Top 10 OSHA Citations in the Healthcare Industry

Each year the Occupational Safety and Health Administration issues hundreds of citations to employers in the healthcare industry. While hospitals, medical centers, physicians' offices and clinics must all comply with a significant number of standards, the standards for which OSHA issued citations within the industry issued remain relatively constant from year to year.  

OSHA identified the following standards as the top cited among these types of healthcare facilities for October 2010 to September 2011: bloodborne pathogens, hazard communication, electrical–wiring methods, respiratory protection and use the proper recordkeeping forms. In hospitals and medical centers, lockout tagout, general criteria in recordkeeping, maintenance of exit routes and asbestos were also among the top standards cited. Rounding out the top cited standards at physicians' offices and clinics are recordkeeping summaries, design and construction of exit routes, medical services and first aid and general requirements for personal protective equipment.  

Here is a more specific look at the most frequently cited standards among hospitals, medical centers, physicians' offices and clinics in the last six months of 2011.

Hospitals and medical centers
1.      Failure to train under the bloodborne pathogen standard
2.      Failure to implement and maintain an exposure control plan under the BBP standard
3.      Failure to engineer out hazards/ensure handwashing under BBP standard
4.      Poor housekeeping under the BBP standard
5.      Failure to use personal protective equipment under the BBP standard
6.      Failure to keep BBP training records and a sharps injury log
7.      Failure to implement and maintain a written hazard communication program
9.      Failure to provide material safety data sheets under the hazard communication standard
10.    Failure to ensure proper labeling of chemicals under the hazard communication standard

Physicians' offices and clinics

1.      Failure to implement and maintain an exposure control plan under the BBP standard
2.      Failure to train under the BBP standard
3.      Failure to engineer out hazards/ensure handwashing under BBP standard
4.      Poor housekeeping under the BBP standard
5.      Failure to implement and maintain a written hazard communication program
6.      Failure to make the Hepatitis B vaccination available under the BBP standard
7.      Failure to prepare exposure determinations under the BBP standard
8.      Failure to use personal protective equipment under the BBP standard
9.      Failure to provide post exposure Hepatitis B vaccination under the BBP standard
10.     Failure to train employees under the hazard communication standard

Employee exposure to safety and health hazards and the issuance of related OSHA citations can be expensive, so it's worth taking the time to avoid these issue by getting compliant with the OSHA standards and by reducing employee exposure. While full compliance with the standards can be difficult, there are steps employers can take to minimize these hazards and avoid citations.  

1. Regularly audit your safety and health compliance by performing facility-wide and recordkeeping inspections and reviews. The focus of the audits should be in those areas where non-compliance is most likely. This includes not only OSHA's top 10 areas, but also those areas specific to the employer's facility.  

For example, if the employer has had previous citations from OSHA, those standards should be a focus of the audit to prevent repeat citations. Employers should also review their first reports of injury, OSHA 300 logs and workers compensation records to look for patterns of injuries related to potential safety infractions. Finally, employers should perform walk-through inspections of their facilities looking for potential hazards and safety violations (and of course, promptly correcting what they find). The information gathered from these audits and inspections should be used improve in areas where safety compliance is found to be deficient; this includes implementing new procedures and policies. For example, an employer that finds it is not properly updating material safety data sheets for new chemicals introduced to the facility may need to revise their intake procedures. Alternatively, the employer might discover that the procedure is adequate, but that the responsible individuals are not performing their duties properly and require retraining, or even discipline.

2. Healthcare employers should audit their training practices, especially in relationship to BBP and hazard communication. Failure to train citations are low-hanging fruit as just one missed employee can result in a citation. In addition, no matter how much training is provided employees often seem to have amnesia when an OSHA compliance officer asks whether they have been trained in a particular area. Employers can avoid these issues by performing regular "refresher training," informally asking their employees about the training they've received to evaluate whether it has been effective and memorable, developing readily-available resources, and reviewing documentation to ensure the training records exist and are readily available if OSHA visits.

While not all hazards, and therefore not all potential for citations, can be eliminated, taking the above-steps will go a long way in reducing the likelihood of their existence. More importantly, these steps are key elements in creating a safer working environment for healthcare employees.

A significant portion of Ms. Casey practice is devoted to workplace risk management preventing OSHA citations, injuries and fatalities. She advises employers in OSHA recordkeeping, hazard assessment and self-audits, corporate-wide safety compliance, maintaining effective safety training and safety management programs, disciplining unsafe employees, inspection preparedness, workplace violence prevention, and health and wellness initiatives.

More Articles on OHSA Compliance:

California Workplace Safety Program Can Reduce Injuries If Enforced
OSHA: 6 Most Frequently Found Hazards in Medical Offices

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