The Joint Commission may ask for your OSHA 200 log
Partnership extends the reach of OSHA regulations
Failure to follow a guideline or directive from the U.S. Occupational Safety and Health Administration (OSHA) may not bring an inspector to your doorstep. But it could earn your hospital a Type I recommendation from the Joint Commission on Accreditation of Healthcare Organizations in Oakbrook Terrace, IL.
The two organizations renewed their three-year partnership in June, saying that their cross-training and educational efforts have led to greater consistency in promoting employee health.
"There’s a high sense of awareness during the survey process," says Carole Patterson, RN, MN, director of the Joint Commission’s standards interpretation group. "The surveyors have been educated about health and safety issues through the partnership and the use of examples published in the standards and accreditation manuals."
In practice, that means Joint Commission surveyors will ask about how you record and respond to needlesticks, whether you’ve implemented safer sharps devices, and other items that stem from OSHA guidelines or standards.
"When we’re doing the survey, we certainly ask to see their OSHA 200 log," says Patterson. "[We’ll ask] what are they doing to deal with their workplace illness and injury rates."
Although the Joint Commission decided not to create a special set of standards geared toward employee health, those issues are included in the infection control and environment of care standards, says Patterson.
Some hospitals may be surprised by questions posed by surveyors who have been specially trained in OSHA regulations.
A surveyor may ask generally about the safety program, such as, "what are your top illness and injury statistics, and what have you done about them?" says Melissa McDiarmid, MD, MPH, professor of medicine and director of the Occupational Health Project at the University of Maryland School of Medicine in Baltimore. The OSHA-Joint Commission partnership began while McDiarmid was director of the office of occupational medicine at OSHA. Staff at some hospitals have noticed changes in Joint Commission surveys, although McDiarmid notes that the focus on employee health issues may differ depending on the surveyor.
Joint Commission doesn’t tattle to OSHA
She recalls fielding an angry call from one hospital "because their feet were held to the fire by a Joint Commission surveyor over a hazardous drug plan, which is an OSHA guideline, not a standard." The guideline involved protecting workers and bystanders from anti-cancer drugs while the drugs were reconstituted and administered as an infusion.
"That’s my idea of a success story," remarks McDiarmid. "That’s a good example of a high-hazard situation in health care that’s recognized both by OSHA and the Joint Commission. Joint Commission surveyors recognized there was an inadequacy of the way those hazards are addressed in that facility and acted on it.
"That hospital doesn’t get an OSHA citation. Joint Commission did not call OSHA to tattle. Joint Commission handled it themselves because they were in agreement that the management plan to handle hazardous drugs was inadequate."
In fact, the partnership benefits hospitals by reducing duplication as they try to comply with the requirements of both OSHA and the Joint Commission, says McDiarmid.
"Our message is that at least with regard to environment of care and infection control, it’s the hazard that needs to be managed," she says. "A single management plan for the hazard, and documentation of that management plan, should be satisfactory to both Joint Commission and OSHA."
Hospitals also can target employee health issues, such as reducing back injuries or needlesticks, in a performance improvement project that satisfies Joint Commission requirements, she says.
When the partnership began in 1996, the Joint Commission was already moving toward more action in the area of workplace safety. The Joint Commission began adding OSHA-related examples to its manuals in 1997.
The partnership was a natural’
"When we first approached the Joint Commission about the shared partnership, we found their educational departments had already finished or had in production either print or audio or video tapes on precisely the hazards we were concerned about," says McDiarmid. "The partnership was a natural."
OSHA provided education to Joint Commission surveyors, and OSHA officials visited the Joint Commission’s headquarters to learn about how the organization conducted surveys.
The partnership greatly increases OSHA’s reach into the health care industry, notes McDiarmid. OSHA may inspect 600 to 800 hospitals a year, mostly in response to complaints, she says. The Joint Commission visits more than 5,000 hospitals within three years.
Beyond the partnership, the Joint Commission also extends the influence of other rules and guidelines that apply to health care. The Joint Commission requires hospitals to comply with appropriate laws, regulations, and guidelines of federal agencies and professional organizations, says Patterson.
So, for example, as the Centers for Disease Control and Prevention in Atlanta completes its guidelines on preparing for pandemic influenza, Joint Commission surveyors will take note. (See Hospital Employee Health, July 2000, p. 73.) "When it gets done, we will teach our surveyors about it and they will ask about it," says Patterson.
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