by Evelyn I. Bain, M Ed, RN, COHN-S Associate Director/Coordinator, MNA Occupational Safety and Health Program
To MNA members, presented below are some things to help nurses should OSHA appear in the very near future to inspect their hospitals. Right now they are "targeting" inspections at employers who had high injury rates during the 2001 OSHA reporting year. Some hospitals in Massachusetts are being visited right now, others are on the "list".
OSHA does not let anyone know ahead of time who they are visiting, but when they come to your facility they will ask if it is represented by a union and if so, who will represent the union during the inspection. The hospital "should" release a person who is a union member to accompany the OSHA inspector. In fact, a person or persons from each union that is represented in the facility should accompany the inspector. This person represents the workers during the inspection. Keep your own notes about what is being looked at and what is being said. Any employee, union and otherwise, should be allowed to talk with the OSHA inspector without management present.
Share with the OSHA inspector, your concerns about health and safety hazards in your hospital. This could include, but would not be limited to concerns listed below. I am giving you some things to think about that would be important to talk with the inspector about.
- Bloodborne pathogens and Sharps safety – Do you have safe needles or needleless systems, everywhere? Are staff nurses on the device selection committees? Are staff nurses on safety committees? Does the hospital make it “easy” for nurses to participate? Is there a plan and is it communicated for nurses when there is a blood or body fluid exposure?
- Workplace violence – How are incidents reported? What is the response protocol when there is an incident of violence? Do you have emergency buttons to summon security? Or the police? Is there a program for post traumatic stress debriefing and treatment for psychological injuries? Is there training in violence de-escalation for all employees? Are security guards trained in de-escalation techniques? Is the lighting in the parking area appropriate to protect those who go out or come in late at night?
- TB and TB Screening – Is the hospital following the CDC guidelines for TB Screening, is everyone having an annual TB test? Are nurses being fit tested for N95 or positive pressure "respirators" (PAPR’s)? Are there negative pressure rooms and do people know where and how to access them?
Exposure to hazards that could cause musculo-skeletal injuries (ergonomics) – Have employees been trained to recognize ergonomic hazards? Are employees trained to report injuries and where to report them?
- Latex allergy – Are employees trained to recognize latex allergy? Are gloves made of alternative synthetic materials available for employees to use?
- Safety Committees – Does the safety committee include staff nurses? Does the hospital make it "easy" for staff nurses to participate? Is the a record of safety inspections? Does the safety committee look at hazards to workers or just work related injuries and lost time days. How are members of the safety committee selected?
- Hazardous materials – Is there employee training on the HAZARDS of exposure to drugs such as chemotherapeutic agents and other drugs considered hazardous to the health of nurses and others? Is there hazard communication training specific to the floor, departments, etc? Have employees been trained in how to respond to a spill of MERCURY, chemotherapeutic agents or other hazardous materials? (Being told to leave it alone, and call XXX, is considered training.) Have people had symptoms related to environmental cleaning agents, have they been trained to recognize the adverse health effects from those products?
OSHA reports after the inspections: If there are any citations, that is violations that must be corrected quickly, they will be posted in the areas where the violation was noticed and must be corrected. Many will carry a (small) fine. The complete report can be obtained, through the Freedom of Information Act, through the OSHA offices throughout MA. The union should want to look at it to be sure that the hospital is following through on what OSHA has recommended. MNA can help you get the report. Please call so we can help you get it.
Many of the things I have identified are OSHA requirements to protect the health and safety of employees. Your hospital is probably very much on target at protecting the safety of patients. Now it is your turn. OSHA is your JCAHO.
Good luck and keep us posted.