OSHA pandemic guidance reinforces need to plan
Guidance serves as valuable reminder for ED
Newly published guidance from the Occupational Safety and Health Administration (OSHA) on preparation for the possibly debilitating effects of an influenza pandemic serves as a valuable reminder to ED managers of just how vulnerable their departments could be during such an event.
Despite the fact that this is "only" a guidance, it should nevertheless be taken seriously by ED managers, experts say. "Unlike other OSHA documents, it's not regulatory," notes Betsy Hackman, RN, CIC, director of infection control for Emory Healthcare in Atlanta. "It's telling us what we need to do in the face of a pandemic."
James J. Augustine, MD FACEP, director of clinical operations at Emergency Medicine Physicians, an emergency physician partnership group based in Canton, OH, says, "This is a good step by the federal government — an attempt to give guidance on what it considers good hygiene practices and preventive measures for health care employees."
Such a guidance is a good idea, Augustine says, "because oftentimes [OSHA] gets to see and identify best practices in a way no one else can do, to find out what does and doesn't work effectively, and then allow us to deal with the bigger issue: keeping employees safe."
EDs are one of the "prime targets" of the guidance, says Peter Kelly, JD, a partner in the Chicago-based law firm Vedder Price, which has created a pandemic preparedness task force to help clients address pandemic-related legal issues. EDs "are in the hierarchy of organizations that are at very high exposure risk because they will be exposed to those infected," Kelly says. On other hand, because EDs recognize this status, many already use protective equipment in terms of masks, globes, shields, and so forth, "so much of what is noted by the guidance is already in use," he says.
The guidance, however, does go farther than recommending the equipment to be provided; it also says it should be properly fitted and periodically refitted; properly and consistently worn, maintained, and replaced; and properly removed and disposed of.
Addressing absenteeism
Kelly and Augustine agree that the areas of the guidance of greatest value to the ED manager are probably those that deal with absenteeism. "There are a number of issues that have to be planned for," notes Kelly. "For example, many are predicting that in a pandemic, the [health care] employer may lose 40%-50% of their work force."
Cross-training is one strategy recommended by the guidance that could help offset this loss of staff, Kelly says. "The guidance says that each task should be understood and able to be performed by three or four different employees to account for absenteeism," he notes.
Absenteeism, he adds, may not only arise as a result of workers who are infected, but also as a result of workers who have family members who are infected. "It's important that management have policies and plans that encourage infected employees to stay home and not come to work," says Kelly.
Augustine agrees. "You should definitely encourage [sick] staff to stay at home," he says. This guidance not only involves absenteeism, but a concept that may not be familiar to all ED managers, called "presenteeism" — employees coming to work when they are not at their best, he says.
"If people feel they have to come to work to get paid, to be thought of as a team player, or in order not to lose their job, they might bring disease to the worksite," he explains. To avoid presenteeism, "you need to establish an illness program that allows them to call in sick and not be penalized," he says. Typically, such policies are hospitalwide, Augustine says. If your facility does not already have such a policy in place, lobby for one, he advises.
Finally, notes Augustine, absenteeism will be greater if employees are unsure they will be safe at work. "ED managers must think ahead about the feelings of employees when they come to work," he says. "This is a critical piece."
Augustine notes that in 2001, when workers in several facilities had to deal with the reality and/or threat of anthrax, smallpox, and severe acute respiratory syndrome (SARS), "We realized what a huge amount of stress there is on an employee, and that if you do not make them feel safe, they are not going to come to work," he says. "It's really important to look ahead, to decide to educate our employees, and do what is necessary to reinforce their confidence in the worksite."
Liability limited
Because the guidance itself is not mandatory, and there are no specific requirements that would apply, there is no direct potential liability linked to it, says Kelly.
"On the other hand, OSHA does have a 'general duty clause,' that contains a generic requirement to maintain a workplace that is free of hazards that could expose employees to serious injury or fatality," he says. "I could possibly foresee a situation where a particular employer or manager could act in such a way as to completely disregard the risks associated with pandemic — like requiring sick employees to come in — thereby exposing others to a potentially fatal illness, or failing to have common-sense quantities of sanitizers, gloves, and so forth."
While such an event seems unlikely, Augustine says the ED manager should remain on top of infection control procedures. "For EDs, we need to think about the patients who will be coming in ahead of time," he says. "Good ED managers have established respiratory programs that involve, for example, having Kleenex, alcohol-based hand washes, and instructions available at the ED entrance." Universal respiratory etiquette, which involves practices such as coughing into one's elbow and asking family members who are ill not to come into the ED, is followed, he says.
ED managers also should seek to increase use of masks, says Augustine. "We have gotten very, very, very generous recently about putting masks on patients," he notes. "This is a fabulous addition to the ED armament, because we will then not be infesting the room with patients' germs." It's more than OK to ask people with respiratory illness to cover their mouths, wear masks, and take similar precautions, Augustine adds.
"The bottom line for ED manager is to reinforce day-to-day use of personal protective equipment and infection control procedures so when the next outbreak of disease occurs, the staff will face it with the knowledge that the hospital and their manager will be taking care of them," he says.
Prepare well in advance, he concludes. "If you wait until an outbreak, you will not have a ghost of a chance," Augustine warns.
Kelly echoes his concerns. "I think it's important for an ED manager to read this guidance, to assess the potential for a pandemic to adversely affect his department, to do some planning and training, anticipate situations, and think about what policies should be applied in their ED," he says.
Finally, work within the framework of your facility's overall emergency preparedness plan, Hackman says. "It would be difficult for an ED manager to go off on their very own and do all the things OSHA says to do," she observes.
Sources/Resource
For more information on the new guidance on pandemic preparedness, contact:
- James J. Augustine, MD, FACEP, Director of Clinical Operations, Emergency Medicine Physicians, 4535 Dressler Road, Canton, OH 44718. Phone: (330) 493-4443. E-mail: [email protected].
- Betsy Hackman, RN, CIC, Director of Infection Control, Emory Healthcare, Atlanta. Phone: (404) 778-7777.
- Peter Kelly, JD, Partner, Vedder Price, Chicago. Phone: (312) 609-7875.
To read the entire Occupational Safety and Health Administration report "Guidance on Preparing Work-places for an Influenza Pandemic," issued February 2007, go to www.osha.gov/Publications/OSHA3327pandemic.pdf.
Newly published guidance from the Occupational Safety and Health Administration (OSHA) on preparation for the possibly debilitating effects of an influenza pandemic serves as a valuable reminder to ED managers of just how vulnerable their departments could be during such an event.You have reached your article limit for the month. Subscribe now to access this article plus other member-only content.
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