update to osha - hcpro · december 2017 revisions osha program manual for medical facilities update...

Dear HCPro Customer:

Enclosed is your latest supplement to the OSHA Program Manual for Medical Facilities. This supplement is designed to keep your product up to date. Your next supplement will be in May 2018. If you have any questions about your subscription, please contact our Customer Service department at 800-650-6787 or e-mail [email protected]. At HCPro, customer comments and suggestions are very important to us—let us know how we can serve you better.

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FILING INSTRUCTIONS

Rev. 12/17 OSHASPM2 Supplement to OSHA Program Manual for Medical Facilities

VISIT www.hcmarketplace.com for the latest compliance and training information.

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xiii-xviii xiii-xviii OSHA Program Manual Contents—updated

Tab 3 Contents Tab 3 Contents updated

3-1 through 3-58 3-1 through 3-58 Tab 3: General Facility Safety—updated

December 2017 Revisions

OSHAPROGRAMMANUALfor Medical Facilities

Update to

About the AuthorMarge McFarlane, PhD, MT (ASCP), CHSP, CHFM, CJCP, HEM, MEP, is an independent safety consultant

with more than 40 years of healthcare experience. She has provided education, emergency management

and safety plan review, life safety, and infection prevention facility surveys for healthcare and businesses

in Wisconsin and across the nation since 2005. She is the author of The Compliance Guide to the OSHA

GHS Standard for Hazardous Chemical Labeling, 2014 and the OSHA Training Handbook for Healthcare

Facilities, Second Edition, 2014. 17L

©2005–2017 HCPro, a division of BLR. All rights reserved, including right of reproduction. The author(s) and their agent(s) have made every reasonable effort in the preparation of this publication to ensure the accuracy of the information. However, the information in this book is sold without warranty, either expressed or implied. The authors, the editors, their agents, and the publishers will not be liable for any damages caused or alleged to be caused directly, indirectly, incidentally, or consequentially by the information in this publication. This publication cannot and does not provide specific information for a user’s exact situation. Users of this publication should exercise their own judgment and, where appropriate, seek the assistance of legal counsel regarding their particular situation.

OSHAPROGRAMMANUALfor Medical Facilities

HCPro, an H3.Group division of Simplify Compliance, LLC 35 Village Road, Suite 200

Middleton, MA 01949Tel: 800/650-6787Fax: 800/639-8511

www.hcmarketplace.com

OSHA Program Manual for Medical Facilities is published by HCPro, an H3.Group division of Simplify

Compliance, LLC.

Copyright © 2017 HCPro, an H3.Group division of Simplify Compliance, LLC

All rights reserved. Printed in the United States of America. 5 4 3 2 1

ISBN: 978-1-60146-743-0

No part of this publication may be reproduced, in any form or by any means, without prior written consent of

HCPro, a division of BLR, or the Copyright Clearance Center (978-750-8400). Please notify us immediately

if you have received an unauthorized copy.

HCPro, a division of BLR, provides information resources for the healthcare industry.

HCPro, a division of BLR, is not affiliated in any way with The Joint Commission, which owns the JCAHO

and Joint Commission trademarks.

Marge McFarlane, PhD, MT (ASCP), CHSP, CHFM, CJCP, HEM, MEP, Author

Sheila Dunn, DA, MT (ASCP), Contributing Editor

Jay Kumar, Associate Product Manager

Mike Mirabello, Facilities Operations Specialist

Matt Sharpe, Senior Manager of Production

Elizabeth Petersen, President

Advice given is general. Readers should consult professional counsel for specific legal, ethical, or

clinical questions.

Arrangements can be made for quantity discounts. For more information, contact:

HCPro

35 Village Road, Suite 200

Middleton, MA 01949

Telephone: 800-650-6787 or 781-639-1872

Fax: 800-639-8511

E-mail: [email protected]

Visit HCPro online at: www.hcpro.com and www.hcmarketplace.com

12/17

OSHA PROGRAM MANUAL

Contents

Front Pocket OSHA Poster 3165: IT’S THE LAW!

Laminated Eyewash Station Sign

4 Sample Biohazard Self-Adhesive Labels

Available as downloads: Master Record Forms (Tab 11) from this Manual for Customization.

xiii

IntroductionImportant Information About the Use of This Program ............................. i

How to Customize This Program ................................................................. iii

Master List of Program Items for Customization ........................................ vii

What Is Included in This Program ................................................................ ix

TAB 1: What Is OSHA?A Quick Look at OSHA .................................................................................. 1-1

States with OSHA-Approved Plans ..................................................................................... 1-1

OSHA Consultative Services Division ................................................................................. 1-2

OSHA’s Jurisdiction ............................................................................................................. 1-2

OSHA’s General Duty Clause .............................................................................................. 1-2

Employee or Employer.................................................................................. 1-4Employer Responsibilities Under OSHA ............................................................................. 1-5

Overview of OSHA Standards ...................................................................... 1-5

OSHA Inspections ......................................................................................... 1-6Employee Complaints .......................................................................................................... 1-6

If an On-site OSHA Inspection Occurs ................................................................................ 1-7

During the Inspection .......................................................................................................... 1-8

What OSHA Inspectors May Ask Employees ...................................................................... 1-8

The Typical OSHA Inspection .............................................................................................. 1-9

The Closing Conference ...................................................................................................... 1-10

OSHA Sanctions ............................................................................................ 1-11

Whistleblower Protection ............................................................................. 1-13

Students and Volunteers ............................................................................... 1-15

Page

Contents

xiv

TAB 2: OSHA Program AdministrationInjury & Illness Prevention Plan Flowchart ......................................... Reverse Side of TOC

Injury & Illness Prevention Plan .................................................................. 2-1Management Leadership and Employee Involvement ........................................................ 2-1Key Contacts for the OSHA Safety Program ....................................................................... 2-2Location of the OSHA Manual Program ............................................................................. 2-2

Duties of the OSHA Safety Officer .............................................................. 2-2

Accident/Incident Investigation & Reporting Procedure .......................... 2-4Definition of an Accident/Incident or Near-Miss Event ........................................................ 2-4When to Investigate an Accident/Incident ........................................................................... 2-4How to Document an Accident/Incident .............................................................................. 2-5Recording Accidents or Injuries for OSHA .......................................................................... 2-5Correcting Unsafe or At-Risk Conditions ............................................................................. 2-5

Recordkeeping Requirements ...................................................................... 2-6Equipment & Facility Records ............................................................................................ 2-6Bloodborne Pathogens Records ......................................................................................... 2-6Hazard Communication Records ........................................................................................ 2-6TB Records ......................................................................................................................... 2-6Training Records ................................................................................................................. 2-7Employee Medical Records ................................................................................................ 2-7Evaluating Exposure Incidents ........................................................................................... 2-8

OSHA Focus on Healthcare ......................................................................... 2-8

Workplace Hazard Analysis ......................................................................... 2-9

Practical Ideas for Involving Employees .................................................... 2-10

Organizing OSHA Compliance Duties ........................................................ 2-11

Weekly Facility Review Checklist ................................................................ 2-12

Monthly Facility Review Checklist .............................................................. 2-13

Annual Facility Review Checklist ................................................................ 2-14

Annual OSHA Safety Program (Includes Exposure Control Plan, Hazard Communication Program, and Respiratory Protection Plan) Review .... 2-17

TAB 3: General Facility SafetyKeeping Employees Safe .............................................................................. 3-1

Important Phone Numbers & Contacts ............................................................................... 3-1Emergency Phone List ....................................................................................................... 3-2

Fire Safety ...................................................................................................... 3-3Automatic Sprinkler Systems ............................................................................................... 3-3Fire Alarms .......................................................................................................................... 3-3Fire Procedures: Immediate Actions .................................................................................... 3-3Building Evacuation ............................................................................................................ 3-4Fire Extinguishers ............................................................................................................... 3-4

Purchase the Right Extinguisher ................................................................................ 3-6

Contents

xv

How Many Fire Extinguishers to Have & Where to Put Them ...................................... 3-7To Use a Fire Extinguisher: Think “PASS” .................................................................. 3-7When to Extinguish Fires with a Portable Fire Extinguisher ........................................ 3-7When NOT to Extinguish Fires and to Evacuate ........................................................ 3-8Fire Extinguisher Inspections ..................................................................................... 3-8Fire Extinguisher Maintenance ................................................................................... 3-8

Fire Risks During Surgery .................................................................................................. 3-8

Fire Extinguisher Supplement ..................................................................... Supplement

Fire Drills ............................................................................................................................ 3-8.2

Electrical Safety ............................................................................................. 3-9

Physical Characteristics of a Safe Medical Facility .................................... 3-10Automated External Defibrillators ....................................................................................... 3-10Air Quality ............................................................................................................................ 3-10

Mold ............................................................................................................................ 3-11Mold Remediation ...................................................................................................... 3-12

Aisles .................................................................................................................................. 3-13Emergency Lighting ............................................................................................................ 3-14Employee Dress Code ......................................................................................................... 3-14Exits, Means of Egress ....................................................................................................... 3-14Exit Doors ........................................................................................................................... 3-15Exit Signs ............................................................................................................................ 3-15Floors .................................................................................................................................. 3-16Lighting ............................................................................................................................... 3-16Noise ................................................................................................................................... 3-16Portable Space Heaters ...................................................................................................... 3-17Restricted Access Areas ..................................................................................................... 3-17Sinks ................................................................................................................................... 3-17Storage ............................................................................................................................... 3-17

Systems Failure ............................................................................................. 3-18

Evacuation Plan ............................................................................................. 3-19Evacuation Procedures ........................................................................................................ 3-19

Methods for Carrying Patients During an Evacuation.................................................. 3-20Evacuation Floor Plan ......................................................................................................... 3-21Example Evacuation Floor Plan ......................................................................................... 3-22

Emergency Preparedness Supplies ........................................................... 3-23

Emergency Action Procedures ................................................................... 3-23Bioterrorism: Suspicious Letters or Packages .................................................................... 3-24

What Is a “Suspicious Package”? ................................................................................ 3-24Bomb Threat ....................................................................................................................... 3-24

If You Discover a Bomb or a Suspicious Item .............................................................. 3-25Explosion .................................................................................................................... 3-26

Civil Disturbance ................................................................................................................. 3-26Earthquake .......................................................................................................................... 3-27

If a Tremor Occurs when You Are Inside ..................................................................... 3-27After the Tremor Is Over ............................................................................................. 3-27

Severe Weather ................................................................................................................... 3-28Flood ........................................................................................................................... 3-28

Contents

xvi

Hurricane .................................................................................................................... 3-28Severe Thunderstorm or Tornado Warning ................................................................. 3-28Tornado Safety Tips .................................................................................................... 3-29Severe Thunderstorm or Tornado Watch ..................................................................... 3-29Toxic External Atmosphere ......................................................................................... 3-29

Violence ............................................................................................................................... 3-30OSHA’s Jurisdiction Over Workplace Violence ........................................................... 3-30Prevalence of Violence ............................................................................................... 3-30Identifying Situations with the Potential for Violence ................................................... 3-32Violence Prevention Plan Introduction ........................................................................ 3-32Overview of Violence Prevention Plan Components .................................................. 3-33 Part 1 ................................................................................................................... 3-33

Workplace Violence Program Checklists .................................................... 3-35Part 2 ................................................................................................................. 3-38.9

More Sources for Prevention of Workplace Violence ................................................... 3-39

First Aid .......................................................................................................... 3-40

Crash Kit/Cart Components ......................................................................... 3-43

Drug-Free Workplace Program ..................................................................... 3-43

Service Animals ............................................................................................. 3-48

Holiday Decorations ...................................................................................... 3-50Sample Checklist: Spot Check Your Facility’s Holiday Decorations ..................................... 3-50

Safe Decorations and Displays Policy ......................................................... 3-52

Slip, Trip, and Fall Prevention ....................................................................... 3-54Contaminants on the Floor .................................................................................................. 3-54Poor Drainage: Pipes and Drains ........................................................................................ 3-54Indoor Walking Surface Irregularities ................................................................................... 3-54Outdoor Walking Surface Irregularities ................................................................................ 3-55Weather Conditions: Ice and Snow ..................................................................................... 3-55Inadequate Lighting ............................................................................................................. 3-55Stairs and Handrails ............................................................................................................ 3-55Stepstools and Ladders ....................................................................................................... 3-56Tripping Hazards: Clutter, Including Loose Cords, Hoses, Wires, Medical Tubing ............... 3-56Improper Use of Floor Mats and Runners ........................................................................... 3-56Healthcare Facility Slip, Trip, and Fall Hazard Checklist ...................................................... 3-57

TAB 4: Ergonomics in the Medical WorkplaceA Quick Look at Ergonomics ....................................................................... 4-1

Common Musculoskeletal Disorders .......................................................... 4-2Back Injuries ........................................................................................................................ 4-3

Techniques to Reduce Injury ....................................................................................... 4-4Fatigue ................................................................................................................................. 4-5Repetitive Stress Injuries/Wrist Injuries ............................................................................... 4-6

Wrist and Hand Exercises ........................................................................................... 4-6Eye Strain ............................................................................................................................ 4-8

Contents

xvii

Why Prevent CVS? ...................................................................................................... 4-8Symptoms of CVS ....................................................................................................... 4-8Other Suggestions for Relieving Eye Strain ................................................................ 4-9

Selecting Equipment ..................................................................................... 4-10

TAB 5: Bloodborne Pathogens Exposure Control PlanExposure Control Plan Introduction ............................................................ 5-1

Overview of Bloodborne Pathogens Standard Components .................... 5-2

A Quick Look at Occupational Exposure .................................................... 5-3

Industries Subject to the Bloodborne Pathogens Standard ..................... 5-3

Universal/Standard Precautions .................................................................. 5-4Other Potentially Infectious Materials (OPIM) ..................................................................... 5-4Implementing Universal/Standard Precautions ................................................................... 5-5

Bloodborne Pathogens ................................................................................ 5-6Epidemiology of Bloodborne Pathogens of Concern to Healthcare Workers ..................... 5-6Update on AIDS in the Workplace ...................................................................................... 5-9Transmission of Bloodborne Pathogens .............................................................................. 5-9

Exposure Determination .............................................................................. 5-9Personnel Who Are Occupationally Exposed ..................................................................... 5-9

Exposure Prone Procedures ....................................................................................... 5-10Bloodborne Pathogens Exposure Determination List #1 (Form 8) ..................................... 5-12Other Personnel Who Could Potentially Be Occupationally Exposed ................................. 5-12Bloodborne Pathogens Exposure Determination List #2 (Form 9) ..................................... 5-13Employees Who Are Not Occupationally Exposed ............................................................. 5-14

Restricted Access Areas ............................................................................... 5-14

Engineering/Work Practice Controls ........................................................... 5-14Biohazard Labels ................................................................................................................ 5-15Handwashing ...................................................................................................................... 5-15

When to Wash Hands .................................................................................................. 5-17How to Wash Hands .................................................................................................... 5-17Artificial Nails ............................................................................................................. 5-17

Sharps Safety ..................................................................................................................... 5-18What to Look for in Safety Devices ............................................................................ 5-18Sharps Evaluation Procedure ...................................................................................... 5-19Use of Non-Safe Sharps ............................................................................................. 5-20Phlebotomy Needles .................................................................................................. 5-21

Sharps Containers .............................................................................................................. 5-21Sharps Container Maintenance .................................................................................. 5-22Sharps Container Disposal Procedure ....................................................................... 5-22

Biohazardous Waste (See Tab 8) ....................................................................................... 5-23Laundry ............................................................................................................................... 5-23

Personal Protective Clothing & Equipment ............................................... 5-24PPE Strategy ...................................................................................................................... 5-24

Contents

xviii

Locations of PPE ................................................................................................................ 5-25Gloves ........................................................................................................................ 5-26

When to Wear Gloves ........................................................................................ 5-26How to Wear Gloves ........................................................................................... 5-26Latex Allergy ....................................................................................................... 5-27Preventing Allergic Reactions ............................................................................. 5-28

Face Protection ........................................................................................................... 5-29Body Protection .......................................................................................................... 5-29Emergency Resuscitation Equipment ........................................................................ 5-30

When to Wear PPE .............................................................................................................. 5-30

Hepatitis B Vaccine ....................................................................................... 5-31Safety of the Hepatitis B Vaccine ........................................................................................ 5-32Documenting Employee Hepatitis Vaccines ....................................................................... 5-32Titering Employees after the Hepatitis B Vaccination ......................................................... 5-33

How to Determine Employee Immunity ...................................................................... 5-33Testing Employees Vaccinated before the Titer Requirement ..................................... 5-34

Types of Hepatitis B Tests ........................................................................... 5-34Interpreting Hepatitis B Test Results.................................................................................... 5-35

New Employee Hepatitis B Virus Vaccination Flow Chart ........................ Supplement

Post-exposure Evaluation & Follow-up ....................................................... 5-37What Is an Exposure? ......................................................................................................... 5-37What to Do after an Occupational Exposure ...................................................................... 5-37For HCV Exposures ............................................................................................................ 5-39For HBV Exposures ............................................................................................................ 5-39For HIV Exposures ............................................................................................................. 5-40When to Get Expert Consultation for HIV Post-exposure Prophylaxis ................................ 5-41Confidentiality of Post-exposure Procedures ...................................................................... 5-41Employee Counseling/Precautions ..................................................................................... 5-42

Occupational Exposure Management Resources ..................................... 5-42

Incident Report/Sharps Injury (Form 14) .................................................... 5-43

Post-exposure Checklist (Form 17) .............................................................. 5-45

Post-exposure Medical Evaluation Declination Form (Form 18) .............. 5-46

Injection Safety ............................................................................................. 5-47Information for Providers .................................................................................................... 5-47

Frequently Asked Questions: Injection Safety FAQs for Providers ......... 5-48Overview ............................................................................................................................ 5-48Injection Procedures ........................................................................................................... 5-50

Infection Control and Safe Injection Practices to Prevent Patient-to-Patient Transmission of Bloodborne Pathogens ...................... Supplement

Infection Control and Safe Injection Practices to Prevent Patient-to-Patient Transmission of Bloodborne Pathogens (fingerstick, blood glucose sampling) ......................................................... Supplement

Bloodborne Pathogens Resources .............................................................. 5-53

TAB 3: GENERAL FACILITY SAFETY

Contents

Keeping Employees Safe ................................................................................. 3-1Important Phone Numbers & Contacts .................................................................................. 3-1Emergency Phone List ........................................................................................................... 3-2

Fire Safety ......................................................................................................... 3-3Automatic Sprinkler Systems ................................................................................................. 3-3Fire Alarms ............................................................................................................................. 3-3Fire Procedures: Immediate Actions ....................................................................................... 3-3Building Evacuation ............................................................................................................... 3-4Fire Extinguishers .................................................................................................................. 3-4

Purchase the Right Extinguisher .................................................................................... 3-6How Many Fire Extinguishers to Have & Where to Put Them ......................................... 3-7To Use a Fire Extinguisher: Think “PASS” ...................................................................... 3-7When to Extinguish Fires with a Portable Fire Extinguisher ............................................ 3-7When NOT to Extinguish the Fire and to Evacuate ......................................................... 3-8Fire Extinguisher Inspections ......................................................................................... 3-8Fire Extinguisher Maintenance ........................................................................................ 3-8

Fire Risks During Surgery ...................................................................................................... 3-8

Fire extinguisher supplement ......................................................................... Supplement

Fire Drills ................................................................................................................................ 3-8.2

Electrical Safety ............................................................................................... 3-9

Physical Characteristics of a Safe Medical Facility ....................................... 3-10Automated External Defibrillators ........................................................................................... 3-10Air Quality ............................................................................................................................... 3-10

Mold ............................................................................................................................... 3-11Mold Remediation .................................................................................................. 3-12

Aisles ..................................................................................................................................... 3-13Emergency Lighting ............................................................................................................... 3-14Employee Dress Code ........................................................................................................... 3-14Exits, Means of Egress .......................................................................................................... 3-14Exit Doors .............................................................................................................................. 3-15Exit Signs ............................................................................................................................... 3-15Floors ..................................................................................................................................... 3-16Lighting .................................................................................................................................. 3-16Noise ...................................................................................................................................... 3-16

Page

Portable Space Heaters ......................................................................................................... 3-17Restricted Access Areas ........................................................................................................ 3-17Sinks ...................................................................................................................................... 3-17Storage .................................................................................................................................. 3-17

Systems Failure ............................................................................................... 3-18

Evacuation Plan ............................................................................................... 3-19Evacuation Procedures .......................................................................................................... 3-19

Methods for Carrying Patients During an Evacuation .................................................... 3-20Evacuation Floor Plan ............................................................................................................ 3-21Example Evacuation Floor Plan ............................................................................................. 3-22

Emergency Preparedness Supplies ............................................................... 3-23

Emergency Action Procedures........................................................................ 3-23Bioterrorism: Suspicious Letters or Packages ........................................................................ 3-24

What is a “Suspicious Package”? .................................................................................... 3-24Bomb Threat .......................................................................................................................... 3-24

If You Discover a Bomb or a Suspicious Item ................................................................. 3-25Explosion ........................................................................................................................ 3-26

Civil Disturbance .................................................................................................................... 3-26Earthquake ............................................................................................................................ 3-27

If a Tremor Occurs when You Are Inside ......................................................................... 3-27After the Tremor Is Over .................................................................................................. 3-27

Severe Weather ..................................................................................................................... 3-28Flood .............................................................................................................................. 3-28Hurricane ........................................................................................................................ 3-28Severe Thunderstorm or Tornado Warning .................................................................... 3-28Tornado Safety Tips ........................................................................................................ 3-29Severe Thunderstorm or Tornado Watch ........................................................................ 3-29Toxic External Atmosphere .............................................................................................. 3-29

Violence .................................................................................................................................. 3-30OSHA’s Jurisdiction Over Workplace Violence ............................................................... 3-30Prevalence of Violence ................................................................................................... 3-30Identifying Situations with the Potential for Violence ....................................................... 3-32Violence Prevention Plan Introduction ............................................................................ 3-32Overview of Violence Prevention Plan Components ...................................................... 3-33 Part 1 ...................................................................................................................... 3-33

Workplace Violence Program Checklists ........................................................ 3-35Part 2 ...................................................................................................................... 3-38.9

More Sources for Prevention of Workplace Violence....................................................... 3-38.10

First Aid ............................................................................................................. 3-39First Aid Kit .............................................................................................................................. 3-39Basic First Aid for Common Emergencies ............................................................................... 3-40

Crash Kit/Cart Components ............................................................................ 3-42

Drug-Free Workplace Program ........................................................................ 3-42

Contents

Contents

Service Animals ............................................................................................... 3-47

Holiday Decorations ........................................................................................ 3-49Sample Checklist: Spot Check Your Facility’s Holiday Decorations ........................................ 3-49

Safe Decorations and Displays Policy ............................................................ 3-51

Slip, Trip, and Fall Prevention .......................................................................... 3-53Contaminants on the Floor .....................................................................................................3-53Poor Drainage: Pipes and Drains ............................................................................................3-53Indoor Walking Surface Irregularities ......................................................................................3-53Outdoor Walking Surface Irregularities ...................................................................................3-54Weather Conditions: Ice and Snow .........................................................................................3-54Inadequate Lighting ................................................................................................................3-54Stairs and Handrails................................................................................................................3-54Stepstools and Ladders ..........................................................................................................3-55Tripping Hazards: Clutter, Including Loose Cords, Hoses, Wires, Medical Tubing ..................3-55Improper Use of Floor Mats and Runners ...............................................................................3-55Healthcare Facility Slip, Trip, and Fall Hazard Checklist .........................................................3-56

3-1

OSHA Program Manual for Medical Facilities

GENERAL FACILITY SAFETY

Keeping Employees Safe

This section provides an overview of the general workplace requirements applicable to ambulatory medical facilities and clinics, including fire safety, electrical safety, exit safety (egress) and building evacuation. It also includes procedures for safely dealing with a wide variety of emergency situations, from civil disturbance to workplace violence.

Important Phone Numbers & Contacts

OSHA updated the 29 CFR 1904 Recordkeeping rule in 2017. Employers must report all work-related fatalities within eight hours and work-related inpatient hospitalizations, amputations and losses of an eye within 24 hours. One can call their local OSHA office if the office is open. Do NOT send an email, fax or leave a voice mail.

Call the OSHA number at 1-800-321-OSHA (6742) or complete the Serious Event Reporting Online Form found at www.osha.gov/pls/ser/serform.html

Be prepared to state the business name, location, and time of the incident, names and number of fatalities or hospitalized, name and number of contact person and a brief description of the incident. A call can be placed immediately if there is an imminent life-threatening situation. A heart attack that occurs in the workplace would need to be reported.

Dial “911” for all emergencies where outside help is required. If the phone system requires you to dial a number to get an outside line (like “9”), be sure to dial it first (i.e., “9-911”). Some facilities may have a special emergency number. Ensure all staff know the correct number to call.

3-2


EMERGENCY PHONE LIST

Note: A master copy of this form is located behind Tab 11: Master Record Forms (Form 7-A)

Keep this emergency phone list current and easily available. It is important to have your exact business address listed here. Be sure that it is not the corporate address. If there is a special door that responders should enter, it should also be listed here.

Name Telephone Number

OSHA 1-800-321-OSHA (6742)

Rescue Squad

Police Department

Fire Department

Hospital Emergency Room

Public Health Department

Equipment Repair

Infectious Waste Disposal Carrier

Safety Officer

Structural Failure

Poison Control Center

Electrician

Sprinkler Company

Heating/Air Conditioning Repair

Fire Extinguisher Company

Elevator Inspector

Gas/Fuel Company (if gas or fuel heat)

Compressed Gas Distributor

3-3


Fire SafetyOSHA addresses fire safety under the General Industry Standards (29CFR1910). Facilities under construction should consult the edition of the of the National Fire Protection Agency (NFPA) Life Safety Code adopted by your state or federal regulating agency for more detailed information. States may follow additional building codes. In any situation, the strictest building code rules will apply.

Automatic Sprinkler Systems

Ensure that those responsible for building maintenance perform preventive maintenance at least once a year on automatic sprinkler systems according to state and local building codes and the currently approved edition of NFPA 25.

Fire Alarms

OSHA standards require that most workplaces have an alarm or signal system to alert employees of the outbreak of fire and the need to evacuate. The National Fire Protection Association (NFPA) 72 fire code requires that business occupancies have a fire alarm system when the building is two or more stories in height, has 50 or more occupants above or below the level of exit discharge, or has 300 or more occupants. Those responsible for building maintenance should have the quarterly, semi-annual and annual fire alarm testing results on file, depending on the complexity of the fire alarm system in the building. All the elements included in the currently approved edition of NFPA 72 need to be addressed on the test report.

The alarm system for smaller medical practices may be voice communication or sound systems such as bells, whistles or horns. In either case, employees must know the alarm procedure, where to find alarms and how to sound or activate them.

Fire Procedures: Immediate Actions

If you smell something burning, but see no smoke:

Contact the Safety Officer to come and investigate

Activate the building fire alarm system, if necessary

Call 911 or the approved emergency number, if necessary

3-4


If smoke or fire is sighted, act quickly following “R A C E”:

Rescue those in immediate danger.

Alarm— Activate the fire alarm. Announce Code Red (or the fire announcement for your facility), call 911(or the approved emergency number) and give exact location of fire, as well as your exact street address, your name and type of fire (if known). Let the operator hang up first.

Contain the fire by closing all doors and windows. Remove all equipment and obstructions from the hallways to assist with evacuation.

Extinguish or Evacuate.

Building Evacuation

OSHA’s Emergency Action Plan standard, 29CFR1910.38, requires the immediate evacuation of the workplace (see page 3-20) in the event of a fire or other emergency. Evacuation is a prudent option even if portable fire extinguishers are available.

Evacuation includes horizontal movement into an adjacent smoke compartment, vertical evacuation and partial or complete building evacuation.

If your plan calls for evacuation, confirm with employees that they are not expected to fight fires with the extinguishers provided in the workplace. The extinguishers are only for employees designated and trained to fight fires in the incipient stage (beginning stage where the fire is small and contained). Training for these employees must be conducted annually and in accordance with the Fire Extinguishers section below.

Check with your local fire authority for the classification of your business under the Life Safety Code of the National Fire Protection Association, as some classifications have greater fire prevention and response requirements than others. For example, ambulatory surgery centers have greater fire requirements than a clinic in a business occupancy.

If time allows, close all doors behind you as you leave. Do not use elevators. Do not run. Follow the evacuation route that you have customized in this OSHA Program Manual on page 3-20.

Fire Extinguishers

Portable fire extinguishers (Figure 3-1, following page) have two functions: to control or extinguish small or incipient stage fires and to protect evacuation routes that a fire may block directly or indirectly with smoke or burning/smoldering materials.

3-5


To extinguish a fire with a portable extinguisher, a person must have immediate access to the correct type of extinguisher, know how to actuate the unit, and know how to apply the agent effectively. Attempting to extinguish even a small fire carries some risk. Fires can increase in size and intensity in seconds, blocking the exit path of the person attempting to fight the fire and creating a hazardous atmosphere. In addition, portable fire extinguishers contain a limited amount of extinguishing agent and can be discharged in a matter of seconds. Therefore, individuals should attempt to fight only very small or incipient stage fires.

Figure 3-1

OSHA requirements for fire extinguishers are as follows:

Purchase the right extinguisher for the type of fire anticipated at the facility

Locate extinguishers where they are readily accessible for immediate use and in sufficient quantity and size to deal with a potential fire

Inspect and maintain fire extinguishers monthly and annually to ensure that they are in good operating condition

Train designated personnel to operate fire extinguishers

3-6


Purchase the Right Extinguisher

Fire extinguishers are classified according to the type of fire they will extinguish:

Class A fire extinguisher: Fires involving ordinary combustibles such as wood, paper, some plastics, and textiles. A green triangle containing the letter “A” usually identifies these extinguishers.

Class B fire extinguisher: Fires involving flammable liquids and oil, gasoline, etc. These fire extinguishers deprive the fire of oxygen and are often identified by a red square containing the letter “B.”

Class C fire extinguisher: Fires involving live electrical equipment. Once the electrical equipment is de-energized, extinguishers for Class A or B fires may be used. A blue circle containing the letter “C” identifies these extinguishers.

Class D fire extinguisher: Fires involving combustible metals such as magnesium, titanium, sodium, etc. A five-point yellow star identifies a Class D extinguisher. These extinguishers are usually not required in medical practices.

Class K fire extinguisher: Fires involving combustible cooking fluids such as oils and fats. Class K fire extinguishers are required to be installed in all commercial kitchens, including those found in restaurants, cafeterias, and caterers. Class K fire extinguishers are only intended to be used after the activation of a built-in hood suppression system. If no commercial cooking system hood and fire suppression system exists, Class K extinguishers are not required.

Clean Agent ABC extinguishers are available in non-ferrous (non-magnetic) cylinders for use near MRI locations. These non-magnetic ABC cylinders are often white or silver in color. Other ABC extinguishers with chemical agents are often in red cylinders (ferrous/magnetic) and should never be brought near the MRI as the magnet will pull the cylinders into the gantry and damage the magnet.

Water-mist fire extinguishers are good for Class A and even Class C (electrical fires). The extinguishers contain deionized water so that there is no risk of electrical shock. Water-mist fire extinguisher cylinders are often white with blue trim. Most water-mist cylinders are approved for use near MRI equipment rated up to three tesla.

Fire extinguishers are also marked with a UL rating. This rating compares the effective-ness of different fire extinguishers. For example, a UL rating on a fire extinguisher that says 4A: 20B:C indicates the following:

4A is the water equivalency rating. Each A is equivalent to 1¼ gallons of water. So, in this example, the extinguisher is equivalent to five gallons of water.

20B refers to the rating for the amount of square footage that the extinguisher can cover when handled by a professional. In this example, 20B is equivalent to 20 sq. ft. of coverage.

The C rating indicates that the extinguisher is suitable for use on electrically energized equipment.

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How Many Fire Extinguishers to Have & Where to Put Them

OSHA requires that employers select and distribute fire extinguishers based on the classes of anticipated workplace fires and on the size and degree of the hazard, which would affect their use. Class A or ABC fire extinguishers must be mounted within 75 ft. of areas containing combustible materials (paper, wood, etc.) and within 10 ft. of any inside storage area containing such materials.

The following chart contains OSHA requirements for classes of fires and allowable travel distance to an extinguisher. Some local requirements may be stricter, so check with your local fire marshal and insurance agent.

Fire Class Travel DistanceClass A 75 feet or less

Class B 50 feet or less

Class C 50 feet or less

Class D 75 feet or less

Class K 30 feet for less

Locations of fire extinguishers must be identified with a sign, if not readily apparent. To prevent fire extinguishers from being moved or damaged, mount them on brackets or in wall cabinets with the carrying handle placed 3 1/2 to 5 ft. above the floor. Check that fire extinguishers are not blocked or inaccessible. Ensure employees know how to operate fire extinguishers. Review the operation of fire extinguishers annually.

To Use a Fire Extinguisher: Think “PASS”

Pull the activation pin.

Aim the nozzle at the base of the fire.

Squeeze the handle to release the extinguishing agent.

Sweep the stream over the base of the fire.

When to Extinguish Fires with a Portable Fire Extinguisher

The fire is limited to the original material ignited.

The fire is contained (such as in a wastebasket) and has not spread to other materials.

The flames are no higher than the person’s head.

The fire has not depleted the oxygen in the room and is producing only small

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quantities of toxic gases. No respiratory protection equipment is required.

Heat is being generated, but the room temperature is only slightly increased. Smoke may be accumulating on the ceiling, but visibility is good. No special personal protective equipment is required.

When NOT to Extinguish the Fire and to Evacuate

The fire involves flammable liquids, has spread more than 60 sq. ft., is partially hidden behind a wall or ceiling, or cannot be reached from a standing position.

Due to smoke and products of combustion, respiratory protection is necessary to fight the fire.

The radiated heat is easily felt on exposed skin, making it difficult to approach.

Fire Extinguisher Inspections

Visually inspect portable fire extinguishers monthly to ensure that:

Fire extinguishers are in their assigned place.

Fire extinguishers are not blocked or hidden.

Fire extinguishers are mounted correctly, with the nameplate containing operating instructions legible and facing outward.

Pressure gauges show adequate pressure.

Pin and tamper seals are in place.

Fire extinguishers show no visual sign of damage, corrosion, or leakage.

Nozzles are free of blockage.

Heft the extinguisher to estimate the weight.

See sample fire extinguisher quick check diagram following page 3-8 of this section.

Fire Extinguisher Maintenance

All fire extinguishers must be serviced, maintained, and tagged annually by qualified individuals. They must always be fully charged and in designated places. Contact your local fire department or fire extinguisher vendor regarding annual fire extinguisher maintenance.

Fire Risks During Surgery

Of the several hundred surgical fires that occur each year, some result in serious harm to the sedated patient.

Fire extinguisher supplement Display as a quick reference guide


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Because operating suites and procedure rooms usually contain ignition sources, fuel sources, and a high oxygen content, they are high-risk environments for fires. Take the following measures to prevent surgical fires from occurring:

Keep ignition sources away from flammables. Items such as electrosurgical units, lasers, certain drills, fiber-optic devices, and electrocautery units can create sparks during a surgical procedure and also produce temperatures hot enough to start a fire. For example, the hot tip of an electrocautery unit laid on a garment or near prepping agents, instead of in its holster, can ignite those materials.

Keep fuel sources away from heat-producing surgical equipment. Wet prepping agents, surgical draperies, and items in the patient’s airway, such as a tracheal tube or sponge, can be flammable when near heat-producing surgical equipment. Do not let prepping agents pool near or under a patient, and allow sufficient drying time for prepping agents before beginning surgery. The required drying time should be discussed before a procedure begins. This “time- out” requires everyone involved to stop and pause to verify the correct person, correct procedure, correct location on the body and any fire risk that may be present. No one involved in the procedure should enter the room after the “time-out” has been completed or the “time-out” should be repeated. Some flammable surgical germicides are labeled as fire risks. Some indicate they should not be use on a patient for a procedure above the neck or near facial hair as it takes a long time for the prep to dry.

Keep oxygen levels low and leaks to a minimum. Oxygen-enriched environments are created by the supply of anesthesia or oxygen to a patient and are potential hazards. These gases act as oxidizers and encourage combustion at lower temperatures. Keep oxygen concentrations in the surgery suite/procedure rooms as low as possible and attempt to reduce the oxygen concentration when a heat-producing device is introduced. Also, be sure that oxygen leaking around nasal cannulas or mouthpieces is not allowed to accumulate under the patient’s draperies. If a spark reaches a drapery, a fire can quickly accelerate out of control.

What to Do if a Surgical Fire Starts. If a fire starts, immediately cut or tear off any burning material from the patient. Use a CO2 extinguisher if tearing the material is ineffective. Water mist extinguishers, as opposed to traditional water extinguishers, are also options for surgical fires. Water mist canisters decrease the risk of electrocution/shock because the mist doesn’t pool as easily as water spray and the water is deionized and will not conduct an electrical current. Some surgical draperies are liquid-resistant; if doused with an extinguisher, water merely beads up on them.

Fire Drills

Federal OSHA does not specifically require fire drills, but your state OSHA plan, local fire authority, or other regulatory authority might. Check the requirements. CMS and other regulatory agencies require ambulatory surgery centers to conduct quarterly fire drills. As

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a best practice, business occupancies and medical offices should conduct fire drills at once per year, during or after office hours. Include scenarios such as designating a staff person to remain in a room as a patient to be sure that staff members perform a search for patients before evacuating the building. Use the Fire Drill Evaluation Form (Form 5-A) and an Employee Fire Drill Participation Sign-up Sheet (Form 5-B) located behind Tab 11: Master Record Forms.

Electrical Safety

Safety when working around electrical equipment is vital to avoid injuries of employees as well as equipment and property. Before beginning a job with electrical equipment, be sure to check the wiring. Grounding is a critical form of protection that connects the equipment to the earth, providing a low-resistance path for the current. Most tools and equipment are grounded. Metal frames or covers on electrical equipment and three-pronged plugs provide additional grounding. To ensure electrical safety in your facility:

Check all electrical cords annually for defects (fraying, cuts, etc.). Report any defects to the OSHA Safety Officer, and remove equipment from service until the defect is repaired.

Check outlets annually for proper voltages and grounding. All outlet/light switches must be covered. Check that combustibles are not stored directly in front of outlets.

Position all equipment so the cords do not present a tripping hazard, or so it is not possible for cords to get wet. Do not touch electric equipment with wet hands.

Be sure no two-pronged medical equipment is in use—three-prong grounded plugs are required. Two-prong plugs are okay for lamps, clocks, radios, etc.

Ensure extension cords are not being used as permanent wiring. Check that outlets contain only plugs that fit the outlet. Be sure that electrical connections are tight.

Immediately remove from use any equipment that produces a tingling sensation until it can be serviced. Unplug all equipment before service.

Leave at least three feet of workspace around electrical equipment for easy access. This includes the circuit breaker box.

Check outlets to ensure that there are not too many pieces of equipment plugged into the same outlet.

Be sure that power strips (relocatable power taps) and surge protector strips as not plugged into one another to form a chain. All medical equipment must be plugged directly into an outlet.

Be sure that no liquids are stored on top of a piece of electrical equipment.

Check that cords are not running under rugs or through doorways.

Check that staff turns off electrical equipment before cleaning or routine maintenance.

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Physical Characteristics of a Safe Medical Facility

Here are some basic OSHA requirements for a safe workplace.

Automated External Defibrillators

Each year, up to 400,000 people die from cardiac arrest, and some of these deaths occur in the workplace. About 500 workplace fatalities are reported to OSHA annually from cardiac arrests.

When administered within a few minutes of a cardiac arrest, automated external defibril-lators (AEDs) can increase survival rates from less than 5% to nearly 75%. Immediate defibrillation can revive more than 90% of victims. Although not an OSHA requirement, OSHA’s 2006 Best Practices Guide: Fundamentals of a Workplace First-Aid Program encourages employers to make AEDs available in workplaces. The Agency estimates that if AEDs revive only 40% of those who suffer a cardiac arrest, as many as 160 work-er lives could be saved yearly. If your facility has AED devices, they should be inspected and tested according to the manufacturer’s directions.

Air Quality

If a building does not receive an adequate amount of conditioned outside air, it is susceptible to a build-up of chemical, biological and particle emissions, as well as irritant gases and moisture.

Recommendations and guidelines for air quality are made by the American Society of Heating, Refrigerating and Air Conditioning Engineers located in Atlanta, Georgia. The current recommended air exchange rate for a medical office examination room is 6 air changes per hour with 2 outside air exchanges per hour. For other areas, the recom-mended air exchange rates depend on the use of a room. For instance, special arrange-ments are recommended for seeing patients with contagious infectious diseases such as:

Making efforts to see these patients at the end of the day.

Quickly triaging these patients out of common waiting areas.

Closing the door of the examining room and limiting access to the patient by staff members who are not immune to the suspected disease.

The duration of time that airborne infectious droplet nuclei remain in a room depends on air exchange rates. For example, in hospitals where air exchange rates are 6-8 per hour, several air exchanges usually occur within 30-60 minutes depending on the size and configuration of the room. In most medical clinics, the air exchange rates are much lower and rooms may not be free of airborne infectious agents for several hours. One way to find out how long a room should be out of service is to have facilities or building

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maintenance staff determine the air exchange rates for different areas where infectious patients might be waiting or seen by clinicians.

“Sick building syndrome” is a term used to describe a condition whereby about 20% or more of a building’s occupants experience a variety of poorly defined symptoms (e.g., headache; eye, nose or throat irritation; dry cough; dry or itchy skin; dizziness and nausea; difficulty in concentrating; fatigue; and sensitivity to odors). The cause of the symptoms is not known and they usually worsen over the length of the day and often stop when the occupants leave the building.

Typical temperatures and humidity levels for medical office buildings should maintain an indoor environment that is thermally acceptable to 80% of a building’s occupants. This translates to an indoor temperature range of 68° F to 75° F in winter and 73° F to 81° F in summer, with a corresponding relative humidity range of 20% to 60%.

Unpleasant or strange odors in the building may be signs that something is wrong with the air supply system. Odors are often carried by the HVAC system, making it difficult tolocate the original odor source. Odors may be eliminated by retrofitting HVAC systems with activated charcoal filters or by contracting a qualified professional industrial hygiene company to clean and maintain them.

The OSHA Safety Officer is responsible for responding to concerns about air quality issues. Indoor air quality complaints will be taken seriously and investigated. If practical and warranted, employees and patients will be removed from the affected area until the complaint can be investigated and the problem rectified. All complaints will be documented on the Safety Report. A master copy of the Safety Report is located behind Tab 11: Master Record Forms (Form 1).

Mold

Molds grow without sunlight, needing only a spore, a nutrient source, moisture, and the right temperature to proliferate. This explains why mold infestation is often found in damp, dark, hidden spaces. Molds cause a variety of negative health effects and also gradually damage furnishings and building materials, weakening floors and walls.

Large-scale mold infestations will need to be abated professionally, however, individuals without experience with mold remediation can often judge whether mold contamination can be managed in-house or whether outside assistance is required. The advice of a medical professional should always be sought if there are any emerging health issues.

Moisture control is the key to mold control. When water leaks or spills occur indoors—act promptly! Any initial water infiltration should be stopped and cleaned promptly. A prompt response (within 24 to 48 hours) and thorough cleanup, drying, and/or removal of water-damaged materials will prevent or limit mold growth.

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To prevent mold:

Repair plumbing leaks and leaks in the building structure as soon as possible.

Look for condensation and wet spots. Fix source(s) of moisture incursion problem(s) as soon as possible.

Perform regularly scheduled building/HVAC inspections and maintenance, including filter changes.

Maintain indoor relative humidity below 70% (20% to 60%, if possible).

Vent cooking areas (if present in the break room) and bathrooms according to local code requirements.

Clean and dry wet or damp spots as soon as possible, but no more than 48 hours after discovery.

Provide adequate drainage around buildings and slope the ground away from building foundations. Follow all local building codes.

Pinpoint areas where leaks have occurred, identify the causes, and take preventive action to ensure that they do not reoccur.

Exposure to mold can irritate the eyes, skin, nose and throat. Molds can cause immediate or delayed allergic reactions. Responses include hay fever-type symptoms such as runny nose and red eyes. Molds can cause localized skin or mucosal infections but, in general, do not cause systemic infections, except for persons with impaired immunity, AIDS, uncontrolled diabetes, or those taking immune suppressive drugs.

If unsure whether a mold problem exists, consider the following:

Are building materials or furnishings visibly moisture damaged?

Have building materials been wet more than 48 hours?

Are there existing moisture problems in the building?

Do staff/patients report musty or moldy odors?

Do staff report health problems that they think are related to mold in the indoor environment?

Has the building been recently remodeled?

Has routine maintenance been delayed?

Mold Remediation

If a mold issue is suspected, the first step is to inspect for any evidence of water dam-age and visible mold growth. Don long sleeved clothes, heavy-duty gloves that extend to the middle of the forearm, goggles that prevent the entry of dust and small particles (safety glasses or goggles with open vent holes are not appropriate) and an N95 res-pirator (a medical clearance and fit test is necessary for those who wear N95s) or a

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medical powered air purifying respirator (PAPR). It is prudent to remove occupants from the area while doing this inspection. Some facilities run a HEPA filter during this process to capture any mold spores that may become airborne during the inspection process.

Look at ceiling tiles, wallboard, insulation, HVAC ducts, joists, etc. for signs of mold to assess the extent of the mold problem and the type of damaged materials. As a general rule, simply killing any mold found is not enough. The mold must be removed since even dead mold contains chemicals and proteins that cause reactions. Mold contamination falls into one of four categories, based upon severity:

Level I: Small Isolated Areas

Level II: Mid-Sized Isolated Areas

Level III:Large Isolated Areas

Level IV: Extensive Contamination

Area affected <10 sq. ft. 10-30 sq. ft. 31-100 sq. ft. >100 sq. ft.

Personnel authorized to remediate

Building maintenance staff*

Building maintenance staff*

Professional consultation required**

Professional consultation required**

* Remediation can be conducted by the regular building maintenance staff as long as they are trained on proper clean-up methods, personal protection, and potential health hazards. Follow the guidance at www.osha.gov/dts/shib/shib101003.html.

** When hiring outside assistance, make sure the contractor has experience with mold remediation. Check references and ask the contractor to follow the recommendations in EPA’s publication, “Mold Remediation in Schools and Commercial Buildings,” or other guidelines developed by professional or governmental organizations.

The highest priority during cleanup is the health and safety of those involved—both regular staff and those performing mold remediation activities. Use caution to prevent mold and mold spores from being dispersed throughout the building. In some cases, especially those involving large areas of contamination, temporary relocation is highly recommended. Eating, drinking, and using tobacco products and cosmetics where mold remediation is taking place should be avoided. This will prevent unnecessary contamination of food, beverage, cosmetics, and tobacco products by mold and other harmful substances within the work area.

Aisles

Keep carpets and floors dry and free of tripping hazards. Aisles must be more than 36-44 inches wide. Do not block aisles, cubicles or exits with storage boxes, plants, surplus furniture, equipment, etc. Dispose of trash and rubbish (especially combustible material) frequently to avoid accumulation in aisles and egress routes.

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Emergency Lighting

If it’s required by fire code, emergency lighting must function for a period of at least 1½ hours in order that individuals involved in an emergency can move about safely. Some occupancy types do not require emergency lighting. Your staff or those responsible for building services must test emergency lighting monthly for 30 seconds and annually for 90 minutes to be sure it functions properly.

Employee Dress Code

Most healthcare facilities set their own company policies that prohibit sandals, tank tops, miniskirts, unnatural hair colors and face piercings in the workplace, but this is not an OSHA or a safety issue. OSHA requires that employees be protected from blood, body fluids and hazardous chemicals. The employer must provide protective garments such as shoe covers when employees enter areas where contamination could be reasonably anticipated if sandals or open toed shoes are allowed. To minimize workplace incidents, designate these areas as “restricted areas.”

The extent to which you want to govern employee appearance depends on the image your practice wishes to convey to the public.

Exits, Means of Egress

To ensure safe evacuation, OSHA standards include minimum requirements for location, design, marking and maintaining exits and ways of access to exits. Each workplace building must have at least two means of egress, remote from one another, to be used in a fire or emergency. This is to minimize the possibility that both exits may be blocked by any one fire or other emergency condition.

OSHA uses the term “means of egress” to designate the route to get out of a building to safety. The most common example is an exit door and the pathways to it, through it, and away from it to a place of safety.

In no case should an exit be through a bathroom, or other room subject to locking, except where the exit is required to serve only the room subject to locking.

Any door, passage or stairway which is neither an exit nor a way of exit access, and which is situated in such a way that it could be mistaken for an exit, must be identified by a sign reading “Not an Exit,” “NO Exit” or similar designation.

Alternatively, a sign indicating the actual name or use of the area (e.g., “To Basement,” “Storeroom,” “Linen Closet”) is acceptable. This is to minimize the danger of persons

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endeavoring to escape from a fire, but finding themselves trapped in a dead-end space, such as a cellar or storeroom, from which there is no other way out.

The minimum width of any exit access must be no less than 28 inches. Where snow or ice is likely, the exterior of the exit should be protected by a roof, or regularly cleared off in the course of normal occupancy.

The distance to an exit from the inside of any building is specified by NFPA 101, the Life Safety Code®. Most office buildings were built to comply with NFPA 101, but changes could occur over time to render the building non-compliant.

The “common path of travel” is the distance from the farthest, most remote occupied point in a building, to a point where occupants can choose to travel to one of two separate exits. The distance is measured along a normal walking pattern to this point, not necessarily a straight line. Office modifications can hamper egress procedures by introducing dead ends, encroaching on traffic patterns and reducing already minimal egress widths. Added cubicles are the most frequent culprits behind violations of the Life Safety Code.

Exit Doors

Exit doors and pathways to them must always be clear of permanent or temporary obstructions, be wide enough to accommodate the number of people trying to get out, and be strong enough to support their weight. Exit doors must be of the side-hinges, swinging type. Do not place hangings, draperies or pictures on exit doors. Do not place mirrors adjacent to an exit in such a manner as to confuse the direction of exit.

Exit Signs

OSHA requires exit signs to have the word “EXIT” legibly marked. The letters need to be at least six inches high with a stroke width (thickness) not less than ¾-inch wide. Exit signs must be distinctive in color and provide contrast with decorations, interior finish or other signs. That means that if the typical red and white exit sign blends in with the background, consider using other colors such as green and white or black and yellow.

Place exit signs with directional arrows in locations where the direction of travel to the nearest exit is not immediately apparent. OSHA also requires that exit signs be suitably illuminated with a reliable light source providing not less than five foot-candles (a measure of the amount of light falling on an object; 1 foot-candle = 1 lumen per square foot) on the illuminated surface. Internally illuminated exit signs are required in all occupancies where reduction of normal illumination is permitted.

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Floors

Although OSHA takes a dim view of carpet for patient exam rooms and other areas that are likely to be contaminated with patient blood or body fluids, the Agency does not forbid the use of fiber-based floor coverings. Since carpet must be disinfected after every instance of contamination, the carpet will likely become bleached or spotted from frequent decontamination and will need to be replaced.

Since carpets in patient care areas will invariably contain much higher levels of microbial contamination than hard-surfaced flooring and can be difficult to keep clean in areas of heavy soiling or spillage, more thorough and frequent cleaning and maintenance procedures are indicated using a disinfectant-detergent formulation.

Lighting

Lights, including emergency lighting, must be functioning and covered.

Noise

OSHA’s Hearing Conservation Amendment, part of the Occupational Noise Standard (29 CFR, Part 1910.95), identifies a safe noise level of less than 90 decibels (dB) based on an eight-hour time-weighted average (TWA). Any eight-hour TWA exceeding 85 dB is an “action level” requiring the employer to implement a hearing conservation program to reduce and monitor noise levels.

Sound is measured in decibels (dB). 10 dB is 10 times greater than 1 decibel (10 x 1) and 20 decibels is 100 times greater than 1 decibel (10 x 10). The following list contains typical noise levels emitted from common sources.

30 dB—whispering in a library 50 dB—rain falling 70 dB—alarm clock ringing, car running, coffee grinder grinding 90 dB—power lawnmower running, passing motorcycle 110 dB—snow blower, car horn, power saw 130 dB—jet engine at 100 feet, air-raid siren 150 dB—firecracker

It is very unlikely that any instrument used in a medical setting would exceed OSHA noise limits, even cast cutters. To determine if a particular procedure or piece of equipment exceeds permissible noise levels, contact the manufacturer’s technical service department for the decibel level or take a decibel reading. If found to be below OSHA’s permissible noise levels, but employees continue to be concerned, earplugs

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may be worn during the procedure providing that decibel level testing is documented to show that It falls under the OSHA action level. Training should also be provided to workers wearing hearing protection.

Portable Space Heaters

Business occupancies such as a freestanding medical and dental offices and clinics have no space heater restrictions, but other occupancy classifications do. The Life Safety Code by the National Fire Protection Association generally prohibits space heaters in healthcare occupancies such as hospitals, nursing homes, and ambulatory occupancies such as surgery centers. But there is an exception to the rule: Space heaters can be used in an employee-only area as long as patients do not sleep or are treated in that smoke compartment and the heating element of the heater does not exceed 212°F and automatically shuts off if tipped over. Be sure to verify your occupancy category with the building manager or your local fire authority.

Restricted Access Areas

A basic principle of infection prevention is to prohibit smoking, eating, drinking, applying cosmetics or handling contact lenses where there is potential for occupational exposure to blood and body fluids. Post signs (biohazard, exits, x-rays, chemotherapy, etc.) as appropriate to control employee and patient access to hazardous areas.

Sinks

While OSHA does not mandate placement of handwashing sinks, many state healthcare building codes require that a sink must be available in every patient care room even when alcohol rinses can suffice for handwashing when hands are not visibly soiled. Always locate a sink in areas where employees perform procedures that could soil their hands with blood or body fluids. Keep sinks free from leaks and blocked drains. Do not store paper goods (including cardboard boxes) or patient care items under sinks.

Storage

Items in storage should not be stored higher than five feet unless a stepstool or ladder is accessible. Don’t allow items to be stored closer than 18 inches from the ceiling below sprinkler heads. Stacked items must be stable and secured. Keep stored items at least three feet from a heat source, fire extinguisher, oxygen shut-off valve, or electrical panel. Do not store combustible items directly in front of outlets.

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Systems Failure

The staff should know what to do in the event of a power failure, telephone outage, or other systems failure. Record the names of individuals and/or companies to call in the event of such an emergency:

System Failure Who to Contact What to Do

Power Failure— Generators are Working

Use power appropriately to maintain essential functions, such as medical equipment, backing up of computer data, or obtaining urgent medical data to provide to emergency personnel.

Electrical Power— Total Failure

Discontinue all nonessential services. Utilize flashlights to evacuate people to the outside. Inform employees when and how to check back about reporting to work.

Elevators out of Service

Use stairwells. Review fire and evacuation plans.

Elevators Stopped Between Floors

Call building maintenance and keep verbal contact with people in elevator to let them know that help is on the way.

Fire Alarm System or Sprinkler System Disabled

Evacuate the building or institute a fire watch if the fire alarm system is down for more than 4 hours in a 24-hour period or the sprinkler system is out of service for more than 10 hours in a 24-hour period; minimize fire hazards. Use phone/runner to report fire. A dedicated person must conduct the fire watch and have no other duties.

Patient Care Equipment

Remove from service and tag defective equipment. Transfer patients as necessary.

Water: Sinks, Toilets Inoperative

Conserve water; use bottled water for drinking. Be sure to turn off water in sinks before evacuating building.

Water: Non-potable Acquire bottled water. Use for drinking. Place “Do Not Drink” signs on all drinking fountains and sinks. Label ice machines or trays “Not for Human Consumption.”

Sewer Stoppage Do not flush toilets. Do not use water. Restrict access to unsafe areas.

Telephones out of Service

Use pay phones or emergency phones. Use e-mail if available. Use runner/messenger system.

Ventilation Open windows, obtain blankets, fans, etc., until facility can be evacuated. Restrict use of odorous/hazardous materials.

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Evacuation Plan

Facilities with 11 or more employees must have a written evacuation plan. Although OSHA and many other regulators do not require evacuation maps, many healthcare facilities find it helpful to post it in the front office area, the break room and on the back of each exam room door. Employees must read the evacuation plan, including a review of evacuation routes, upon initial hire and whenever changes are made to the plan. Employees are to be trained at least annually.

Emergencies that may require some level of evacuation (horizontal, vertical or out of the facility) include:

Bomb threat

Chemical release/natural gas leak/radiation release

Fire/explosion

Aircraft/train/vehicle incident nearby

High winds (expected and unexpected), other severe weather situations

Civil unrest or outside disturbance

Person with a weapon

Evacuation ProceduresCall 911 (or approved emergency number) and activate internal alarm system. This

internal alarm system consists of (check one or more):

Alarm (describe): ________________________________________________

Public address system announcement (describe): ______________________ ______________________________________________________________

Verbal announcement (describe): ___________________________________

Evacuate patients, visitors, or personnel closest to the danger first. Close any fire doors between the danger and the individuals. Ensure the exit corridors are cleared of any equipment or obstructions. Follow the evacuation route in this OSHA Program Manual.

Assist visitors and patients to the outside assembly point (e.g., parking lot) at least 50 ft. from premises. Alternative locations may be identified as the situation requires.

Move non-ambulatory patients by means of appropriate carriers (wheelchairs/gurneys). If carriers are not available, use the Hip Carry, Cradle Drop, Swing Carry, or Extremity Carry (see below). Evacuation equipment such as evacuation sleds/slides or evacuation stair chairs may be available. This equipment should be included in the evacuation plan and a staff training program implemented.

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In the event of an emergency, the following employee(s) are to remain in the workplace to shut down or monitor critical operations such as turning off machinery or protecting hazardous chemicals before they evacuate (enter employee names or job titles): ________________________________________ ________________________________________________________________.

During an emergency, the following employees are to perform rescue or medical duties (enter employee names or job titles): ______________________________ ________________________________________________________________.

Employees then proceed to this same assembly point (e.g., parking lot) and await instructions from the OSHA safety officer, who will conduct a head count to ensure full evacuation of employees from premises.

Evacuate internally in the event of unexpected high winds (i.e., tornado warning). In the event of an outside disturbance/riot, lock the doors and call 911 or the approved emergency number. Internal assembly will be (state location): ____________________________________________________ ________________________________________________________________.

Do not linger or leave premises unless instructed or as imminent danger dictates.

Do not return to building unless instructed to do so by the OSHA safety officer or local response agency.

Do not stand near glass windows during high wind conditions.

Take all events, alarms, and drills seriously.

Methods for Carrying Patients During an Evacuation

Hip Carry (One Person)—Roll patient onto his or her side. With your back towards the patient, pull his arm over your shoulder and slide your other hand under the patient’s armpit. Release your hold on the patient’s arm, grip behind knees, then pull the patient against your hips and straighten up. To unload, back up against wall, drop to one knee and let patient slide down against wall to floor.

Cradle Drop (One Person)—Fold blanket in half lengthwise and place it on the floor beside the exam table or chair. Slide one arm under the patient’s neck and shoulders and the other under patient’s knees. Pull patient to the end of the table/chair, drop down to one knee and lower patient so that your knee supports patient’s back. Let patient slide gently to the blanket and pull from room headfirst on blanket.

Swing Carry (Two Persons)—The first person raises the patient to a sitting position at the edge of the chair or exam table and places one arm behind the patient’s shoulder and the other arm under the patient’s knees. The second person places one arm behind the patient and grasps the first person’s shoulders, then places the other arm under the patient’s knees and grasps the first person’s wrist. The patient sits on rescuers’ clasped hands and wrists and leans back against their arms.

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Extremity Carry (Two Persons—The first person raises the patient to a sitting position, then, from behind, reaches under the patient’s armpits and grasps his or her own wrists in front of the patient’s chest. The second person moves between the patient’s legs with his or her back to the patient and encircles the patient’s legs at the knees with each arm. The first person hugs and lifts, the second carries the patient’s legs while the patient is moved feet first.

EVACUATION FLOOR PLAN

Draw the floor plan of your medical facility, clearly noting exits and fire safety equipment.

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EXAMPLE EVACUATION FLOOR PLAN

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Emergency Preparedness Supplies

To prepare for emergencies that temporarily deny access to the medical facility, consider storing some materials off site. While it may be impractical to keep a sizeable collection of the following in one location solely in preparation for an emergency/disaster, create a cache of all the items that may be needed and would not otherwise be reliably available:

___Flashlights ___Cellular phone and charger ___Pulse oximeter ___Stethoscope ___Blood pressure cuffs ___Thermometers ___Otoscopes/ophthalmoscopes ___ACLS kit ___Necessary medications (analgesics, antibiotics) ___Wound care supplies (gauze, gloves, tape, suture supplies) ___IV/phlebotomy supplies ___Oxygen with needed accessories ___Insurance forms ___Lab request forms ___Copy of phone tree ___Progress note sheets ___Medical reference books ___Patient list ___Prescription pads ___Pens and paper ___Weather radio

Moreover, certain types of emergencies/disasters will require additional off-site resources—a generator (tested and ready), a complete back-up set of patient records or access to electronic records, insurance forms, etc.

Emergency Action Procedures

Having a safe medical facility means more than just knowing what to do in a fire, or having the proper safety equipment. It’s also knowing what to do in a wide variety of other emergency situations.

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Bioterrorism: Suspicious Letters or Packages

What is a “Suspicious Package”?

Packages with any of the following characteristics:

Restrictive markings, such as “personal”

Excessive postage

Mailed from a foreign country

Badly typed or poorly written label with misspelled words

No return address

Addressed to a title only, or wrong title with a name

Lopsided, rigid or bulky

Strange odor

Wrapping with oil stains

Evidence of white powder or other powdery substances

If you receive a suspicious package or letter:

Do not handle the piece of mail or package suspected of contamination

Isolate it and cordon off the area

Require all persons who have touched the item to wash their hands with soap and water

Notify your local law enforcement authorities

List all persons who have touched the item with their contact information

Have this information available for the authorities

Place all items worn when in contact with the suspected mail in plastic bags and have them available for law enforcement agents. If possible, change clothing at the workplace

As soon as practical, shower with soap and water

If requested by your local health department, notify the Center for Disease Control Emergency Response at 800-232-4636 and answer any questions they may ask

Local health officials will determine whether exposed employees will need antibiotic prophylaxis. In most circumstances, this decision will be delayed until the presence or absence of Bacillus anthraces is determined

Bomb Threat

Most bomb threats are received by phone. Bomb threats are serious until proven otherwise. Act quickly, but remain calm and obtain information.

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If you receive a telephone bomb threat:1. Remain calm. Keep the caller on the line for as long as possible.DO NOT HANG UP, even if the caller does. 2. Listen carefully. Be polite and show interest. 3. Try to keep the caller talking to learn more information. 4. If possible, write a note to a colleague to call the authorities or, as soon as the

caller hangs up, immediately notify them yourself. 5. If your phone has a display, copy the number and/or letters on the window display. 6. Write down as much detail as you can remember. Try to get the exact words.

– Listen for background noises, such as music, voices, or cars

– Note how the caller’s voice sounds. Accent? Gender? Age? Any unusual words or phrases?

– Does the caller seem to know specifics about your office? How is the bomb location described? Does the caller use a person’s name? Does the caller give his/her name?

– When the call is over, record as much of the previously mentioned information as possible, unless the alleged or predicted detonation time given does not permit completion

7. Immediately upon termination of the call, DO NOT HANG UP, but from a different phone, contact 911 or your emergency contact number immediately with information and await instructions. Give the operator all the information you collected. Identify yourself. Give your name, address and phone number.

8. After this is done, notify your supervisor immediately, then stand by for further instructions.

– If it is deemed necessary to evacuate, the OSHA Safety Officer, your supervisor or the overhead paging system, will notify you. Evacuate via the primary route for your area, or by the alternate route, if so directed

If a bomb threat is received by handwritten note:

Call 911 or your emergency contact number immediately with the information

Handle note as minimally as possible.

If a bomb threat is received by email:

Call 911 or your emergency contact number immediately with the information

Do not delete the message.

If You Discover a Bomb or a Suspicious Item

Leave it untouched and secure area until police arrive. Notify the OSHA Safety Officer or your supervisor immediately.

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If directed, dial 911 or the approved emergency number and report a suspicious item. You may be asked to assist in a search because you are familiar with the area. If so directed, evacuate your area. See your departmental evacuation plan.

Explosion

If the explosion is in your area:

Remove patients and personnel from immediate danger area. Make an effort to keep patients and visitors calm.

Activate fire alarm system or call 911 or the approved emergency number.

Prepare for further evacuation, if necessary.

Use telephones for emergencies only.

Civil DisturbanceReassure patients, visitors and staff. Encourage them to stay in the facility if

danger is in the immediate vicinity. Discontinue all non-essential services and send staff, visitors and patients home, if it is safe to do so.

Determine how staff will triage, treat and transfer patients to a hospital, if needed.

If individuals are on the premises with no official business or related reason, the OSHA Safety Officer shall approach the individuals and escort them off the premises. If these individuals object, dial 911 or the approved emergency number.

Close entrance door. Close window blinds and drapes. Secure and isolate, if possible, individuals who are on the premises with no official business. If security needs exceed the capabilities of the practice, contact an appropriate local agency or dial 911 or the approved emergency number.

Use telephone for emergencies only. Direct all calls from emergency agencies to the OSHA Safety Officer.

If telephone service is impaired or inoperable, the OSHA Safety Officer will designate one person to act as a messenger until telephone communications are restored.

Assemble staff and patients. (Specify this location: _______________________.) If the disturbance renders any portion of the facility unsafe for patients, visitors or staff, the OSHA Safety Officer will restrict access to that portion of the facility until the area becomes safe.

Await further instructions from management. Discontinue all non-essential services and reassign personnel as determined by the OSHA Safety Officer.

The OSHA Safety Officer shall contact suppliers in the event of a shortage of necessary supplies to continue to provide essential medical services.

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Cooperate with arriving Emergency Response personnel.

Assist in the coordination of transfer of patients.Assist in the coordination of transfer of patients.

Earthquake

Earthquakes usually strike without warning and are over in seconds, which precludes preparatory action. Most earthquake injuries are caused by:

Partial building collapse, falling ceilings, lights and pictures

Flying glass from broken windows and mirrors

Overturned furniture, such as bookcases, and appliances

Fires from open or ruptured gas lines and other causes

If a Tremor Occurs when You Are Inside

Stay inside. Watch out for falling debris. Cover your head and shoulders and try to protect yourself from falling objects and shattered glass.

Crawl under a table or desk, sit or stand against an inside wall staying away from windows and mirrors, or stand inside a strong doorway.

After the Tremor Is Over

Check for injured people. Do not move seriously injured people unless they are in immediate danger.

Ensure that all patients are wearing shoes to avoid injury from debris and broken glass.

If you think the building has been damaged, evacuate. After-shocks can level severely damaged buildings.

Do not use the telephone except to report an emergency.

Do not use plumbing or anything electrical (including elevators) until after the utility and electrical lines have been checked.

Open closets and doors carefully, watching for objects that may fall.

Do not use matches or lighters. Watch for fires that may have started.

Be prepared for additional aftershocks.

Inspect the area to the extent it can be done safely, to determine damage such as fire or fire hazards from broken electrical lines or short circuits.

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Inspect the area to determine injuries. Qualified people may administer appropriate first aid.

The OSHA Safety Officer shall determine whether it is necessary to evacuate or if patient services may be continued or need to be rescheduled.

Clean up spills according to established procedures.

Severe Weather

Flood

The OSHA Safety Officer or designee is responsible to monitor/follow emergency warnings and subsequently issue advisories to staff, patients and visitors.

Move patients, visitors and staff to the safest area of the building (specify this location): _________________________________________________.

Move unsecured equipment into a safe area.

Discontinue non-essential services and evacuate, if possible. If flooding is in the vicinity, move to a higher story and contact 911 or the approved emergency number.

Hurricane

The OSHA Safety Officer or designee is responsible for monitoring/following emergency warnings and subsequently issuing advisories to staff, patients and visitors. Many hurricane warnings are given with adequate time to determine if routine office activities will be cancelled and rescheduled for a future date. Follow your facilities severe weather plan.

Severe Thunderstorm or Tornado Warning

The National Weather Service issues a “Severe Thunderstorm Warning” when storms with strong winds, rain, and hail are expected in the area. In 2010, the National Weather Service updated the definition of a severe thunderstorm to include having large hail of at least 1 inch in diameter, severe (storm-force) winds of 58 miles per hour or greater and potential to produce a tornado without warning,

A “Tornado Warning” is issued when a tornado or cloud rotation has been sighted and is threatening the community. The weather warning sirens may be sounded for a severe thunderstorm warning or just for a tornado warning, if available in your area. It is important for the OSHA Safety Officer to be familiar with the severe weather warning protocols in your service area. Media broadcast emergency messages that include the tornado’s location, direcion and speed may interrupt programming with special announcements.

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When a Tornado Warning has been issued:

Direct patients to the safest area of the building (specify this location): ___________________________________________________________. A good rule of thumb is to go to a low-lying area and get near to the ground.

If time permits, move all unsecured equipment into a safe area/storage. Follow the safety tips below.

Once the tornado has passed report structure damage (area involved, type, and extent of damage) to Management by phone, if possible. If phone service is interrupted, take a verbal message to Management who will assess tornado damage and determine priority of repair work needed.

Inspect the area to determine injuries. Qualified people may administer appropriate first aid.

Tornado Safety Tips

The best shelter from a tornado is a basement. Alternatively, go to an inside room without windows on the lowest level of the building, such as a closet, bathroom or interior hall. Protect your body with a heavy blanket or something similar.

Avoid windows. Do not open windows; go find shelter instead.

If you are caught in an open space or open large building, get into the restroom, if possible, which is usually made of concrete block and will offer more protection.

If there is no time to relocate, try to get up against something that will support or deflect falling debris. Protect your head with your hands and arms.

If you are in your car, get out if you can find shelter. An underpass of a bridge, a culvert or ditch can all provide shelter if a substantial building is not nearby.

Severe Thunderstorm or Tornado Watch

If a Severe Thunderstorm or Tornado Watch is announced, the OSHA Safety Officer should keep apprised of local atmospheric conditions and monitor, via the media (radio or television), to determine if weather conditions are deteriorating.

If advised by the OSHA Safety Officer, staff must be prepared to move all individuals to a safe area and move unsecured equipment and hazardous chemicals to a safe area (if time allows). Do not stand near window glass during high wind conditions.

Toxic External Atmosphere

Upon receipt of information of an external toxic atmospheric condition, the OSHA Safety Officer will announce the condition to patients, visitors and staff.

Keep doors and windows shut and locked during the condition. Shut down all air handlers.

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Follow instructions given by civil authorities. Upon notification by civil authorities that the condition no longer exists, the OSHA Safety Officer will issue an “All Clear” announcement.

The OSHA Safety Officer and attending physicians will determine if patient services may resume or need to be rescheduled.

Violence

OSHA’s Jurisdiction Over Workplace Violence

Healthcare and social service workers face significant risks of job-related violence and it is OSHA’s mission to help employers address these serious hazards. In 2015, OSHA released an update to their voluntary guidelines for preventing workplace violence in healthcare and social service workers. The Guidelines for Preventing Workplace Violence in Healthcare and Social Service Workers updates OSHA’s 1996 and 2004 voluntary guidelines. It is based on industry best practices and provides recommendations for developing policies and procedures to eliminate or reduce workplace violence in a range of healthcare settings. These guidelines are intended to cover a broad spectrum of workers, including those in psychiatric facilities and hospital emergency rooms, as well as neighborhood clinics and mental health centers. The publication can be found at www.osha.gov/Publications/osha3148.pdf.

According to Enforcement Procedures for Investigating or Inspecting Incidents of Workplace Violence, CPL 02-01-052, which the agency issued September 2011, citations could be issued under Section 5(a)(1) General Duty Clause; 29 CFR 1904 Recording and Reporting Occupational Injuries and Illnesses; 29 CFR 1910.151 Medical Services and First Aid.

According to the Enforcement Procedures, inspections concerning workplace violence hazards must be considered where there is a complaint, referral, or report of a fatality and/or catastrophic event involving an incident of workplace violence, especially when it occurs in the high-hazard workplaces identified by OSHA. An inspection can also be initiated during a programmed inspection when the OSHA agent identifies potential for violence in that work setting. Employers should use these guidelines to develop appropriate workplace violence prevention programs and engage workers to ensure their perspective is recognized and their needs are incorporated into the program.

Prevalence of Violence

Workplace violence, such as physical assault or the threat of physical assault, represents a serious occupational risk. According to OSHA and the Bureau of Labor Statistics, 27 out of the 100 fatalities in healthcare and social service settings that occurred in 2013 were due to assaults and violent acts. According to the FBI, work-place

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violence is any action that may threaten the safety of an employee, affect the employee’s physical or psychological well-being, or cause damage to company property.

Workplace violence is any physical assault, threatening behavior, or verbal abuse occurring in the work setting. A workplace includes the buildings and the surrounding perimeters, including the parking lots, field locations, patients’ or clients’ homes, and traveling between work assignments.

For healthcare workers and social workers, the number of workplace assaults between 2011 and 2013 ranged from 23,540 and 25,630 annually. Assaults on healthcare workers account for 10-11% of workplace injuries involving days away from work as compared to 3% of injuries for all private sector employees. Assaults, hostage taking, rapes, robbery and other violent actions are reported at healthcare and community settings. Research has found that workplace violence is under reported—suggesting that the actual rates may be much higher.

Healthcare settings that are particularly vulnerable are psychiatric facilities, hospital emergency departments, community mental health clinics, drug abuse treatment clinics, pharmacies, community-care facilities, residential facilities and long-term care facilities.

At-risk workers include physicians, registered nurses, pharmacists, nurse practitioners, physicians’ assistants, nurses’ aides, therapists, technicians, public health nurses, home healthcare workers, social and welfare workers, security personnel, maintenance personnel maintenance, and emergency medical care personnel.

Workplace violence is defined as any act or threat which creates a hostile work environment.

Workplace Violence includes:

Swearing Obscene phone calls

Name calling Harassment with intimidation

Shouting Suicides and near-suicides

Gestures or expressions that communicate a threat

Wrestling, pushing, restraining, slapping and biting

Discourteous conduct Assaults (aggressive physical actions)

Stalking Suicides and near-suicides

Threats to inflict bodily harm Bullying

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Identifying Situations with the Potential for Violence

Some common factors that increase risk for workplace violence are:

Working directly with volatile patients, especially if they are under the influence of drugs or alcohol or have a history of violent or psychotic behavior

Working when understaffed or alone (lunch or break time, after hours)

Overcrowded, uncomfortable waiting rooms, poor environmental design including unrestricted movement of the public.

Poorly lit corridors, rooms or parking lots

Inadequate security

Lack of staff training and policies for preventing and managing crises

Transporting patients

Long waits for service

The following signs may help in early identification of a violent individual:

Talks and complains loudly; uses profanity, or makes sexual comments

Continually uses excuses and/or blames others

Demands unnecessary services

States that he or she is going to lose control

Paces rapidly, excessive sweating or flushed face, twitching face, shallow breathing, keeping head down, furrowed brows

Challenges authority

Appears tense and angry

Appears intoxicated or under the influence of drugs

Has a history of violence

Has had multiple life stressors, such as divorce, death in the family, or financial problems

Violence Prevention Plan Introduction

Workplace violence can and does occur, in even the best of workplaces. The best approach to workplace violence is to stop it before it happens by dealing effectively with acts of aggression that can snowball into full-fledged violence. You should understand the following:

The most effective line of defense against workplace violence is a well-prepared workforce.

Your employer maintains a “zero tolerance” for workplace violence and provides additional training to help you become prepared to recognize and prevent it.

You can best prepare by gaining confidence in your abilities to do so.

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This facility is committed to providing a safe and healthful workplace for the entire staff. This violence prevention plan, which follows the Enforcement Procedures for Investigating or Inspecting Incidents of Workplace Violence and Guidelines for Preventing Workplace Violence for Health Care & Social Service Workers, OSHA Publication 3148, 2015, is provided to eliminate or minimize occupational exposure to hostile work environments and violent acts.

Overview of Violence Prevention Plan Components

The following violence prevention plan is separated into two parts. The first part includes an introduction and steps to take promote a violence-free workplace. The second part outlines actions that will be taken in case a violent act occurs at this facility.

PART 1:

A written program for workplace violence prevention, incorporated into the overall safety and health program, offers an effective approach to reduce or eliminate the risk of violence in the workplace. The building blocks for developing an effective workplace violence prevention program include:

1. Management commitment and employee participation; 2. Worksite analysis and hazard identification; 3. Hazard prevention and control; 4. Safety and health training; and 5. Recordkeeping and program evaluation.

The workplace violence prevention program should have clear goals and objectives for preventing workplace violence, be suitable for the size and complexity of the facility, and be adaptable. Facilities should also check for applicable state requirements. Several states have passed legislation and developed requirements that address workplace violence.

According to the FBI there are four general classifications of workplace violence:

TYPE 1: Violent acts by criminals who have no other connection with the facility but enter to commit robbery or another crime

TYPE 2: Violence directed at employees or providers by patients and their families or others to whom services is provided

TYPE 3: Violence against coworkers, supervisors, or managers by a present or former employee

TYPE 4: Violence committed in the workplace by someone who doesn’t work there, but has a personal relationship with an employee—an abusive spouse or domestic partner

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Violence Prevention Program

STEP 1. Management Commitment and Worker Participation

Management commitment and worker participation are essential elements of an effective violence prevention program. Appropriate authority and resources must be allocated to all responsible parties to include access to information, personnel, time, training, tools and equipment. A system of accountability must be maintained for managers, supervisors and staff. Establish a comprehensive program of medical and psychological counseling and debriefing for workers who have experienced or witnessed assaults and other violent incidents. Establish policies that ensure the reporting, recording and monitoring of Incident and near misses no reprisals are made against anyone who does so in good faith.

Staff should participate in the development, implementation, evaluation and modification for the workplace violence prevention program. Ensure that the perspectives of front line staff are included in the policies. Identify the daily activities that staff, including contract workers, believe to put them most at risk for workplace violence. Include procedures to ensure that staff are not retaliated against for voicing concerns or reporting injuries. Conduct training and continuing education programs.

Once you have customized this plan, disseminate it to managers, supervisors, and coworkers. Post a sign notifying clients, patients, and visitors that this facility maintains a zero-tolerance for workplace violence, verbal and nonverbal threats, and related actions.

STEP 2. Worksite Analysis and Hazard Identification

A worksite analysis involves a mutual step-by-step assessment to find existing or potential hazards that may lead to incidents of workplace violence. Cooperation between staff and employers in identifying and assessing hazards is the foundation of a successful violence prevention program. Although management is responsible for controlling hazards, staff have a critical role to play in helping to identify and assess workplace hazed because of their knowledge and familiarity with facility operations, process activities and potential threats. The assessment should include a review of incident reports and near miss events. This assessment will serve as the basis for training and education. Some facilities will determine that a comprehensive annual worksite analysis should be conducted but require that an investigative analysis occur after every incident or near miss.

Complete the Risk Factors for Workplace Violence Checklist. This checklist was adapted by OSHA from the California Department of Human Resource workplace violence prevention program. This form can also be found behind Tab 11: Master Record Forms (Form 6).

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A periodic inspection of the workplace should evaluate new or revised tasks in order to identify hazards, conditions, activities and situations that could lead to potential violence. Information is often collected through injury and incident report analysis, job hazard analysis, employee surveys, and patient surveys.

Records Analysis and Tracking

Medical records and incident report reviews are important to identify patterns of assaults or near misses that could be prevented or reduced through the implementation of appropriate controls. Include medical, safety, specific threat assessments, workers’ compensation, and insurance records. Incident and near miss reports provide valuable trending information that might be missed in the day-to-day activities of a busy facility.

Job Hazard Analysis

A job hazard analysis focuses on job tasks to identify hazards.It examines the relationship between the staff, the task, tolls and work environment. Priority analysis should be given to:

Jobs with high assault rates due to workplace violence

Jobs that are new to the facility or have undergone procedural changes that may increase the potential for workplace violence

Jobs that require written instructions, such as procedure for administering medication and steps for transferring patients

After an incident or near miss, the analysis should focus on:

Analyzing those positions that were affected;

Identifying if existing procedure and operations were followed, and if not, who not (in some instances, not following procedures could result in more effective protections);

Identifying if staff were adequately qualified and /or trained for the tasks required; and

Developing, if necessary, new procedures and operations to improve staff safety and security.

Staff Surveys

Staff surveys or questionnaires are effective ways for employers to identify potential hazards that may lead to violent incidents, identify the types of problems faced by workers and asses the effects of change in the work processes. Baseline surveys can help pinpoint tasks that put workers at risk. Periodic surveys conducted annually or whenever takes change or there is an incident, could help identify new or previously unnoticed risk factors and deficiencies or failure in work practices.

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Sample questions might include:

What daily activities, if any, expose you to the greatest risk of violence?

What, if any, work activates make you feel unprepared to respond to a violent action?

Can you recommend any changes or additions to the workplace violence training you received?

STEP 3: Hazard Prevention and Control

After completing the systematic worksite analysis, the employer should take appropriate steps to prevent or control the hazards that were identified.

Substitution

The best way to eliminate a hazard is to substitute a safer work practice. While this may be challenging, referring or transferring a patient to a more appropriate setting might be an example.

Engineering Controls and workplace adaptations to minimize risk

Engineering controls are physical changes that either remove the hazard from the workplace or create a barrier between the worker and the hazard. Engineering controls include:

Using a physical barrier (such as enclosures or guards) or door locks to reduce employee exposure to the hazard

Metal detectors

Panic buttons

Better or additional buttons

More accessible exits (where appropriate)

The measures taken should be site specific and based on the hazards identified in the worksite analysis. If any modifications are planned for a facility, assess any plans to eliminate or reduce security hazards.

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Check off which of the following facility guidelines have been implemented to reduce violence. Base decisions to adopt some or all of these activities/protocols/techniques based on actual or perceived risk:

___ Use closed-circuit video continuous recordings for high-risk areas

___ Routinely test and maintain mechanical devices utilized for security and safety to ensure effectiveness.

___ Lock all unused doors to limit access (from the outside), in accordance with fire code regulations.

___ Install bright and effective lighting systems indoors and outdoors.

___ Provide employee “safe rooms” for use in emergency situations.

___ Place curved mirrors or cameras at hallway intersections or concealed areas, and ensure bright lighting.

___ Install deep service areas and/or enclosed nurses’ stations, using bullet-resistant, shatterproof glass in reception areas, triage, or client service rooms.

___ Install silent alarms. If this is cost-prohibitive, consider emergency signaling or monitoring systems.

___ Provide metal detectors–either installed or hand-held–to identify weapons.

___ Provide panic buttons, hand-held alarms, cellular phones, and private radio channels so employees can get help when they need it in emergency situations.

___ Rearrange furniture and other objects to minimize their use as weapons so that individuals are not trapped or hurt in potentially violent situations.

___ Use drop safes to minimize cash on hand.

___ Post signs announcing that limited (or no) cash is on hand.

___ Provide comfortable waiting rooms (client or patient) designed to minimize stress.

___ Design the triage area and other public areas to minimize the risk of assault.

___ Provide lockable and secure bathrooms for staff members separate from patient/client and visitor facilities.

___ Establish “time-out” or seclusion areas with high ceilings without grids for patients who “act out.”

___ Ensure that counseling or patient care rooms have two exits.

___ Ensure cabinets and syringe drawers have working locks.

___ Pad or replace sharp edged objects (such as metal table frames)Smooth down or cover any sharp surfaces.

___ Consider changing or adding materials to reduce noise in certain areas.

___ Replace all burned out lights immediately.

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Administrative and work practice controls

Administrative and work practice controls are appropriate when engineering controls are not feasible or completely protective. These controls affect the way staff perform jobs and tasks. Changes in work practices and administrative procedures can help prevent violent incidents.

Check off which of the following administrative actions have been implemented to avoid violence, or tailor some of these prevention techniques for your particular workplace situation and needs:

___ Prohibit weapons from the facility.

___ Clearly stating to patients, visitor and staff that violence is not permitted and will not be tolerated. Such a policy makes it clear to staff that assaults are not considered part of the job or acceptable behavior.

___ Have facility security (or police) routinely check on workers and escort them to the parking area after dark.

___ Instruct employees to remain vigilant and to report anything unusual.

___ Work with local police to establish liaison and response mechanisms for police assistance when calls are made for help.

___ Recognize and act on legitimate complaints regarding overbearing physicians, managers and supervisors.

___ Consider potentially volatile interoffice occurrences with employees, supervisors or employers when designing specific prevention techniques.

___ Train employees in restraining techniques.

___ Train employees in developing sensitivity to racial/ethnic issues and differences that may have causal connections with violent behavior.

___ Provide regular dialogue on workplace violence during staff meetings and other forums to communicate feelings, gain support and share innovative ideas. Survey employees to determine perceived risk factors present in the workplace.

___ Provide group therapy for staff with particularly difficult patients or a significant event.

___ Provide adequate staffing, particularly during times of increased patient activities or during restraining procedures.

___ Escort patients to and from waiting rooms. Do not permit patients to move about unsupervised.

___ Instruct employees to carry only small amounts of cash.

___ Design staffing patterns to prevent personnel from working alone.

___ Make it clear that employees should not enter any location where they feel unsafe.

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___ Provide sensitive and timely information to people waiting in line or in waiting rooms. Adopt measures to decrease waiting time.

___ Establish a list of “restricted visitors” for patients with a history of violence or gang activity.

___ ___

Discourage employees from wearing necklaces or chains to help prevent possible strangulation in confrontational situations.

___ Establish polices and procedure for secured areas and emergency evacuations.

___ Use a “buddy system”, especially when person safety may be threatened.

___ Advise workers of facility’s procedures for requesting police assistance or filing charges when assaulted and assist them in doing so, if necessary.

___ Provide management support during emergencies. Respond promptly to all complaints.

___ Emergency action plans should be developed to ensure that staff know how to call for help or medical assistance.

___ Survey the facility periodically to remove tools or possessions left by visitors or staff could be used inappropriately by patients.

___ Keep desks and work areas free of items, including extra pens and pencils, glass photo frames, etc.

STEP 4. Training

The Training can:

1. Help raise the overall safety and health knowledge across the facility. 2. Provide employees with the tools needed to identify workplace safety and

security hazards. 3. Address potential problems before they arise and ultimately reduce the

likelihood of staff being assaulted.

The training program should involve all staff, including contracted workers, supervisors and managers. Staff who may face safety and security hazards should receive formal instruction on any specific or potential hazards associated with the job of the facility. Such training may include information on the types of injuries or risks identified during the workplace violence assessment and the methods for controlling specific hazards.

Every staff member should understand the concept of “universal precautions for violence”, that is, that violence should be expected but can be avoided or mitigated through preparation. Staff should understand the importance of a culture of respect, dignity, and active mutual engagement in preventing workplace violence.

The Guide for Prevention of Workplace Violence (2015) states that new and reassigned staff receive an initial orientation and that every worker receives required training annually.

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Visiting staff, including physicians, should receive the same training as permanent staff and contract workers.

Provide safety education for employees:

Provide in-service education sessions or other opportunities for employees to practice and improve their skills and confidence.

Local police departments often provide free training on how to recognize avoid or diffuse potentially violent situations.

The following topics provide an outline for baseline training for staff in workplace violence prevention:

The workplace violence prevention policy

Risk factors that cause or contribute to assaults

Policies and procedures for documenting patients’ change in behavior

The location, operation and coverage of safety devices such as alarm system along with the required maintenance schedules and procedures

Early recognition of escalating behavior or recognition of warning signs or situations that may lead to assaults

Ways to recognize, prevent tor diffuse volatile situation or aggressive behavior, manage anger and appropriate use mediations

Ways to deal with hostile people other than patients such as relatives and visitors

Proper use of safe rooms or areas where staff can find shelter from a violent incident

A standard response action plan for violent situations including the availability of assistance, response to alarm systems and communication procedures

Ways to protect oneself and coworkers, including use of the “buddy system”

Policies and procedure for reporting and recordkeeping

Policies and procedures for obtaining medical care, counseling, workers compensation or legal assistance after a violent episode or injury

Supervisors and managers must be trained to recognize high risk situations so they can ensure that staff are not place in assignments that compromise their safety. Such training should include encouraging workers to report incident and to see the appropriate care after experience a violent incident.

STEP 5. Recordkeeping and program evaluation

Recordkeeping and evaluation of the violence prevention program are necessary to determine its overall effectiveness and identify any deficiencies or changes that should be made.

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Accurate records of injuries, illnesses, incidents, assaults, hazards, corrective actions, patient histories and training can help employers determine the severity of the problem, the effectiveness of the plan and identify training needs. Document findings in safety committee meetings. Record hazard analysis and corrective actions recommended and taken. Record all training programs, attendees and qualification of the trainers.

Violence Prevention Techniques for Medical Facilities

Have employees practice identifying the potential and actual causes of workplace violence and stress. Work on conflict resolution and nonviolent responses. Use role-playing for practice with assessing and managing violent individuals and their victims. Note that typical work activities may arouse anger or fear in some patients and result in acts of violence. Long waits and inability to obtain needed services also contribute to the problem of violence.

What Employees Should do to De-escalate a Potentially Violent Situation

Position yourself so that you have immediate access to an exit. Stand at a right angle rather than directly in front of the person. Don’t invade his or her personal space. A good distance is 3 to 6 feet away.

Project calmness. Move and speak slowly, quietly, and confidently.

Don’t use communication styles that produce hostility (hands on hips, arms crossed, pointing fingers), apathy, coldness, condescending language, or inflexibility.

Be an empathetic listener. Encourage the person to talk, and listen patiently. Indicate that you can see he or she is upset.

Don’t make sudden movements that can be interpreted as threatening.

Don’t challenge, threaten, or dare the individual; don’t belittle the person or make him or her feel foolish. Don’t criticize or act impatiently toward the agitated individual.

Ask for small, specific favors such as asking the person to move to a quieter area (preferably where there are no objects that can be used as weapons).

Don’t attempt to bargain with a threatening person.

Establish ground rules if unreasonable behavior persists. Calmly describe the consequences of any violent behavior.

Use delaying tactics to give the person time to calm down; for example, offer a drink of water.

Don’t try to impart a lot of technical or complicated information when emotions are running high. Don’t take sides or agree with distortions.

Repeat back to him what you feel he or she is requesting of you. Don’t make false statements or promises you can’t keep.

Be aware of anything in the room that can be used as a weapon.

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If a Violent Situation Cannot be Defused Quickly:

Remove yourself from the situation—get to a safe place.

Call for help.

Report violent incidents to management.

PART 2:

If a Violent Incident Occurs

STEP 1. Make calls for help as needed using 911, the approved emergency number or according to other emergency protocols made by your facility.

This facility’s emergency protocol is _______________________________________________________________________________________________________________

STEP 2. Encourage employees to promptly report all incidents of aggressive behavior (e.g., pushing, threatening, etc.) to _____________________________________, even if there were no injuries.

Document all incidents and threats of workplace violence and promptly report violent incidents to the local police department.

Require records of incidents or near-incidents to assess risk and to measure progress.

Investigate all violent incidents and threats. Monitor trends in violent incidents by type or circumstance.

Institute corrective actions to reduce or eliminate future risks.

STEP 3. Inform victims of workplace violence of their legal right to prosecute perpetrators.

Provide assistance in making a report to the appropriate law enforcement agency.

Employees may not be discouraged or coerced when making reports or filing worker’s compensation claims.

STEP 4. Provide prompt medical evaluation and treatment for employees whenever an assault takes place regardless of severity.

STEP 5. Maintain records concerning the assault, including the type of activity (e.g., unprovoked sudden attack, patient-to-patient altercation), and management of assaultive behavior. Include:

Who was assaulted and circumstances of the incident, without focusing on any alleged wrongdoing of the staff person.

A description of the environment, location or any contributing factors, corrective measures identified, including building design, or other measures needed.

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STEP 6. Define your organization’s response to the perpetrator, visitors, or patients: ______________________________________________________________________Employee: _____________________________________________________________

STEP 7. Arrange critical incident stress-debriefing sessions and/or post-trauma counseling services to help workers recover from a violent incident. Healthcare workers, who have been abused by patients, particularly if the attack comes without warning, have reported a full range of problems, including:

Death or severe and life-threatening injuries

Impaired relationships with co-workers and family

Shock Self-blame

Post-traumatic stress Disbelief

Anger Fear of returning to work

Anxiety Disturbed sleep patterns

Irritability Headaches

Depression Short- and long-term psychological trauma

Counseling services will be provided by ____________________________________.

STEP 8. Report any act of violence that is recordable and which results in a fatality within 8 hours of the incident or in any employee being hospitalized to OSHA by telephone (800-321-OSHA) within 24 hours of the incident or complete the Serious Event Reporting Online Form found at www.osha.gov/pls/ser/serform.html.

More Sources for Prevention of Workplace Violence

NIOSH Tips For Developing A Violence Prevention Programwww.cdc.gov/niosh/violpurp.html

OSHA Publication, “Guidelines for Preventing Workplace Violence for Healthcare and Social Service Workers”. www.osha.gov/Publications/osha3148.pdf

Enforcement Procedures for Investigating or Inspecting Incidents of Workplace Violence, CPL 02-01-052, September, 2011www.osha.gov/OshDoc/Directive_pdf/CPL_02-01-052.pdf

Federal Bureau of Investigation Statisticshttp://www.fbi.gov/stats-services/publications/law-enforcement-bulletin/january2011/january-2011-leb.pdf

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First Aid

Although most medical workplaces have supplies to handle minor emergencies, OSHA requires a separate, readily available, first aid kit for employee injuries. The ANSI 308.1 standard was revised in 2015. There are now first aid kits for different types of work envi-ronments. Many of the supplies that used to be recommended are now required. Store your first aid kit in a convenient area for emergency access and include the following (your workplace could have additional hazards that necessitate extra components):

First Aid Kit

Required Equipment includes but may not be limited to:

Absorbent Compress, 32 sq. in. with no side smaller than 4 in. (1)

Adhesive Bandages, 1 x 3 in. (16)

Adhesive Tape, 2-5 yds. (1)

Antiseptic, 0.5 g (0.14 fl. oz.) application (10)

Burn Treatment, 0.5 g (.014 fl. oz.) application (6)

Medical Exam Gloves (4)

Surgical Scissors (1)

Sterile Pad, 3 x 3 in. (4)

Triangular Bandage, 40 x 40 x 56 in. (1)

Directions for requesting emergency assistance (if a caregiver is not available) /First Aid Guide

Analgesic/Pain Reliever (i.e. acetaminophen, Aspirin, individually packaged and of non-drowsy formulation) (16)

Antibiotic Treatment 1/32 oz (6)

Bandage Compress 2” x 36” (4)



Breathing Barrier (CPR) (1)

Burn Dressing 4” x 4” (1)

Cold Pack (1)

Eye Covering, 2.9 sq Inches per eye (2)

Eye Wash 1 oz (1)

Roller Bandage 4” x 6 yd (1)

Roller Bandage 2” x 6 yd (1)

Emergency Blanket (1)

Tweezers (1)

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Elastic Wraps (2)

Splint (1)

Automated External Defibrillator (AED)

Source: American National Standards Institute (ANSI), 308.1-2015. For additional information and list of required elements, the 2015 ANSI standard can be purchased at www. Ansi.org.

Keep first aid items in a weatherproof container with individual sealed packages for each type of item. Check the contents of the kit monthly to make sure expended or expired items are replaced.

In 29 CFR 1910.151(b), OSHA requires that employers have medical personnel “readily available” for advice and consultation. If there is no nearby (within a 15-minute drive) infirmary, clinic, or hospital that is used for treating all injured employees, then one or more person on every shift in every outpatient medical facility must be adequately trained to render first aid. Persons who render first aid must have a “valid” certificate in first-aid training from the American Red Cross, or equivalent documented training.

Basic First Aid for Common Emergencies

Each type of emergency has its own first aid procedure. Some common situations employees might encounter are:

Bleeding: If someone is bleeding heavily, stop the flow until medical help arrives by applying pressure to pushing on the wound with a cloth or your hand. For deeper cuts, elevate the wound while maintaining pressure.

Broken Bones: Don’t move someone who may have broken bones unless it’s absolutely necessary. Keep the person still and wait for experts to arrive.

Eye Injuries: If chemicals were splashed in the eye, immediately flush with water for at least 15 minutes. Then close the eyes, cover them with a clean cloth, and get medical help. If something is stuck in the eye, keep the person calm until help arrives.

Electrical Shock: Don’t touch a person in contact with a live electric current. Turn off the main electric switch or fuse, or get an electrician to do it if possible. If you must move the person from a live wire, stand on something dry and use a dry stick or

First Response for anEmployee Injury

Stay calm but act fast. Consult emergency numbers, which should be posted near all phones, for your local ambulance service or call for employees with first-aid training.

Know where first-aid kits are kept.

If you’re unsure of what to do, call for medical help immediately and explain the kind of injury and the location of the victim. Wait with the injured individual.

Don’t move an injured person unless it’s necessary to save his

or her life.

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board to push the person off the wire. Never use anything metal, wet, or damp. After the person is removed from the electricity, check for heartbeat and breathing. If necessary and if you are able, administer artificial respiration or CPR.

Choking: Ask the person loudly, “Are you choking?” If he or she cannot respond, perform the abdominal thrusts and back blows as recommended by the American Red Cross. (formerly known as the Heimlich maneuver.)

If abdominal thrusts and back blows as recommended by ARC do not work and the person is unconscious, use your index and middle fingers to try to remove the object from the throat.

Or, place the person on his or her back and push in and up sharply on the abdomen below the rib cage. Don’t stop until the object is dislodged or medical help arrives.

Heart Attack: Although symptoms are not always obvious, do the following if you believe someone is having a heart attack:

Place him or her in a comfortable reclining or sitting position.

Loosen tight clothing at the waist and neck.

Give oxygen if you have been trained to do so.

Ask if the person has medication for the problem that you can give.

Keep the person still until help arrives.

If the heart stops and you have been trained in CPR, use it, or use a defibrillator/AED if one is available. Otherwise, wait for help. Waiting can cost a life, so be sure there are at least two members on staff that have been trained in CPR or ACLS (Advanced Cardiac Life Support).

Abdominal Thrusts

Stand behind the victim with your arms around his or her waist. Make a fist with one hand and place it, thumb side in, against vic-tim’s stom ach be tween the navel and the ribs. Grab your fist with your other hand. Pull in and up sharply and repeat as necessary.

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Crash Kit/Cart Components

Contact your state medical board for specific requirements regarding cardiac response items to be immediately available when conscious sedation, deep sedation or general anesthesia is performed. Contact the American Heart Association Advanced Cardiac Life Support Manual (www.heart.org) or the American College of Emergency Physicians (www.acep.org) for the latest recommendations for crash cart contents.

If you have a crash cart, inventory monthly to ensure expired medications are replaced.

Drug-Free Workplace ProgramA drug-free workplace program is an organization’s best line of defense against alcohol and drug problems. The drug-free workplace policy below serves as the foundation of this company’s drug-free workplace program. The goal of our drug-free workplace policy is:

To send a clear message that use of alcohol and drugs in the workplace is prohibited, and

To encourage employees to voluntarily seek help with alcohol and drug problems.

Our drug-free workplace program includes: (Please select all* that apply.) Drug-free workplace policy (below)Supervisor trainingEmployee educationEmployee assistanceDrug testing

* Although programs can be effective with just the policy statement, it’s recommended that additional program components be implemented to ensure a comprehensive program. Research shows that more components may lead to a more effective program.

Drug-Free Workplace Policy

Purpose and Goal

This workplace is committed to protecting the safety, health and well being of all employees and other individuals. We recognize that alcohol abuse and drug use pose a significant threat to our goals. We have established a drug-free workplace program that balances our respect for individuals with the need to maintain an alcohol and drug-free environment.

This policy recognizes that employee involvement with alcohol and other drugs can be very disruptive, adversely affect the quality of work and performance of employees, pose

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serious health risks to users and others, and have a negative impact on productivity and morale.

Covered Workers

Any individual who conducts business for the organization, is applying for a position or is conducting business on the organization’s property is covered by our drug-free workplace policy. Our policy includes, but is not limited to CEO, executive management, managers, supervisors, full-time employees, part-time employees, off-site employees, contractors, volunteers and interns.

Applicability

Our drug-free workplace policy is intended to apply whenever anyone is representing or conducting business for the organization. Therefore, this policy applies during all working hours, whenever conducting business or representing the organization, while on call, paid standby, while on the property and at company-sponsored events.

Prohibited Behavior

It is a violation of our drug-free workplace policy to use, possess, sell, trade, and/or offer for sale alcohol, illegal drugs or intoxicants.

Prescription and over-the-counter drugs are not prohibited when taken in standard dosage and/or according to a physician’s prescription. Any employee taking prescribed or over-the-counter medications will be responsible for consulting the prescribing physician and/or pharmacist to ascertain whether the medication may interfere with safe performance of his/her job. If the use of a medication could compromise the safety of the employee, fellow employees or the public, it is the employee’s responsibility to use appropriate personnel procedures (e.g., call in sick, use leave, request change of duty, notify supervisor, notify company doctor) to avoid unsafe workplace practices.

The illegal or unauthorized use of prescription drugs is prohibited. It is a violation of our drug-free workplace policy to intentionally misuse and/or abuse prescription medications. Appropriate disciplinary action will be taken if job performance deterioration and/or other accidents occur.

Consequences

One of the goals of our drug-free workplace program is to encourage employees to voluntarily seek help with alcohol and/or drug problems. If, however, an individual violates the policy, the consequences are serious.

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In the case of applicants, if he or she violates the drug-free workplace policy, the offer of employment can be withdrawn. The applicant may not reapply.

If an employee violates the policy, he or she will be subject to progressive disciplinary action and may be required to enter rehabilitation. An employee required to enter rehabilitation that fails to successfully complete it and/or repeatedly violates the policy will be terminated from employment. Nothing in this policy prohibits the employee from being disciplined or discharged for other violations and/or performance problems.

Assistance

This organization recognizes that alcohol and drug abuse and addiction are treatable illnesses. We also realize that early intervention and support improve the success of rehabilitation. To support our employees, our drug-free workplace policy:

Encourages employees to seek help if they are concerned that they or their family members may have a drug and/or alcohol problem.

Encourages employees to utilize the services of qualified professionals in the community to assess the seriousness of suspected drug or alcohol problems and identify appropriate sources of help.

Treatment for alcoholism and/or other drug use disorders may be covered by the employee benefit plan. However, the ultimate financial responsibility for recommended treatment belongs to the employee.

Confidentiality

All information received by the organization through the drug-free workplace program is confidential communication. Access to this information is limited to those who have a legitimate need to know in compliance with relevant laws and management policies.

Shared Responsibility

A safe and productive drug-free workplace is achieved through cooperation and shared responsibility. Both employees and management have important roles to play. All employees are required to not report to work or be subject to duty while their ability to perform job duties is impaired due to on- or off-duty use of alcohol or other drugs. In addition, employees are encouraged to report dangerous behavior to their supervisor.

It is the supervisor’s responsibility to:

Inform employees of the drug-free workplace policy.

Investigate reports of dangerous practices.

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Document negative changes and problems in performance.

Counsel employees as to expected performance improvement.

Clearly state consequences of policy violations.

Communication

Communicating our drug-free workplace policy to both supervisors and employees is critical to our success. To ensure all employees are aware of their role in supporting our drug-free workplace program, all employees have access to the written copy of this policy in our OSHA Program Manual.

Supervisor Training (This section applicable only if checked on page 3-43.)

Supervisors in this workplace are trained to ensure they understand:

The drug-free workplace policy.

Ways to recognize and deal with employees who have performance problems that may be related to alcohol and other drugs.

How to refer employees to available assistance.

Their responsibility to monitor employees’ performance, staying alert to and documenting performance problems, and enforcing the drug-free workplace policy. Supervisors are not expected to diagnose alcohol- and drug-related problems or provide counseling to employees who may have them.

If supervisors are responsible for making referrals for drug testing based on reasonable suspicion, they are trained on how to make that determination.

Employee Education (This section applicable only if checked on page 3-43.)

All employees participate in our drug and alcohol education program. The program provides employees with the information they need to fully understand, cooperate with and benefit from this company’s drug-free workplace program.

The employee education program provides information on:

The details of the drug-free workplace policy.

The general nature of alcohol and drug addiction.

The impact of addiction on work performance, health and personal life.

The types of help available for individuals with related problems.

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The educational program message is delivered on an ongoing basis through a variety of means. Forums may include home mailings, workplace displays, brown-bag lunches, guest speakers, seminars and sessions at new employee orientation.

Employee Assistance (This section applicable only if checked on page 3-43.)

Our Employee Assistance Program (EAPs) is a benefit offered to our employees. Through this program we offer an alternative to dismissal via an effective vehicle to address poor workplace performance that stems from an employee’s personal problems, including the abuse of alcohol or other drugs.

To receive counseling or referrals for assistance though our EAP contact:____________________________________________________________________

Drug Testing (This section applicable only if checked on page 3-43.)

This employer drug tests employees for a variety of reasons, including deterring and detecting drug use, as well as providing concrete evidence for intervention, referral to treatment and/or disciplinary action.

Drug tests are conducted according to all local, state and Federal laws and any collective bargaining agreements. Note: It is strongly recommended that legal counsel be sought before starting a drug testing program.

Drug testing will be performed by: _______________________________________________________________________________________________________________.

The following employees are subject to drug testing: (Please select all that apply.)All staffJob applicantsEmployees in safety-sensitive positionsOther: ______________________________

Drug tests will be conducted: (Please select all that apply.)Pre-employmentUpon reasonable suspicion or for-causePost-accidentRandomlyPeriodicallyPost-rehabilitationOther: ______________________________

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Drug tests will be conducted for: (Please select all that apply.)Illegal drugs AlcoholCertain prescription drugsOther: ______________________________

Additional policy statements regarding drug testing follow: ________________________ ___________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________.

Service Animals

Title III of the Americans with Disabilities Act (ADA) requires that places of public accommodation, including healthcare facilities, modify their policies and practices to permit the use of a service animal by a person with a disability, unless doing so would create a fundamental alteration or direct threat to the safety of others or to the facility. For example, a service animal may howl through the night and prevent people from sleeping, or it may, in a nonthreatening manner, block a healthcare provider from administering care to a client. A direct threat would occur were a service animal to growl at or impede a person’s safe travel.

Healthcare facilities are advised by the U.S. Department of Justice Civil Rights Division to accept the verbal reassurance of the person that he or she has a disability and that the animal is a service animal. Additional inquiry into the nature of the disability is prohibited by the ADA.

Risk assessment: The behavior of the animal should help in assessing whether the animal constitutes a direct threat to health or safety or a fundamental alteration to the nature of the business. If the animal’s presence or behavior creates such a direct threat or fundamental alteration, it does not have to be tolerated by the healthcare facility and may require removal of the animal from the premises. If a service animal does exhibit a condition that presents a direct threat to the health or safety of others, the animal may be removed, restricted, or denied access to the area.

Persons should wash their hands with soap and water after direct contact with the service animal, its equipment, or other items with which the animal has been in contact.

Handlers, whether employee, visitor, or patient, must understand that the animal is not allowed to contact any patient’s nonintact skin (surgical sites, drainage tubes, wounds, etc.).

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Animals will only be permitted in areas considered to be public space. Animals will not be allowed in areas such as the invasive procedure/operating room, food preparation areas, medication preparation areas and sterile storage areas, or areas where special equipment is required to enter (e.g., gowns, gloves, and masks).

No special housekeeping methods are needed provided there is no contamination with animal urine, feces, vomit, or blood (organic debris).

If allergic reactions occur among staff members or other patients, avoid or limit contact with the service animal’s saliva, dander, and urine.

The care and behavior management (stewardship) of the service animal is the responsibility of the handler. If the patient is unable to care for the animal (toileting and exercising the animal, cleaning up excrement in the toileting area, feeding the animal, and storing the animal’s food and water), the patient may elicit support from family, community volunteers, animal welfare organizations, animal caregivers, or other sources. If the patient with a service animal must have access to an area that is off-limits to service animals, it is the patient’s responsibility to provide alternative stewardship for the animal during the time he or she is in the area.

Any injuries caused by a service animal must be evaluated and treated promptly. Employees should seek evaluation by the occupational health provider designated by the practice. If a service animal damages property, the handler may be held responsible for those damages. Document any injuries or property damage and report it to your supervisor.

If the animal contaminated the area:

The cleanup procedures should be performed by using appropriate personal protective equipment

The spill should be removed with paper towels, which should be placed in a plastic bag in the trash container, similar to the disposal of diapers

After removal of the organic debris, the area of the spill should be cleaned with hospital disinfectant, allowing for adequate contact time

Definitions:1. Service animal, a legal term defined in the ADA, is any animal individually trained

to do work or perform tasks for the benefit of a person with a disability. Examples of service animals include guide dogs, hearing or signal dogs, seizure alert cats, mobility dogs, and emotional support cats. A service animal is not considered a “pet” because it is specially trained to help a person overcome the limitations caused by his or her disability.

2. Disability, as defined in the ADA, is any physical or mental impairment that substantially limits one or more major life activities, including but not limited to walking, talking, breathing, hearing, or caring for oneself.

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Holiday Decorations

It comes with the territory of being the Safety Officer that you are responsible to make sure holiday decorations do not affect the overall safety of your facility.

The Life Safety Code®, which the Centers for Medicare & Medicaid Services and other regulatory agencies such as The Joint Commission observe, generally prohibits combustible decorations in hospitals, nursing homes, and ambulatory care centers.

But even if your practice is not subject to that regulation, it makes good sense to be careful with items that could cause a fire event in your facility.

Educate your staff that it is the policy of your healthcare facility to allow employees todisplay decorations in the spirit of the holiday or specific event.

However, you don’t want to increase the potential for fire or decrease overall fire safetyin the facility by using these decorations.

With that in mind, check your holiday decorations against the sample checklist below. It is also a good idea to have a written decoration policy. You can use the sample policy on p. 3-52. It is a reasonable policy that most employees can accept.

Sample Checklist: Spot Check Your Facility’s Holiday Decorations

Use this checklist to help monitor and assess fire safety concerns regarding holiday decorations and displays. Any “no” answers may indicate a life safety risk for workers and patients.

Properties of decorations

Are all decorations noncombustible or flame-retardant?

Does the facility ban all cut trees and live vegetation (which could dry out and become a fire risk) used as decorations?

Does the facility ban all open flames from decoration displays unless approved by management?

Do electrical or battery-operated light strings and displays have a label from a recognized testing laboratory (e.g., Underwriters Laboratories)?

Are electrical and battery-operated light strings and displays prohibited from patient treatment and sleeping areas?

Are electrical light strings and displays running on a timer to control how long they remain on?

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Placement of decorations

Do decorations cover less than 10% of a door?

Do decorations obstruct egress routes?

Do decorations block access to fire protection equipment or devices?

Do decorations obstruct exit signs?

Do staff members avoid hanging decorations off sprinkler pipes or sprinkler heads (if the facility is sprinklered)?

Do decorations block necessary views through windows and vision panels?

Do staff members avoid placing decorations near electrical equipment and heat sources?

Do staff members avoid placing electrical cords or light strings such that they create a trip hazard?

Do staff members avoid using extension cords for electrical decorations?

Management strategies

Do unit managers or safety officers check on decoration placement during hazard surveillance rounds?

Has the facility issued a decorations policy reminder to staff members?

Does the facility’s decorations policy note how the facility will deal with violations to the policy?

Sources: Claude Baker, CFPS, fire and life safety officer and interim manager of safety and regulatory compliance, University of Chicago Medical Center; Kansas State Fire Marshal’s Office; various information from past issues of Healthcare Life Safety Compliance and Briefings on Hospital Safety, both published by HCPro, Inc., Danvers, MA.

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Safe Decorations and Displays Policy

Policy title: ________________________________________________________________________________

Effective date: ______________ Revision date: ______________ Review date: ______________

Submitted by: ____________________________________________________________________________

Approved by: _____________________________________________________________________________

Purpose:

The purpose of this policy is to ensure maximum safety for all patients, employees and properties of (facility name) _______________________________________.

General Information:

Often the greatest fire and accident potential occurs as a result of decorations and displays installed for special events such as holiday parties, special events, etc. The safety committee/safety officer is committed to providing a safe environment free from these potential risks as well as providing guidelines for a safe celebration of all holidays and events. These rules apply year round. Any infringement is reported to the safety officer (Ext. ______), and the offending items will be removed.

Procedure:

A. Decorations, posters, and furnishings1. No furnishings, decorations, posters or other objects are permitted in egress

routes.2. No furnishings or decorations of highly flammable or combustible character

are allowed in the facility.3. All decorations and decorative materials are to be flame retardant or

flameproof.4. Loose paper or decorations on walls/doors shall not exceed 10% of the total

wall surface. Only approved signage is allowed in corridors.5. Do not tape decorations or papers onto other painted/varnished surfaces

(ceilings, walls, door frames, and doors) as it can damage the finish or occlude emergency information.

6. Do not hang decorations/signs/banners, etc., from ceiling tiles or ceiling tile grids as this will infringe on the fire protection properties of the ceiling.

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B. Decorating guidelines1. Do not install decorations within 18 inches of sprinkler heads. 2. Do not place decorations near electrical equipment or other heat sources.3. No lit candles, open flames, or spark-producing devices are allowed as

decorations.4. Lights or decorations using electricity must be approved by the safety

officer prior to use. They must be UL approved and must be turned off when unattended. Never remove the UL listing information from the product. Trip and fall hazards must be abated when using any decorations. Cords are not to run across aisles or corridors. Extension cords and multi-outlet strips are not acceptable for use.

C. Holiday specifics1. The use of artificial trees and decorations is allowed. All must be listed as

flame retardant by a nationally recognized testing laboratory with evidence of this attached to the tree or decoration.

2. Natural or “live” trees/decorations are not allowed unless specifically approved by the Safety Officer. Specific directions for watering and monitoring will be put in place by the department when these items are allowed. (Never in patient care areas.)

Lighted candles may be used for religious ceremonies in approved areas only. Approval must be obtained from the Safety Officer prior to their use. They must be constantly attended when lit and extinguished immediately at the conclusion of the ceremony.

Approved date: _________________________

Review date: _________________________

Source: Avera McKennan Hospital and University Health Center in Sioux Falls, SD. Reprinted with permission.

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Slip, Trip, and Fall Prevention

Preventing slip, trip, and fall (STF) injuries is important to healthcare organizations as they “frequently result in serious disabling injuries that impact a healthcare employee’s ability to do his or her job, often resulting in lost workdays, reduced productivity, expensive worker compensation claims, and diminished ability to care for patients,” according to the NIOSH publication, Slip, Trip, and Fall Prevention for Healthcare Workers.

Also, U.S. Bureau of Labor Statistics data indicate that the incidence rate of lost-workdays from STFs is 90% greater in healthcare than the average for all other private industries.

The purpose of section is to help you and staff members identify common STF hazards in order to better to recognize and reduce the risks.

Here are the top sources of STF hazards that may be relevant to your type of healthcare facility as adapted from the NIOSH publication. Check that publication at www.cdc.gov/niosh/docs/2011-123/ for visual examples of the hazards covered below.

Also, the Healthcare Facility Slip, Trip, and Fall Hazard Checklist (Form 7-B) is available in the Master Record Forms Tab of the OSHA Program Manual.

Contaminants on the FloorContaminants on the floor (water, grease, and other fluids) are the leading cause of STF incidents in healthcare facilities. Written housekeeping procedures, correct floor cleaning, proper usage of mats and signs, accessible clean-up materials, and slip-resistant shoes will help to minimize STF risk of slipping.

Look for these hazards in decontamination areas; food service areas including ice machines; near soap dispensers and drinking fountains; and at building entrances.

Poor Drainage: Pipes and DrainsImproperly aligned drains and water pipes can cause liquid to spill onto walking sur-faces, and clogged drains can cause water to back up onto the floor

Look for these hazards wherever there are pipes and drains in the facility such as decontamination areas, food service or break rooms, emergency drench showers, and outside where downspouts spill onto sidewalks.

Indoor Walking Surface IrregularitiesInside healthcare facilities, uneven flooring surfaces due to damage, warping, or buckling, can cause employees to stumble, trip, slip, or fall.

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Look for these hazards in entrance areas; exam or patient rooms; operating rooms; hallways; next to drains; where floor matting is used.

For changes in walkway elevation, remember to create visual cues using safety signs and yellow warning paint.

Outdoor Walking Surface IrregularitiesIf your facility includes or is responsible for outdoor areas, be aware that poorly maintained, uneven ground, protruding structures, holes, rocks, leaves, and other debris can cause employees to stumble, trip, slip, or fall.

Look for these hazards at entrances; lawn edges; parking garages and lots; walkways; around drains in the ground.

Weather Conditions: Ice and SnowIf your location is subject to icy and snowy conditions and your facility includes or is responsible for outdoor areas, have a program to promptly remove ice and snow.

Look for weather condition hazards at entrances; parking garages and lots; walkways; outside stairs.

Inadequate LightingInadequate lighting impairs vision making it difficult for employees to see and avoid unsafe conditions and hazards.

Look for improper lighting conditions in parking structures; storage rooms; hallways; stairwells; inside and outside walkways.

General prevention strategies include installing more lighting in poorly lit areas; checking light bulbs for appropriate brightness; installing light fixtures to emit light from all sides.

Stairs and HandrailsProper construction and maintenance of stairs and handrails can reduce hazards, while stairs that are poorly marked or uneven, or handrails of inappropriate size, height, or that are poorly maintained can lead to missteps and can cause employees to trip and fall.

Look for these hazards at indoor and outdoor stairs; steps inside classrooms or conference rooms; elevated and/or sloping walkways; parking structures; ramps.

General strategies include creating visual cues with yellow safety paint and checking that slip-resistant stair treads are in good condition.

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Stepstools and LaddersIf not used properly, stepstools and ladders used to work from heights can create a hazardous situation.

Look for these hazards in medical records areas; pharmacy; areas with elevated storage; kitchens, break rooms, and pantries; outdoor work situations.

Be sure to instruct employees about maintaining three points of contact with the ladder and stepstools at all times while ascending and descending (two hands and one foot or one hand and two feet).

Tripping Hazards: Clutter, Including Loose Cords, Hoses, Wires, Medical TubingStorage areas, work areas, hallways, and walkways can accumulate clutter leading to potential STF incidents such as exposed cords on the floor that can catch an employee’s foot and lead to a trip.

Look for these hazards at nurses’ stations; operating rooms; exam and patient rooms; computer workstations; storage areas; hallways and walkways.

Improper Use of Floor Mats and RunnersMats can be useful to prevent STFs by providing slip-resistant walking surfaces and absorbing liquid, but improperly placed and maintained, mats can contribute to STFs.

Look for these hazards at facility entrances; laboratories; under sinks; water fountains; food preparation and serving areas.

Good prevention strategies include choosing sufficiently large mats at entrances; using non-slip mats where employees may routinely encounter wet flooring; selecting beveled-edge, flat, and continuous or interlocking mats.

ReferencesSlip, Trip, and Fall Prevention for Healthcare Workers, NIOSH, December 2010, www.cdc.gov/niosh/docs/2011-123/

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HEALTHCARE FACILITY SLIP, TRIP, AND FALL HAZARD CHECKLIST

Read each statement and place a check mark in the box indicating either Yes or No. If a check mark falls in a shaded box, that indicates a hazardous condition may be present and needs further attention. This is a comprehensive check created by NIOSH from Slip, Trip, and Fall Prevention for Healthcare Workers. Some hazards or areas of concern may not apply to your specific healthcare facility.

Yes No LocationContamination and Irregularities (Indoor Walking and Working Surfaces)Do tiles, linoleum, or other flooring have holes, cracks, or bumps?Is carpeting buckled, loose, or frayed? Are carpet edges curled up?Does floor feel greasy or slippery?Are liquid contaminants present (water, grease, oil, cleaning solutions, coffee, body fluids)?Are dry contaminants present (powder, sawdust, dirt, flour, food, wax chips)?Are there sudden changes in indoor floor elevation > 1/4”?Are there metal grates or mesh flooring in the walkway?Are water absorbent walk-off mats used in entrances?Are slip-resistant mats used in wet areas?Are there gaps, cracks, or holes in the outdoor walkway > 1/2”? Are there metal grates or mesh flooring in the walkway? Is the walkway uneven, with abrupt changes in level > 1/2”? Is there debris (pebbles, rocks, leaves, grass clippings) on the walkway? Are there any slippery conditions present (water, grease, ice, snow)? Are concrete wheel stops in the parking areas highlighted with paint? Drainage: Pipes and DrainsAre drains clogged or filled with debris?Are pipes splashing water onto a walking surface?Are outside drain pipes or down spouts spilling water on walkways?Are pipes properly aligned with drains inside and outside of the facility?

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Yes No LocationWeather Conditions (Ice and Snow)Are bins containing ice melting chemicals and scoops provided at areas of heavy pedestrian traffic?Are ice-melting chemicals swept up once walkways are dry?Is winter weather communications distribution system in place?Is snow removal appropriately scheduled?Stairs and HandrailsAre all handrails 34–38” from the floor?Are handrails provided on slopes, ramps, stairs?Do handrails extend at least as far as the last step?Are handrails provided at steps (employee shuttle bus stop, entrances, conference and training rooms)?Are the edges /noses of each step painted or marked?Are stairway risers and steps all of uniform size?Tripping Hazards (Clutter, Loose Cords, Hoses, Wires, and Medical Tubing)Are cords bundled using a cord organizer?Are cords on the floor covered with a beveled protective cover or tape?Are cords mounted under the desk or on equipment?Are hallways, stairs, and walkways clear of clutter (boxes, cords, equipment)?Is there appropriate storage (closet, shelves, hooks, lockers)?Are stepstools available for use in areas with overhead storage?Do rolling office chairs have a sturdy base (no less than 5 legs)?Lighting (Check both inside and outside the healthcare facility.)Are light bulbs burned out?Are any areas dim, poorly lit, or shadowy? Are lighting levels compliant with local codes, ANSI, and/or Illuminating Engineering Society (IESNA) recommendations?MatsDo mats have abrupt squared-off edges, lacking a bevel?Are mat edges curled up or flipped over?Do mats slide around on the floor?

(Healthcare Facility Slip, Trip, and Fall Hazard Checklist, page 2 of 3)

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Yes No LocationSlip-Resistant ShoesAre employees wearing slip-resistant shoes (safety shoe marketed as slip-resistant)?Do shoe soles have worn-down tread?Is the shoe sole tread clogged with dirt, food, debris, or snow? Are employees that must work outside wearing slip-resistant footwear?Visual CuesAre changes in walkway elevation highlighted?Are curbs highlighted?Are highly visible wet floor signs available and used correctly?Are barriers available and used to prevent access into wet or dangerous areas?Are wet floor signs removed promptly once floor is dry/ clean? Safety ProductsAre the following products available and conveniently located throughout the facility?

– Wall-mounted spill absorbent pads or paper towels?– Cups near water fountains?– Trash cans?– Pop-up tent floor signs?– Umbrella bags?– Barrier and access restriction devices?

Employee Communication (Training and Employee Involvement)Do all employees know the contact number for the housekeeping department?Are winter weather warnings distributed to staff through email?Are all employees aware of the housekeeping procedures?Do employees know where safety products are stored?Are cleaning methods for all floors and paths recorded and displayed?Are employees that use ladders trained in safe ladder use and maintenance?

(Healthcare Facility Slip, Trip, and Fall Hazard Checklist, page 3 of 3)

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