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October 12, 2012
Enforcement: Federal OSHA inspects veterans hospitals; 5 violations that may surprise healthcare employers

In November 2011, federal OSHA compliance officers visited four Veterans Administration (VA) medical facilities in the VA's Northern California Health Care System. Federal agencies must comply with the same safety and health standards as private sector employers covered under the Occupational Safety and Health Act by Executive Order 12196.

Although one federal agency cannot cite or fine another, federal OSHA can issue Notices of Unsafe or Unhealthful Working Conditions to another federal agency—and it issued 26 notices to the VA. The cited hazards, however, were not what a healthcare employer might expect.

If your facility has been closely focused on reducing injuries from patient handling and slips, trips, and falls, perhaps it's time to determine whether you have other hazards that you should address.

Practice tip

Although one federal agency cannot cite another, the same is not true within the state. States with their own OSHA agencies, like Cal/OSHA, must include other state and municipal government agencies in their enforcement program.

Unexpected hazards

The most common hazards in health care are overexertion hazards—primarily back, shoulder, and neck injuries caused by patient handling—and slip, trip, and fall hazards, according to the U.S. Bureau of Labor Statistics. Together, these hazards account for 64 percent of nonfatal injuries to healthcare workers. But none of the cited violations involved these kinds of hazards.

What OSHA did find may surprise and inform other healthcare employers. The 23 notices for serious violations and one notice for a repeat violation at the VA facilities involved several areas that Cal/OSHA standards also address:

  • Blocked emergency exit doors and routes. When emergency exit doors and routes are blocked, the safety of both employees and patients is compromised.

    Under General Industry Safety Orders (GISO) Sections 3215 through 3235, employers have to maintain emergency exit routes in safe, functional condition. Exit doors must be unlocked, and workers must be able to open exit route doors from the inside at all times without tools, keys, or special knowledge. Exit routes must be unobstructed. For example, exit routes cannot go through rooms that can be locked, such as storerooms or bathrooms.

    Under most circumstances, an exit door that has been improperly blocked has been blocked closed, but many healthcare facilities have fire-rated doors that must be free to close in an emergency. Make sure emergency fire doors are not improperly blocked in the open position.

  • Electrical hazards. The potential for electrical hazards exists throughout most healthcare facilities.

    Damaged, poorly maintained, or improperly connected electrical equipment is a fire and electrocution hazard. Electrical equipment in the presence of oxygen or flammable chemicals is a fire hazard. And electrical equipment in wet environments is an electrocution hazard.

    In federal OSHA's Technical Manual, the agency recommends that its inspectors check whether hospital-grade electrical equipment is tested at appropriate intervals and serviced according to a preventive maintenance schedule. This equipment includes anesthesia machines, portable X-ray machines and laser systems, biological safety cabinets, and exhaust ventilation systems. Electrical installations and equipment in healthcare environments are also subject to the applicable requirements of Cal/OSHA's Electrical Safety Orders.

  • Machine guarding. Although not an obvious hazard in health care, machine guarding issues do exist, particularly in ancillary service areas like kitchens, laundries, maintenance departments, and fabricating areas (for example, orthotic and prosthetic labs). Machine guarding issues may also arise in the surgical suite.

    Under GISO Group 8, Points of Operation and Other Hazardous Parts of Machinery, employers must ensure that workers are protected from crushing and amputation hazards at the point of operation of the machine.

  • Exposure to contaminated needles. Exposure to contaminated needles is an area of concern in health-care settings. Where workers may be exposed to infectious diseases by contaminated needles, the bloodborne pathogens standard (GISO Section 5193) requires employers to implement an exposure control plan that outlines how workers will be protected from this hazard. Needle-free devices, safer needles, and safe disposal methods (sharps containers) are protective strategies that the standard requires.

    Workers may be exposed to hazards other than bloodborne pathogens through contact with contaminated needles. Healthcare employers should also make sure that workers are protected against chemical hazards that may be posed by needlesticks, such as accidental injection with hazardous drugs. This exposure is not covered by the bloodborne pathogens standard, but it is covered by the hazard communication standard (GISO 5194) and can be controlled with many of the same methods.

  • Improper storage of biological hazardous waste. Because the VA Medical Center at Long Beach was also issued a notice for this hazard, the VA Northern California Health Care System was issued a notice of repeat violation for it.

    The bloodborne pathogens standard requires that wastes contaminated with blood or other potentially infectious materials be disposed of safely. This means that wastes not containing sharps must be in containers that are: closable; leak-proof during handling, storage, transport, and shipping; and labeled in accordance with the standard.
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