There are few businesses that must stay on top of government regulations like those that operate in the long-term care sector. Here are several questions regarding the latest Occupational Safety and Health Administration (OSHA) Site-Specific program. Given these scenarios, would your community pass an OSHA inspection today?
Recent Regulatory Updates
A significant change included in the 2009 program includes dividing the primary list of establishments slated for inspection into three sectors: manufacturing, non-manufacturing, and nursing homes (which includes assisted living communities). Rather than use one universal rate for all worksites, OSHA established minimum injury and illness rates for each sector, allowing the agency to inspect even more establishments that exceed the minimum rates specific to that sector. Additionally, some companies that did not answer an OSHA Data Initiative Survey will be added to the inspection as a way to deter non-compliance on reporting measures.
Inspectors also may be on the way to your assisted living community if it shows high injury and illness rates. In September 2009, OSHA announced increased inspections for nursing homes, including organizations under Standard Industrial Classifications (SIC) codes for skilled facilities (SIC 8051); intermediate care facilities (8052), and nursing and personal care facilities (8059). Assisted living communities are included in SIC 8059. Organizations with high injury and illness rates should prepare for an inspection in the next year. The OSHA program covers organizations with 10 or more employees.
Personal care communities and nursing homes reportedly are being targeted because of injuries sustained transferring and lifting residents. These injuries can be serious and take time and medical intervention to treat, thus extending days away from work. For the personal care sector, a high illness/ injury rate is considered 17 or more on the DART scale (Days Away, Restricted or Transferred) and 14 or more on the DAFW scale (Days Away from Work). OSHA has determined that it will visit approximately 300 sites in the SIC 805 category based on their current rates. These include individual locations within multi-location operations and chains.
Inspection Preparation Questions
Here is a list of questions for organizations to ask their locations, assure compliance, and prepare for inspections:
Tuberculosis and Blood Borne Pathogens
- Do your human resource policies and procedures and employee handbook require testing for tuberculosis?
- Are employees trained on blood-borne pathogens upon hire (within 90 days) and annually thereafter to comply with the OSHA requirement?
- Do you have an OSHA-compliant exposure control plan to prevent employee exposures to blood-borne pathogens? Is the program reviewed and updated annually?
- Does your organization have an internal audit function to make sure that employees comply with your policies and procedures and with applicable state and local laws?
- Is training attendance recorded and will records demonstrate that all potentially exposed associates have been trained on blood-borne pathogens and have been offered the hepatitis B vaccination?
- If they received the hepatitis B vaccine, will your documentation show that they received the series of three?
- If an employee declines the vaccine, do you have a dated form signed by the associate indicating that he/she declined?
- Do you offer relevant annual training for associates who have potential blood-borne pathogen exposure? Is this documented?
Ergonomics
- Do you offer frequent training and reinforcement on proper methods of handling people and material?
- Do you reinforce proper body mechanics for lifting and transferring residents?
- Are gait belts used and are associates trained in their use?
- Do you hire physical therapists to provide coaching on handling of typical, challenging, and obese residents and on the proper use of devices?
- Do you have protocols for handling obese (bariatric) residents?
- Although not commonly seen in assisted living communities, are lifting devices available for residents?
- Are associates engaged in peer-review or buddy training on proper body mechanics?
- Is office workstation ergonomic training extended to the administrative staff to prevent musculoskeletal strain and injuries to the upper extremities?
- Are employees trained on the basics of ergonomics to understand neutral posturing to reduce musculoskeletal strain and injury?
Slips, trips, and falls
- Do you have an effective system to keep people away from wet areas?
- Do you have procedures for quickly cleaning up spills?
- Are these protocols carried out consistently?
- Have you considered incorporating a slip-resistant footwear program at your communities?
- Are anti-slip strips installed in strategic places, such as the areas near freezers, refrigerators, and laundry facilities?
The prospect of an inspection is a daunting one, but proper preparation can help ensure the process is as painless as possible. The proactive steps you can take in advance of an OSHA inspection can also lead to lasting improvements in individual communities as well as your overall injury and illness rates.
For additional community level tips and strategies to ensure the best possible inspection, see this article online at ALFApublications.org.
John Atkinson, managing partner, is the practice leader, Senior Housing and Long- Term Care, at Willis of Illinois, Inc.
Feedback
- Share your comments about this article on ALFA
Exchange, an online social networking community for senior
living professionals. - Email your comments using ALFA’s $LC:ACTIONFORM:-12:online
contact form$. - Email [email protected].
