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OSHA COMPLIANCE
IN ASSISTED LIVING AND RESIDENTIAL CARE
2,986,500
Total recordable cases of work
related injury and illness in 2011
4,609
Fatal work-related injuries
458
Homicides
COURSE DESCRIPTION
•
OSHA is increasing the frequency of inspections in
assisted living and residential care.
•
During this 4 hour course we will discuss the latest
trends in OSHA violations, tips for compliance, and
your responsibilities as an administrator/manager.
•
Topics addressed will include injury and illness
prevention programs, bloodborne pathogens,
personal protective equipment, and reporting
requirements.
AGENDA
1) Introduction
Why OSHA matters?
Violations and fines
AGENDA
2) Back and
lifting safety
AGENDA
3) Bloodborne
pathogens
and standard
precautions
AGENDA
4) Personal protective
equipment
AGENDA
5) Emergency and
disaster
preparedness
AGENDA
6) General workplace
safety
AGENDA
7) Hazard communication
AGENDA
8) Recordkeeping
AGENDA
9) Injury and Illness
Prevention Programs
AGENDA
10) Tools, Tips,
and Resources
Introduction to OSHA
INTRODUCTION
About OSHA
•
The Occupational Safety and Health Administration
•
Federal agency created in 1971
•
Ensure safe and healthful working conditions for working
men and women...
•
Most private sector employers are required to follow OSHA
regulations
INTRODUCTION
Why Worry
About OSHA?
•
Your staff are your most
valuable asset
Because you
care about your
employees
•
Reduce work-related injury and
illness
•
Quality matters!
INTRODUCTION
Why Worry
About OSHA?
Because
accidents cost
money
•
Workers compensation
•
Modified duty
•
Overtime for temporary fill-in
staff
•
Cost of recruiting, hiring, and
training new staff
INTRODUCTION
Why Worry
About OSHA?
•
Fine can be thousands of
dollars!
Avoid OSHA
fines!
•
National Emphasis Program
OSHA FINES
•
$87,430,000 in proposed
penalties to BP for the
Gulf of Mexico oil spill
•
Largest fine in OSHA's
history
•
The prior largest total
penalty, $21 million, was
issued in 2005, also
against BP
OSHA FINES
Types of OSHA Violations
•
Regulatory Violation
•
General Violation
•
Serious Violation
OSHA FINES
Types of OSHA Violations
•
Regulatory Violation
•
A violation, other than one defined as Serious or
General that pertains to permit, posting,
recordkeeping, and reporting requirements as
established by regulation or statute.
•
Up to $7,000 per violation
OSHA FINES
Types of OSHA Violations
•
General Violation
•
A violation which is specifically determined not to
be of a serious nature, but has a relationship to
occupational safety and health of employees.
•
Up to $7,000 per violation
OSHA FINES
Types of OSHA Violations
•
Serious Violation
•
Deemed to exist in a place of employment if there
is a substantial probability that death or serious
physical harm could result from a violation
•
Up to $25,000 per violation
INTRODUCTION
National Emphasis Program
•
Implemented by OSHA in 2012F
•
Focus attention and inspections on nursing homes
and assisted living/residential care communities
•
Increased reports of OSHA inspections from
providers
•
http://www.osha.gov/OshDoc/Directive_pdf/CPL_0
3-00-016.pdf
INTRODUCTION
National Emphasis Program
•
Lifting
•
Bloodborne pathogens
•
Tuberculosis
•
Workplace violence
•
Slips, trips and falls
INTRODUCTION
National Emphasis Program
•
“During inspections under this Instruction, the
OSHA-300 logs for the previous three (3) years will
be reviewed.”
•
DART will be calculated
•
If over 5.3 = inspect
DART
DART
•
Days away from work,
•
Days of restricted work activity, or
•
Job transfer
DART
Calculating your DART rate:
Total recordable
cases
# hours worked by
all employees
X
200,000
÷
DART Rate
=
DART
Calculating your DART rate:
Total recordable
cases
2
# hours worked by
all employees
X
200,000
÷
110,000
DART Rate
=
3.6
DART
DART
Back and Lifting Safety
182,270
Cases involving injury to the back
BACK AND LIFTING SAFETY
General lifting safety tips:
•
Avoid manual lifting of residents whenever possible
•
Get help for heavy objects
•
Split into smaller loads if possible
BACK AND LIFTING SAFETY
Posture is critical!
•
Use a wide stance and bend at the knees
BACK AND LIFTING SAFETY
Posture is critical!
•
Move slowly and avoid sudden movements
•
Keep the weight as close to your body as possible
•
Avoid lifting above the waist line
•
Turn the whole body, do not twist
BACK AND LIFTING SAFETY
Get help when you need it:
•
Help from another person
•
Help from a device or mechanical aide
BACK AND LIFTING SAFETY
Gait belts
• Use for transferring residents who are
partially dependent, have some
weight-bearing capacity, are
cooperative
• Use when assisting to ambulate
• More than one caregiver may be
needed
• Do not use to “lift” the resident
• Use good body mechanics and a
rocking and pulling motion rather than
lifting when using a belt
BACK AND LIFTING SAFETY
Gait belts
• May not be suitable for ambulation
of heavy residents or residents
with recent abdominal or back
surgery, abdominal aneurysm, etc
• Ensure belt is securely fastened
• Ensure a layer of clothing is
between residents' skin and the
belt
• Keep resident as close as possible
to caregiver during transfer
BACK AND LIFTING SAFETY
Powered sit-to-stand or
standing assist device
•
Use for transferring residents
who are partially dependent,
have some weight-bearing
capacity, are cooperative, can
sit up on the edge of the bed
with or without assistance, and
are able to bend hips, knees,
and ankles.
BACK AND LIFTING SAFETY
Lift chairs
•
Transferring residents who are
weight-bearing and cooperative
but need assistance when
standing and ambulating.
•
Can be used for independent
residents who need an extra
boost to stand.
•
May not be appropriate for
heavier residents
BACK AND LIFTING SAFETY
Mechanical lifts
•
Lifting residents who are totally
dependent, are partial- or nonweight bearing, are very heavy,
or have other physical
limitations
•
More than one caregiver may be
needed
•
Follow manufacturer instructions
BACK AND LIFTING SAFETY
Draw sheets, transfer boards
•
Use for repositioning
•
More than one caregiver may be
needed
•
Work at waist level when
possible
•
Avoid bending/reaching
•
Synchronize with other
caregivers, which applicable
BACK AND LIFTING SAFETY
Height adjustable bed
•
Follow regulations regarding
bed rails
•
Electric powered preferred
•
Adjustments should be
completed within about 20
seconds to ensure use
BACK AND LIFTING SAFETY
Wheelchair
scale
Transfer
bench
Toilet seat
riser
Grab bars
Bloodborne Pathogens
BLOODBORNE PATHOGENS
•
Infectious microorganisms in human blood that can
cause disease in humans
•
Include hepatitis B (HBV), hepatitis C (HCV) and
human immunodeficiency virus (HIV)
•
Needlesticks and other sharps-related injuries may
expose workers to bloodborne pathogens
BLOODBORNE PATHOGENS
Occupational exposure:
Reasonably anticipated skin, eye, mucous
membrane, or parenteral (piercing mucous
membranes or the skin barrier through such events
as needlesticks, human bites, cuts, and abrasions)
contact with blood or other potentially infectious
materials that may result from the performance of an
employee's duties.
BLOODBORNE PATHOGENS
Who is at risk for occupational exposure in your
workplace?
_____________________________
_____________________________
_____________________________
_____________________________
_____________________________
_____________________________
BLOODBORNE PATHOGENS
Exposure Control Plan (ECP)
• Employers must implement
• Details on employee protection
measures
• Use of engineering and work
practice controls
• Use of personal protective clothing
and equipment
• Training, medical surveillance,
hepatitis B vaccinations, and signs
and labels
BLOODBORNE PATHOGENS
Exposure Control Plan (ECP)
•
A copy must be accessible to employees
•
Must be updated at least annually and whenever
necessary
•
Must include staff training
BLOODBORNE PATHOGENS
Sharps Injury Log
•
Date and time of the exposure incident
•
Type and brand of sharp involved in the exposure
incident
•
Description of the exposure incident
•
Each exposure incident shall be recorded on the
Sharps Injury Log within 14 working days of the date
the incident is reported to the employer
•
Must protect the confidentiality of the injured employee.
BLOODBORNE PATHOGENS
Hepatitis B Vaccines
• Make available the hepatitis B vaccine and vaccination
series to all employees who have occupational
exposure
• Must be made available at no cost to the employee
• Must be made available after training and within 10
days of initial assignment
• Post-exposure evaluation and follow-up for bloodborne
pathogens exposure to all employees who have had an
exposure incident
• Document!
PERSONAL PROTECTIVE EQUIPMENT
•
"Personal Protective Equipment" is specialized
clothing or equipment worn or used by an
employee for protection against a hazard.
•
General work clothes (e.g., uniforms, pants, shirts
or blouses) not intended to function as protection
against a hazard are not considered to be personal
protective equipment.
PERSONNEL PROTECTIVE EQUIPMENT
•
Must be provided by the employer
•
Must be readily available to appropriate personnel
•
Maintain appropriate sizes, etc.
•
Provide training in use, donning, and removing
Disaster and Emergency
Preparedness
DISASTER AND EMERGENCY PREPAREDNESS
•
Planning
•
Chain of command
•
Emergency response teams
•
Response activities
•
Training
•
Personal protection
•
Medical assistance
DISASTER AND EMERGENCY PREPAREDNESS
•
Fire
•
Elevator failure
•
Wildfires
•
Bomb threats
•
Earthquakes
•
Workplace violence
•
Hurricanes
•
Tornadoes
•
Floods
•
Power failure
DISASTER AND EMERGENCY PREPAREDNESS
•
Evacuations
•
72-hour self-reliance
•
Staff training
DISASTER AND EMERGENCY PREPAREDNESS
DISASTER AND EMERGENCY PREPAREDNESS
Hazard Communication
HAZARD COMMUNICATION
•
Chemical manufacturers and
importers must prepare labels
and safety data sheets
•
Employers with hazardous
chemicals in their workplaces
must have labels and safety data
sheets for their exposed workers
•
Employers must train staff to
handle the chemicals
appropriately
HAZARD COMMUNICATION
•
Hazard communication program
•
Labels
•
SDS
•
Information and training
HAZARD COMMUNICATION
Labels
•
The manufacturer, importer,
or distributor is required to
label each container of
hazardous chemicals
•
If the hazardous chemicals
are transferred into
unmarked containers, these
containers must be labeled
with the required information
HAZARD COMMUNICATION
Safety Data Sheets (SDS)
•
Provided by chemical manufacturers
•
Indicate possible hazards resulting from use of the
material
•
Must have a SDS for each hazardous substance
used in the workplace
•
Shall be in English
•
Must be readily accessible during each work shift
to employees when they are in their work area(s)
HAZARD COMMUNICATION
•
Do you need to keep MSDSs for commercial
products such as "Windex" and "White-Out"?
OSHA does not require that MSDSs be provided to purchasers of
household consumer products when the products are used in the
workplace in the same manner that a consumer would use them,
i.e.; where the duration and frequency of use (and therefore exposure)
is not greater than what the typical consumer would experience.
This exemption in OSHA's regulation is based, however, not upon the
chemical manufacturer's intended use of his product, but upon how it
actually is used in the workplace. Employees who are required to work
with hazardous chemicals in a manner that results in a duration and
frequency of exposure greater than what a normal consumer would
experience have a right to know about the properties of those
hazardous chemicals.
Globally Harmonized System
WHAT IS THE GLOBALLY HARMONIZED SYSTEM?
•
The Globally Harmonized System of Classification and
Labeling of Chemicals (GHS)
•
International approach to hazard communication, based on
major existing systems around the world, including OSHA's
Hazard Communication Standard
•
Agreed criteria for classification of chemical hazards, and a
standardized approach to label elements and safety data
sheets
•
Updates to OSHA’s Hazard Communication Standard:
https://www.osha.gov/dsg/hazcom/index.html
WHY?
•
Health and safety of workers
•
Standardization
•
Improve information received from other countries
WHO MUST FOLLOW GHS?
•
Chemical manufacturers or importers must classify the
hazards of chemicals which they produce or import
•
Employers must provide information to their employees
about the hazardous chemicals to which they are
exposed, by means of a hazard communication
program, labels and other forms of warning, safety data
sheets, and information and training.
•
Applies to any chemical which is known to be present
in the workplace in such a manner that employees may
be exposed under normal conditions of use or in a
foreseeable emergency.
Due Dates
GHS DUE DATES
December 1, 2013
December 1, 2015
Employee training
Distributors shall not ship
containers without GHS labels
2014
2015
2016
2017
June 1, 2015
Compliance with all
provisions
June 1, 2016
Update alternative
workplace labels
DECEMBER 1, 2013
Requirement
Who
Train employees on the new
label elements and safety
data sheet (SDS) format.
Employers
JUNE 1, 2015
Requirement
Who
Compliance with all modified
provisions of the final rule
Chemical manufacturers,
importers, distributors and
employers
DECEMBER 1, 2015
Requirement
Who
Distributors shall not ship
containers labeled by the
chemical manufacturer or
importer unless it is a GHS
label
Chemical manufacturers,
importers, distributors and
employers
JUNE 1, 2016
Requirement
Who
Update alternative workplace
labeling and hazard
communication program as
necessary, and provide
additional employee training
for newly identified physical or
health hazards.
Employers
PHASE IN PERIOD
•
During the phase-in period, employers are required
to be in compliance with either the existing HCS or
the revised HCS, or both
•
OSHA recognizes that hazard communication
programs will go through a period of time where
labels and SDSs under both standards will be
present in the workplace
•
This will be considered acceptable, and employers
are not required to maintain two sets of labels and
SDSs for compliance purposes
Changes to Hazard Communication
MAJOR CHANGES TO HAZCOM
•
Hazard classification
•
Labels
•
Safety Data Sheets
HAZARD CLASSIFICATION
•
Definitions of hazard have been changed to
provide specific criteria for classification of health
and physical hazards, as well as classification of
mixtures.
•
Ensure that evaluations of hazardous effects are
consistent across manufacturers
•
Ensure that labels and safety data sheets are more
accurate as a result
LABELS
•
Pictograms
•
Signal words: a single word used to indicate the relative level of
severity of hazard and alert the reader to a potential hazard on
the label. "Danger" is used for the more severe hazards, while
"warning" is used for less severe hazards.
•
Hazard Statement: a statement assigned to a hazard class and
category that describes the nature of the hazard(s) of a chemical,
including, where appropriate, the degree of hazard.
•
Precautionary Statement: a phrase that describes
recommended measures to be taken to minimize or prevent
adverse effects resulting from exposure to a hazardous chemical,
or improper storage or handling of a hazardous chemical.
PICTOGRAMS
SAFETY DATA SHEETS
•
Material Safety Data Sheets (MSDS) are now
called Safety Data Sheets (SDS)
•
Information required on the safety data sheet will
remain essentially the same
•
The revised Hazard Communication Standard
(HazCom 2012) requires that the information on
the SDS be presented using specific headings in a
specified sequence
SAFETY DATA SHEETS
•
Section 1. Identification
•
Section 2. Hazard(s) identification
•
Section 3. Composition/information on ingredients
•
Section 4. First-Aid measures
•
Section 5. Fire-fighting measures
•
Section 6. Accidental release measures
•
Section 7. Handling and storage
•
Section 8. Exposure controls/personal protection
SAFETY DATA SHEETS
•
Section 9. Physical and chemical properties
•
Section 10. Stability and reactivity
•
Section 11. Toxicological information
•
Section 12. Ecological information
•
Section 13. Disposal considerations
•
Section 14. Transport information
•
Section 15. Regulatory information
•
Section 16. Other information, including date of
preparation or last revision
Recordkeeping
RECORDKEEPING
•
Employers not exempt
from OSHA's
recordkeeping
requirements must
prepare and maintain
records of work-related
injuries and illnesses.
•
Form 300, 300A, 301
RECORDKEEPING
Exempt if:
•
If you had 10 or fewer employees during all of the
last calendar year, or
•
Your business is classified in a specific low-hazard
retail, service, finance, insurance, or real estate
industry
•
(Unless the Bureau of Labor Statistics or OSHA
informs you in writing that you must do so)
RECORDKEEPING
•
Current and former
employees, or their
representatives, have the
right to access injury and
illness records.
•
Employers must give the
requester a copy of the
relevant record(s) by the
end of the next business
day.
RECORDKEEPING
When is an injury or illness considered work-related?
•
If an event or exposure in the work environment caused or
contributed to the condition or significantly aggravated a
preexisting condition.
•
Work-relatedness is presumed for injuries and illnesses
resulting from events or exposures occurring in the
workplace, unless an exception specifically applies.
•
The work environment includes the establishment and other
locations where one or more employees are working or are
present as a condition of their employment.
RECORDKEEPING
What injuries must be recorded?
•
Record those work-related injuries and illnesses
that result in:
•
Death
•
Loss of consciousness
•
Days away from work
•
Restricted work activity or job transfer
•
Medical treatment beyond first aid
RECORDKEEPING
What injuries must be recorded?
•
You must record any significant work-related injury or illness
that is diagnosed by a physician or other licensed health
care professional.
•
You must record any work-related case involving cancer,
chronic irreversible disease, a fractured or cracked bone, or
a punctured eardrum.
RECORDKEEPING
Form 300
•
Log of Work-Related Injuries and Illnesses
•
Used to list injuries and illnesses and track days
away from work, restricted, or transferred
RECORDKEEPING
RECORDKEEPING
Form 300A
•
Summary of Work-Related Injuries and Illnesses
•
Shows totals for the year in each category
•
Must post from February 1 to April 30 of each year
RECORDKEEPING
RECORDKEEPING
Keeping injury and illness records:
•
Injury and Illness Report (Form 301) to record
supplementary information about recordable cases.
•
You can use a workers' compensation or insurance
form, if it contains the same information.
RECORDKEEPING
http://www.osha.gov/recordkeeping/index.html
Injury and Illness Prevention Programs
INJURY & ILLNESS PREVENTION PROGRAMS
•
Employers are required to
have an effective written
Injury and Illness
Prevention Program (IIPP)
•
An effective IIPP improves
the safety and health in
your workplace.
INJURY & ILLNESS PREVENTION PROGRAMS
An IIPP must :
• Fully involve all employees,
supervisors, and
management
• Identify the specific
workplace hazards
employees are exposed to
• Correct identified hazards in
an appropriate and timely
manner
• Provide effective training
INJURY & ILLNESS PREVENTION PROGRAMS
Your IIPP must include:
• Responsibility
• Compliance
• Communication
• Hazard Assessment
• Accident/Exposure
Investigation
• Hazard Correction
• Training and Instruction
• Recordkeeping
Tools, Tips, and Resources
TOOLS, TIPS, AND RESOURCES
Create a safety
committee
STAFF TRAINING
TOPIC
SUPER. /
MNGRS.
EMP.
FREQUENCY
Employee records
X
X
Initial, annual
Accident investigation and reporting
X
X
Initial
Aerosol transmissible diseases
X
X
Initial, annual
Back safety
X
X
Initial, annual
Bloodborne pathogens
X
X
Initial, annual
Compressed gas
X
X
Initial, as needed
Emergency and disaster planning
X
X
Electrical safety
X
X
Fire safety, prevention
X
X
Ergonomics
X
X
First Aid
X
X
Initial, annual
Initial, as needed
STAFF TRAINING
TOPIC
SUPER. /
MNGRS.
EMP.
FREQUENCY
Flammable and combustible liquids
X
X
Initial, as needed
General safety awareness
X
X
Power tools
X
X
Initial, as needed
Hazard communication
X
X
Initial, annual
OSHA recordkeeping
X
Personal protective equipment
X
X
Initial, as needed
Portable ladder safety
X
X
Initial, as needed
IIPP
X
X
Initial, as needed
Walking and working surfaces
X
X
TOOLS, TIPS, AND RESOURCES
www.osha.gov
TOOLS, TIPS, AND RESOURCES
•
Free consultation service
•
Does not result in citations or penalties
•
http://www.osha.gov/dcsp/smallbusiness/consult.html
TOOLS, TIPS, AND RESOURCES
ANY QUESTIONS?
Quiz
QUESTION #1
OSHA is a ________ agency that was
created in 1971.
a.
State
b.
County
c.
Federal
d.
International
QUESTION #1
OSHA is a ________ agency that was
created in 1971.
a.
State
b.
County
c.
Federal
d.
International
QUESTION #2
Which of the following is not one of the types of
OSHA violations?
a.
Incident
b.
Regulatory
c.
General
d.
Serious
QUESTION #2
Which of the following is not one of the types of
OSHA violations?
a.
Incident
b.
Regulatory
c.
General
d.
Serious
QUESTION #3
Which of the following are important points for back
and lifting safety when training your staff?
a.
Posture
b.
Avoid lifting above the waist line
c.
Ask for assistance from another person
whenever necessary
d.
All of the above
QUESTION #3
Which of the following are important points for back
and lifting safety when training your staff?
a.
Posture
b.
Avoid lifting above the waist line
c.
Ask for assistance from another person
whenever necessary
d.
All of the above
QUESTION #4
A gait belt is an effective tool when helping to pick up
a resident after a fall.
a.
True
b.
False
QUESTION #4
A gait belt is an effective tool when helping to pick up
a resident after a fall.
a.
True
b.
False
QUESTION #5
With regards to blood borne pathogens, ECP stands
for:
a.
Electric Control Posture
b.
Exposure Control Plan
c.
Exposure Containment Program
d.
Extended Control Profile
QUESTION #5
With regards to blood borne pathogens, ECP stands
for:
a.
Electric Control Posture
b.
Exposure Control Plan
c.
Exposure Containment Program
d.
Extended Control Profile
QUESTION #6
HIV vaccines must be made available at no cost to
all employees.
a.
True
b.
False
QUESTION #6
HIV vaccines must be made available at no cost to
all employees.
a.
True
b.
False
QUESTION #7
This liquid combined with water makes a commonly
used and effective disinfectant:
a.
Soap
b.
Windex
c.
Lysol
d.
Bleach
QUESTION #7
This liquid combined with water makes a commonly
used and effective disinfectant:
a.
Soap
b.
Windex
c.
Lysol
d.
Bleach
QUESTION #8
Because of changes in the Globally Harmonized
System, Material Safety Data Sheets (MSDS) are
now called what?
a.
Material Sheets
b.
Safety Data Sheets
c.
Mandatory Data Sheets
d.
Chemical Sheets
QUESTION #8
Because of changes in the Globally Harmonized
System, Material Safety Data Sheets (MSDS) are
now called what?
a.
Material Sheets
b.
Safety Data Sheets
c.
Mandatory Data Sheets
d.
Chemical Sheets
QUESTION #9
Chemical labels must now include which of the
following:
a.
Pictograms
b.
Signal words
c.
Hazard statement
d.
Precautionary statement
e.
All of the above
QUESTION #9
Chemical labels must now include which of the
following:
a.
Pictograms
b.
Signal words
c.
Hazard statement
d.
Precautionary statement
e.
All of the above
QUESTION #10
When does the Form 300A have to be posted?
a.
From February 1 to April 30 of each year
b.
From January 1 to December 31 of each year
c.
From May 1 to May 31 of each year
d.
None of the above
QUESTION #10
When does the Form 300A have to be posted?
a.
From February 1 to April 30 of each year
b.
From January 1 to December 31 of each year
c.
From May 1 to May 31 of each year
d.
None of the above
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