage. Don’t stop until the object is dislodged or medical help arrives.

Heart Attack: Although symptoms are not always obvious, do the following if you believe someone is having a heart attack:

Place him or her in a comfortable reclining or sitting position. Loosen tight clothing at the waist and neck. Give oxygen if you have been trained to do so. Ask if the person has medication for the problem that you can give. Keep the person still until help arrives. If the heart stops and you have been trained in CPR, use it, or use a defibrillator if one is

available. Otherwise, wait for help. Waiting can cost a life, so be sure there are at least two members on staff that have been trained in CPR or ACLS (Advanced Cardiac Life Support).

Crash Kit/Cart ComponentsContact your state dental board for specific requirements regarding cardiac response items to be immediately available when conscious sedation, deep sedation or general anesthesia is performed. Contact the American Heart Association Advanced Cardiac Life Support Manual (www.heart.org) or the American College of Emergency Physicians (www.acep.org) for the latest recommendations for crash cart contents.

If you have a crash cart in the facility, inventory monthly to ensure expired medications are replaced.

Stand behind the victim with your arms around his or her waist. Make a fist with one hand and place it, thumb side in, against victim’s stomach between the navel and the ribs. Grab your fist with your other hand. Pull in and up sharply and repeat as necessary.

Abdominal Thrusts

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