OSHA Cracking Down on Healthcare Facilities

Fit-For-Duty, Miscellaneous, Return to Work, Workers Compensation

On June 25, OSHA announced it was going to focus on injury prevention procedures and equipment used in hospitals and nursing care centers by doing inspections on these facilities to determine whether they are doing what is necessary to keep their employees safe. According to the memo (https://www.osha.gov/dep/enforcement/inpatient_insp_06252015.html), they found “Inpatient healthcare settings to have some of the highest rates of injury and illness among industries for which nationwide injury and illness rates were calculated for Calendar Year 2013…and for every 100 full-time employees, almost twice as high as the rate for private industry as a whole.” Their National Emphasis Program on this industry was completed between 2012 & 2015. The result was that they felt their efforts should continue in reducing hazards such as ergonomic hazards as well as other hazards such as Bloodborne Pathogens, Workplace Violence, and Slips, Trips and Falls. Their effort to reduce these hazards could come in the form of an “alert letter” or worse, citations.

The memo includes guidelines for inspections and mentions that musculoskeletal disorders and overexertion accounted for approximately 44% of the injuries reported. OSHA’s guidelines include employee training (e.g. how to do patient lifts and transfers); use of assistive devices; systems for hazard analysis and identification, etc.

However, there is no mention of the safe physical ability of the healthcare worker at all. While assistive devices, patient hoists, training, employee input and wellness programs are all excellent when implemented correctly, the injury prevention still comes down to the bottom line: is that worker physically able to do the job? If they are not physically able to do the job, none of the other safety initiatives will help.

Lifting assistive devices are a frequent point of contention for several reasons: 1) can all hospitals and nursing facilities afford to have the number of these devices needed to prevent all lift injuries?; 2) for those facilities that do have the equipment available – are they easily accessible to all personnel who need to use them? (e.g. – are they stuck in the back of a storage room somewhere, making it difficult to access in a timely manner?) 3) what about all of the occasions where a patient starts to fall or loses their balance and the healthcare worker is in a position to “catch” them? Training is certainly helpful, but sometimes this happens so quickly that it is definitely a “reflex” reaction on the part of the worker.

Making sure new hires are tested for their physical ability to do the job is the best prevention for future worker’s comp claims. This includes identifying pre-existing medical conditions that could put that worker at risk for injury. It also includes documenting baseline musculoskeletal measurements to use as comparison should the worker get injured later. But don’t stop there – making sure healthcare workers continue to be safe by doing Fit for Duty exams either after injury or as a part of their annual performance evaluation, will also reduce injuries greatly.

OSHA’s memo does not mention any pre-employment or pre-placement testing, yet having this type of program in place can reduce injury costs as much as 50%-80%. I’ve never been part of an OSHA inspection (knock on wood!), but I think it would be safe to say that fewer citations for healthcare facilities will be issued if this type of ADA & EEOC-compliant testing program was in place. Healthcare workers have difficult enough jobs without having to face possible disabling injuries. It’s our job, not OSHA’s, to protect our workers and find the best practices for doing so.