5 Keys to OSHA Compliance

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Keeping your employees safe on the job.


Surgical facilities have topped the annual list of industries reporting 100,000 or more work-related injuries and illnesses for 4 years running, according to the CDC. Here are 5 tips toward fostering a safer surgical facility.

1. Don't assume you're immune
Think it's unlikely you'll ever have to answer to federal or state authorities for your facility's safety lapses? Think again. "I think one of the biggest misconceptions that healthcare administrators hold is that they don't think OSHA will come visiting," says Luke A. Petosa, MSc, HEM, HEM-CC, a management education and training director for the ECRI Institute, a Plymouth Meeting, Pa.-based non-profit healthcare research group.

In fact, it's more likely than ever. "Under the current administration, OSHA is ratcheting up enforcement more than it has in the past decade," he says, noting that the federal agency has increased its hiring of compliance officers over the past 9 months. "This will translate to more site inspections, and perhaps more citations."

Healthcare providers may not see themselves as exposed to the same magnitude of occupational risks as construction or manufacturing workers are, says Mr. Petosa. But a tip from a concerned employee or a trend observed in the annual injury and illness log many employers must submit to OSHA can still summon inspectors. "And once they're in the door on the reported matter, anything's fair game," he says.

If violations are found, the resulting penalty can range from the demand for a response plan to a fine of hundreds or even thousands of dollars. (On the high end, a "willful violation" of OSHA standards can cost an employer as much as $70,000 per citation.)

2. Reach out to resources
OSHA's standards cover a lot of ground. Mastering the healthcare-relevant rules to maintain compliance can prove taxing to busy administrators. Fortun-ately, assistance is available, even through the agency itself. "I know it's a feared name in industry, but my experience in health care has shown me that OSHA is frequently looking to teach," says Don Hougendobler, director of environmental health and safety for the Lehigh Valley Health Network in Allentown, Pa. Some notable examples:

Additionally, you can seek out the on-site advice of an occupational safety consultant or attend professional conferences or training courses on the subject. The U.S. Department of Labor has authorized OSHA Training Institute Education Centers nationwide (www.osha.gov/dte/edcenters/index.html) to provide guidance on compliance. For a surgical facility, an expert source on call or in-depth training could prove a wise investment, says Mr. Petosa. "A handful of citations is going to cost you a heck of a lot more."

3. Find safer alternatives
If unresolved risks are identified, it's imperative that you put safer practices into place. Oftentimes, that's the letter of the law. OSHA's most recent accounting of its citations against general medical and surgical hospitals, a classification that includes ASCs and HOPDs, shows violations of the Bloodborne Pathogens Standard leading the list. According to healthcare safety experts, that's largely attributable to facilities that have failed to evaluate and adopt sharps safety devices and techniques.

While non-surgical areas have seen a 30% decrease in sharps injuries since the standard's Needlestick Safety and Prevention Act component took effect in 2001, surgical areas have seen a 6.5% increase, says Mark Davis, MD, FACOG, an Atlanta-based safety consultant and author. "Standard suture needles cause the majority of sharps injuries," he says, "and these can be easily prevented with blunt-tipped suture needles. [But] only 5% to 10% of surgeons routinely use them, not much of a change from a decade ago," despite OSHA's mandate and professional organizations' endorsements.

Safer practices are a non-negotiable requirement, says Mr. Hougendobler. You've got to show evidence of a concerted effort to trial safety-engineered scalpels, suture needles, reusable scalpel blade removers and passing trays, he says, and you've got to implement an alternative. "Cost guides so many things, but OSHA is not too keen on hearing, 'That costs too much, we didn't try it,'" he says. If clinicians dislike a particular product, acknowledge their input and document their reasons in your facility's bloodborne pathogen exposure control plan, but keep evaluating the options.

4. Spread the word
The key to enacting safer practices is effective training, which involves overcoming tendencies toward human error. Take, for instance, the proper use of personal protective equipment. Your staff wouldn't think of entering an OR where a C-arm was in use without donning lead aprons. "You can't escape radiation if you're in that space," says Monica Ziegler, MSN, CASC, administrator of the Physicians Surgical Center in Lebanon, Pa. But when someone's reprocessing a scope, says Ms. Ziegler, they might think they're careful enough with it that they don't need the full complement of PPEs, "that they won't splash themselves this one time."

Staff training, during orientation and among existing employees, should emphasize safety as a priority every time. PPEs must be worn correctly. Surgical smoke evacuators should be engaged whenever an electrosurgical generator or laser unit is in use. (Smoke plumes aren't specifically mentioned in OSHA's standards, but they can be cited under its General Duty Clause for workplace safety.) Patient lifting, transferring or positioning should be accomplished with an assisting device, or the staffer should ask for help. (Nine states — Illinois, Maryland, Minnesota, New Jersey, New York, Ohio, Rhode Island, Texas and Washington — have passed patient lifting legislation, and federal lawmakers have been considering the subject.) "Don't ever be in too much of a hurry to put yourself at risk," says Mr. Hougendobler. "And make sure your safety practices are consistent among your staff."

Discussing safety issues in staff meetings and on the perioperative floor, providing medical literature on the subject and enlisting the training of vendors can help to raise awareness, as can seeking out staff's own input. Ms. Ziegler recommends you ask your staff to conduct the quarterly environmental safety assessments. "It gives them the opportunity to speak up as to what their working conditions are like," she says. This outlet can help them bring concerns to your attention, and can prevent a potential hazard from reaching the complaint, inspection and citation stage.

5. Look beyond the immediate
Your safety efforts will focus largely on perioperative procedures, but don't neglect the other aspects of your workplace. On OSHA's list of its most frequent citations in surgical facilities, the Bloodborne Pathogens Standard is followed by 3 standards involving the maintenance and upkeep of electrical equipment.

For example, a piece of immobile equipment, such as OR lights, a boom or a surgical table, that's been disassembled for maintenance without having been locked and tagged out of service can easily endanger a staffer's safety, and would trigger an OSHA citation. As would a damaged plug or cord, a failure to replace the cover on an electrical junction box, an obscured EXIT sign or a box-cluttered corridor.

Be sure to review the relevant occupational health and safety regulations and develop safety policies not just with your clinical staff, but also with biomedical personnel, housekeepers and every employee. "The reporting of injuries is inconvenient and time-consuming," says Dr. Davis, "but prevention is easy."

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