OSHA plan may target health care facilities for wall-to-wall’ inspections
High injury and illness rates will flag high-hazard hospitals
You could be getting an OSHA inspection for Christmas if your hospital has high injury and illness rates, thanks to a new data collection system that identifies and targets high-hazard employers, Hospital Employee Health has learned.
For about the past 10 years, the U.S. Occupational Safety and Health Administration (OSHA) has inspected hospitals mainly in response to complaints from employees or union representatives, but a new method of data collection could change all that, says Rich Fairfax, CIH, director of compliance for OSHA.
OSHA’s new system is based on data collected from 80,000 U.S. employers, including hospitals, to which OSHA sent letters requesting injury and illness information. The agency is using that information to establish what it calls a "high-hazard target system," which will identify individual employers with the highest injury/illness rates.
Scheduled inspections could occur every two years
Targeted employers could receive generally scheduled comprehensive inspections as frequently as every two years, Fairfax says, although a regular interval will not be established. A new list of targeted high-hazard employers will be developed every year. Any employer that has received a comprehensive inspection within the past two years will be dropped from the current list.
Traditionally, OSHA has conducted two types of inspections: complaint inspections and generally scheduled or programmed inspections. Industries receiving the latter type were those OSHA considered "high-hazard" according to Bureau of Labor Statistics injury and illness data. Employers within those industry categories were chosen for inspections randomly from computer-generated lists. However, Fairfax points out that under that system, individual employers with low injury/illness rates at their work sites were sometimes inspected simply because they were part of a high-hazard industry.
"The problem was that a particular establishment might have a good record, but we still had to do the inspection. Within an industry, some employers have good records and some don’t, but the problem with the old system was that we never knew. We wasted our time and the employer’s," he explains.
Fairfax notes that in the late 1980s, when bloodborne pathogens became a hot issue in hospitals, OSHA did conduct programmed inspections and found many violations at first, including "very significant cases" involving penalties of more than $100,000. However, within a few years, violations "dropped off," he says, and the program of generally scheduled inspections in hospitals was scrapped in favor of complaint inspections.
OSHA’s mindset is slowly changing’
Nevertheless, with the new targeting system, some hospitals may be in line for "wall-to-wall" inspections, depending upon where OSHA draws the cutoff line for high injury and illness rates based upon collected data, Fairfax says.
While OSHA has not considered hospitals a high-hazard industry despite high injury/illness rates (see Hospital Employee Health, March 1998, pp. 36-37), "that mindset at OSHA is slowly changing," he says. Although OSHA violations may have decreased in the early 1990s, "now data are coming back to us, and we’re hearing information that there are other problems, so we’re going to go out and revisit the industry."
OSHA began collecting data this spring. After several months of analysis, the agency should be ready to begin comprehensive inspections of "site-specific targets" by the end of this year, Fairfax says.
Comprehensive general hospital inspections will "start at the beginning and go all through the facility," he adds, including safety and health programs, respirator programs, chemical exposures, ergonomics, hazard communications, tuberculosis control programs, and bloodborne pathogens — "anything that could expose or harm workers."
Occupational health experts generally favor the new plan. The Washington, DC-based Service Employees International Union (SEIU), which represents some 650,000 HCWs, has long advocated stricter oversight of working conditions in the nation’s health care facilities. William K. Borwegen, MPH, SEIU’s occupational safety and health director, sees the move as "an incredibly positive development."
However, he takes issue with OSHA classifying hospitals as anything less than high-hazard workplaces.
"The number of people who work in hospitals is astronomical compared to the number of people who work in, for example, chemical plants that have been inspected by OSHA so many umpteen times that they provide a coffee mug with the inspectors’ name on it. It’s inconceivable to me what other type of workplace has a greater range of potentially hazardous conditions than a health care environment, with chemicals, radiation, infectious diseases, ergonomic problems, and workplace violence," he says.
Part of the problem is that OSHA doesn’t have specific standards that apply to many of those exposures, "but you can’t find a more diverse range of hazards than those that health care workers face," Borwegen says. "Any type of entree into the health care sector that this initiative would provide would help hospitals take occupational safety and health more seriously," he adds.
JCAHO may set employee health standards
Kathleen Van Doren, RN, BSN, COHN-S, executive president of the Association of Occupational Health Professionals in Healthcare (AOHP) in Reston, VA, agrees that increased OSHA scrutiny would have a positive effect on worker safety.
"I regard OSHA as an advocate for occupational health. Any time we can work with them for improved worker health and safety in our health care facility, it’s a win-win all the way around," she says. "Some [hospital occupational health] programs out there are not up to grade-A standards because they’re not doing all they should. This will wake them up."
Besides welcoming OSHA, Van Doren would like to see the Joint Commission for Accreditation of Health Care Organizations (JCAHO) include employee health departments in its periodic hospital surveys.
In a letter earlier this year, the AOHP asked JCAHO to consider "stand-alone standards" specific to employee health in the areas of health assessments; recognition, evaluation, and control of occupational health and safety hazards; evaluation, treatment, and case management of occupational injury and illness; surveillance, prevention, and control of infection; management of occupational health information; education; and health promotion and wellness.
"Implementation of employee health functions would be enhanced by comprehensive and coherent employee health standards," the letter states. "Some employee health areas of responsibility are addressed in Joint Commis sion environment of care; management of human resources; or surveillance, prevention, and control of infection chapters. Others are not. Successful implementation of employee health functions requires specific clinical and technical expertise and competencies that are unique to that specialty area. Separate JCAHO employee health standards would facilitate compliance with federal and state OSHA requirements."
JCAHO began considering additional employee health standards as early as last year when its Committee on Health Care Safety began discus sing tuberculosis protection in health care facilities, says Susie McBeth, associate director of JCAHO’s department of standards.
"We began to think then that maybe we need to look more closely at employee health overall," she says.
JCAHO’s Standards and Surveys Procedures Committee of the board of directors will consider this spring whether to recommend that the organization develop more definitive standards applying to employee health programs, or whether to suggest only that additional examples be provided for existing standards in the accreditation manual. Those standards, which mainly are included in the manual’s infection control and environment of care chapters, mention that health care facilities should include employees in protection programs. However, they don’t provide detailed examples or specifications.
"If the decision is made to establish standards, we would have to do some investigation about what to include," McBeth says. "The committee has several options to choose from. We could just add examples applying specifically to employee health services."
Van Doren sees more OSHA and JCAHO oversight as a boon to employee health practitioners in hospitals that haven’t given them adequate administrative support. And most importantly, increased federal attention could save employee health departments from extinction, she says.
"Unless Joint Commission and OSHA really start paying attention to employee health, it’s going to be phased out or outsourced, and nurses are going to find themselves out of a job," she warns. "It’s time we stood up and fought for this instead of crawling off into a corner. There’s no reason to fear Joint Commission or OSHA if we’re doing what we’re supposed to be doing. If we have our own [JCAHO] standards and OSHA starts doing general inspections and talking with employee health staff, we’ll be able to get a lot of recognition from that. It will educate everyone to what employee health does."
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