Look out: New reporting rules may lead to more inspections for hospitals
New standard adds needlesticks, clarifies definitions
New record-keeping rules will greatly increase recordable injuries at hospitals but will simplify the forms used to report them. As a consequence, the rise in reported injuries may make more hospitals the subject of targeted inspections by the U.S. Occupational Safety and Health Administration (OSHA).
Under the revised standard, which becomes effective Jan. 2, 2002, all needlestick injuries will be recorded on the OSHA 300 log. That log also can be used to comply with the revised bloodborne pathogen standard, which becomes effective April 18.
Last year, OSHA added hospitals to its targeted inspection program, which involves unannounced, wall-to-wall inspections of facilities with high-injury rates. Of 400 to 500 hospitals surveyed, 34 received letters advising them to improve their safety programs. OSHA did not reveal how many of those received targeted inspections.
"It’s only going to accelerate" inclusion of hospitals in that program, predicts Geoff Kelafant, MD, MSPH, FACOEM, medical director of the occupational health department of the Sarah Bush Lincoln Health Center in Mattoon, IL, and vice chairman and communications chairman of the medical center occupational health section of the American College of Occupational and Environmental Medicine in Arlington Heights, IL.
"The reality is that employers that have high rates are going to be looked at," concurs Kae Livsey, RN, MPH, public policy and advocacy manager at the American Association of Occupational Health Nurses in Atlanta. However, she cautions employers not to become too alarmed. "It’s necessary to know where these incidents are occurring so you can reduce them," she says.
OSHA’s record-keeping standard, issued on President Clinton’s last day in office, was designed to reduce underreporting, streamline forms, and make analysis easier. The standard incorporates a privacy provision and defines what is work-related, what is first aid, and how to count lost days. "Maybe this will tend to make the numbers more reflective of what actually is going on," says Kelafant. "It’s certainly much more clear in many areas than it was before."
The forms have been streamlined, and OSHA provides easy-to-read algorithms to determine what needs to be reported, notes Jim Maddux, a statistician who was involved in drafting the OSHA standard. "The overriding goal is to try to improve the quality of data — to make sure they are complete, consistent, and . . . descriptive." He acknowledges that hospitals will see an immediate rise in recordable injuries, but adds, "As safer devices get into more and more workplaces, I think those numbers are going to drop down pretty rapidly. There are a lot more devices coming onto the market all the time."
Here are some specific changes and how they will affect reporting:
• There are three forms instead of two. Beginning next year, employers will use the OSHA 300, 300A, and 301. The 300A summary form makes it easier to calculate rates and to post the log without revealing employee names. Also, by placing the summary on a separate sheet, the OSHA 300 now fits on a legal-sized page.
• All needlestick exposures must be reported. Needlesticks or sharps injuries that result in exposure to blood or other bodily fluids must be reported. "Clean" sticks, a needlestick with a syringe or sharp that hasn’t been contaminated, don’t need to be reported. Other types of exposures, such as splashes, do not need to be reported unless they result in seroconversion of a bloodborne illness or meet other recording criteria, such as requiring more than first-aid treatment.
• Musculoskeletal disorders (MSDs) are recorded in a separate column. Work-related MSDs are recorded in a separate column to help track the high-prevalence injury. OSHA defines the condition as "disorders of the muscles, nerves, tendons, ligaments, joints, cartilage, and spinal discs. MSDs do not include disorders caused by slips, trips, falls, motor vehicle accidents, or other similar accidents."
• Illnesses and injuries are reported together. This provision calls for illnesses to be reported in the same manner as injuries. Previously, any illness (such as a rash), no matter how insignificant, would be reported. Now illnesses must meet the threshold of requiring more than first aid.
• Timelines have changed. Recordable injuries and illnesses must be entered on the OSHA 300 log and 301 incident report within seven calendar days. The annual summary of injuries and illnesses must be posted for three months, instead of just one month.
• Tuberculosis (TB) exposure is recorded separately. If an employee is occupationally exposed to TB and subsequently has a positive skin test or a physician’s diagnosis of TB infection, that incident is recorded under a column labeled "respiratory condition." If further investigation shows the TB exposure was not work-related, the incident can be removed.
• Privacy provisions apply. The employee’s name may be withheld from the OSHA 300 log in the case of: injury or illness to intimate body parts or reproductive system; sexual assault; mental illness; HIV infection, hepatitis, or TB; needlestick and sharps injuries; and illness cases where the employee requested anonymity. The incident would be marked "privacy-concern case."
The name would be recorded on the OSHA 301 incident report. However, employee representatives seeking access to information on 301 forms would not receive the employee’s name.
• Definitions of first aid and work-relatedness are clearer. OSHA provides a detailed list of circumstances in which injuries or illnesses would not be work-related. For example, an injury that occurs during a voluntary wellness or fitness activity or in a car accident, which occurs in a company parking lot while the employee was commuting to or from work, would not be work-related.
A pre-existing condition must be "significantly aggravated" by some event in the work environment in order for it to become work-related. The rule also provides a complete list of tasks that are considered "first aid," including the administration of nonprescription drugs at nonprescription dosages, the use of bandages, and massages.
• The rule counts calendar days, not lost workdays. The term "lost workdays" has been eliminated in this standard. Instead, employers must report the number of days an employee was unable to work due to a work-related injury or illness "regardless of whether or not the employee was scheduled to work on those days." Weekends, holidays, and vacation would still count as days away from work due to injury.
• Employees and their representatives have greater access to records. If an employee, former employee, personal representative, or "authorized employee representative" (i.e., a union official) asks for a copy of the 300 log, employers must provide it by the end of the next business day. Current or former employees and their designated representatives also can request the 301 incident report and must receive a copy by the next business day. If union representatives ask for the 301 log, they may receive only the descriptive portion (titled "Tell us about this case . . ."). Employers have seven calendar days to provide that information.
A top executive must sign off on the injury and illness summary. OSHA now requires an officer of the corporation to certify the annual summary. This ensures that top managers are aware of the injury record at the company, Maddux says.
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