2007 News
OSHA Report
U.S. Department of Labor
Occupational Safety and Health Administration
639 Granite Street, 4th Floor
Braintree, MA 02184
Phone: 617.565.6924 Fax: 617.565.6923
July 13, 2007
Kimberly Walsh, VP of Patient Services
Brockton Hospital
680 Centre Street
Brockton, MA 02302
Dear Ms Walsh:
During an inspection conducted beginning March 19, 2007 at your facility located at 380 Centre Street, Brockton, Massachusetts, conditions were observed, which although not violative of the standards, are considered significant enough to be brought to your attention.
Based on employee interviews and a review of incident reports of workplace violence during the previous six months, employees are suffering physical assaults from patients which can lead to serious injuries. The types of physical assaults include, but are not limited to, punching, kicking, biting, scratching and pulling hair. Resulting injuries include, but are not limited to bruising/contusions, cuts, hematomas, strains, and sprains. The majority of the cases involved patient care givers who were assaulted while assisting and/or caring for patients in the emergency department and psychiatric unit.
Since no OSHA standard applies and it is not considered appropriate at this time to invoke Section 5(a) (1), the general duty clause of the Occupational Safety and Health Act, this letter is being issued. In the interest of workplace safety and health, OSHA recommends that you take the following steps voluntarily to eliminate or reduce your employees’ exposure to hazards described above.
Section 21 of the Occupational Safety and Health Act authorizes OSHA to train employers and employees about workplace hazards and appropriate abatement methods. The following are recommendations to improve the existing workplace violence program. Although not exhaustive, the recommendations address employee involvement, worksite analysis, hazard prevention and control, and program evaluation.
a. Management Commitment and Employee Involvement: Develop a specific workplace violence safety committee whose focus is to minimize assaults and violence from patients and which includes as members: front-line workers, patient caregivers, doctors, security personnel, risk managers, facilities engineering, and administrators. Ensure that frontline workers have the time to attend the meetings so that can provide input on how to minimize the safety problems in the work place. Ensure there is adequate staffing so workers can attend meetings and be actively involved in hazard analysis and implementation of any corrective actions. Make the reduction of violence incidents a priority for management personnel. Responsibilities of the committee include performing continuous worksite analyses, conducting periodic walkthroughs of the hospital, reviewing case studies and guidelines, and making recommendations to reduce assaults.
b. Implementation of a Written Program: Put together all the existing hospital policies that address workplace violence into one cohesive workplace violence written program. The program should include existing site specific procedures to deal with different types of violence in your workplace. The workplace violence committee should annually review and update the program.
c. Worksite Analysis: This involves a step-by-step look at the facility to find existing or potential hazards for assaults and workplace violence. Continue to record analysis, tracking of injuries, and monitoring trends of injuries based on location, shift changes, and staffing levels. Workplace analysis also includes conducting a walkthrough of the facility to identify environmental risk factors. Another important tool is an annual anonymous employee survey to get employee’s ideas on the potential for violent incidents and to identify or confirm the need for improved security measures. Work analysis should also include a review of the security personnel’s ability to respond to unit crisis on all shifts. This analysis should be shared with the workplace violence safety committee so that the trends can be studies and acted upon.
d. Hazard Prevention and Control: This element includes engineering controls and workplace adaptations, administrative and work practice controls, and post incident responses. Evaluate the effectiveness of current security measures. Explore engineering controls such as installing metal detectors where appropriate, increasing the number of security cameras, placing curved mirrors in concealed areas, and enclosing the nurses’ station on the psychiatric unit C3. Also, utilize administrative controls such as increasing the number of “watchers” who watch overflow patients waiting in hallways in the emergency department psychiatric area, increasing the presence of security personnel in the emergency department, ensuring staffing levels of security personnel are adequate for each shift, developing a violence reporting program that identifies patients with a history of violence through a computerized database and establishing a liaison with local police and state prosecutors.
e. Training and Education: Continue to train all affected employees, (including but not limited to: patient caregivers, doctors, supervisors, security personnel, administrators, facilities engineering, managers and risk managers) on Management of Aggressive Behavior (MOAB) and/or Crisis Prevention Institute (CPI) training. The training session should include at a minimum (but is not limited to): a copy and discussion of the written violence prevention program; the person in charge of the program; the contacts for bringing up concerns (at local and corporate level): past assaults and follow-up actions taken by the facility; site specific hazards in your work area, site specific methods to reduce the risk in you work area; and policies and procedures for obtaining medical care, counseling, workers’ compensation, and legal assistance after a violent episode or injury.
f. Recordkeeping and Evaluation of the program: Continue maintaining records of all workplace violence incidents and continue analyzing the records. Continue keeping records of all follow-up actions following all workplace violence incidents. Ensure that the written workplace violence program and all of its elements are reviewed annually to ensure that it is working (i.e., downward trend in number of assaults and injuries and downward trend in severity of assaults), and make recommendations and updates for continuous improvement.
The above guidelines are taken from a publication entitled “Guidelines for Preventing Workplace Violence for Health Care and Social Service Workers” – OSHA 3148, published in 1996, which is available on the OSHA website: www.osha.gov.
These methods are not meant to be the only ones available or feasible. OSHA makes available an on-site consultation service which may identify other measures or you may consider hiring outside consultants. The on-site consultations are free and do not in any way affect the enforcement activities of OSHA. On-site consultants may be contacted at:
Consultation Services
The Commonwealth of Massachusetts
Dept. of Labor and Industries
1101 Watertown Street
West Newton, Ma 02465
Tel. 617.969.7177
OSHA request that progress reports on your specific effort to address this problem be provided to this office monthly (first progress report due August 15, 2007) until the above components have been fully implemented. The reports should include a management plan to address the workplace violence hazards and a timetable for implementation of the above elements. The plan should assign responsibility for the violence prevention plan, worksite analysis, hazard prevention and control, training and education of all employees, and recordkeeping/evaluation of the program implemented. The progress report should also include all new reports of assaults and follow-up actions taken as well as safety committee minutes. If you have any questions, please contact the supervisor in charge of this case, Maria Lisa Abundo 617.565.6924 extension 640.
Respectfully,
Brenda J. Gordon
Area Director
