OSHA Concentrates its Health Care Facility Inspections on Key Areas, but Specific Requirements Remain Elusive

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On June 25, the U.S. Department of Labor's Occupational Safety and Health Administration (OSHA) issued a press release outlining its focus areas for health care facility inspections. Musculoskeletal disorders (MSDs), blood-borne pathogens (BBP), workplace violence, tuberculosis, and slips, trips and falls will be evaluated on all inspections of health care facilities. OSHA programs administered by states are required to follow suit. What's hard to discern is what exactly is changing from current OSHA protocol.

In its Inspection Guidance for Inpatient Healthcare Settings, OSHA reports that during a three-year period from 2012 to 2015, it conducted 1,100 inspections of nursing and residential care facilities, and issued 11 citations using its General Duty Clause provision related to MSD issues. OSHA addressed this issue in a Self Assessment for Safe Patient Handling. Like MSDs, BBP is already a well-recognized hazard by the health care industry, and one of the most frequently issued citations. In its memo, OSHA directs its inspectors to evaluate compliance against the Department of Health and Human Service's guidance for preventing the transmission of tuberculosis in health care settings, dated 2005. OSHA previously addressed workplace violence in the health care setting in its Guidelines for Preventing Workplace Violence for Healthcare and Social Service Workers.

But, what is your facility required to do to comply with OSHA's increased emphasis? Unfortunately, there's no definitive answer. The links provided in this alert provide insight for the health care compliance specialist into what an inspector will be looking for, but may not provide definitive guidance on how to avoid a citation. OSHA's press release appears to be more of the same, beating the drum to encourage companies to focus more attention on these common health care industry hazards.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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