Dr. Scott Harris will present “OSHA in Healthcare: Out of Sight and Out of Mind?” in a free webinar sponsored by PureSafety on Thursday, October 20, 2011 at noon central time. Registration is open to all interested parties.

What does OSHA think about safety efforts in the healthcare sector?  Hint: “a weak culture of worker safety…”  Who is getting inspected and what are they finding?  How exactly does OSHA apply to Healthcare settings?  Does The Joint Commission cover applicable OSHA standards?  Healthcare incident rates are double the national average?  Is there a new standard coming on infection control?  Does a reported 99,000 patient deaths per year from healthcare-acquired infections have something to do with that?

On Friday September 30, 2011, Dr. Scott Harris will present ”OSHA in Healthcare: Out of Sight & Out of Mind?” at the 2011 AOHP national conference in Minneapolis, MN.  Our web visitors can download sneak preview slides of Scott’s presentation here.

OSHA claims nosocomials to be “among the leading causes of death in the United States, accounting for an estimated 1.7 million infections and 99,000 associated deaths in 2002.”  If accurate, healthcare-associated infections — these things you catch while there for something else — kill more people in the U.S. every year than AIDS, drug overdoses, food-borne illness, murder, highway, rail and plane crashes, lightning, tornadoes, West Nile Virus and workplace fatalities COMBINED.  OSHA is using strong language with clear intent to take action and in their 2010 Request for Information (RFI) characterizes healthcare as having “a weak culture of safety.”  Eleven million employees across thousands of sites, incident rates far higher than general industry norms, low inspection rates, complaints driving half of hospital inspections and millions of infections and 99,000 fatalities per year make healthcare an attractive target.  An industry view of TJC accreditation as the program that matters combined with the relative lack of healthcare inspections by OSHA has marginalized occupational health and safety programs within healthcare and nurtured the myths discussed in this presentation.

Keith Spencer of IESO will be conducting a two-day arc flash train-the-trainer course in Lexington, KY beginning November 8, 2011.  You can register or inquire about the course at the OSHA OutreachTrainers website (select “Arc Flash Train-the-Trainer” from the QuickSearch drop-down menu) or contact us directly from our website.  The cost is $695 per person.

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On Tuesday September 14, 2011, Dr. Scott Harris will present ”OSHA in Healthcare: Out of Sight & Out of Mind?” at the 2011 PureSafety Conference in Nashville, TN. He is one of a handful of industry speakers invited to participate in the event.  Our web visitors can download sneak preview slides of Scott’s presentation here.  A technical paper on this presentation is scheduled for publication in OSHATracker in September.  Sorry, no release until then, but we will post it here as soon as it’s out.

So what is all the fuss about?  Based on a number of generally accepted myths about OSHA, members of the healthcare community may think that management would be justified in taking little or no additional action to prevent the spread of occupationally acquired infectious diseases or deal with other OSHA issues. The facts say otherwise.

Keith Spencer of IESO will be conducting a two-day arc flash train-the-trainer course in Lexington, KY beginning November 8, 2011.  You can register or inquire about the course at the OSHA OutreachTrainers website (select “Arc Flash Train-the-Trainer” from the QuickSearch drop-down menu) or contact us directly from our website.  The cost is $695 per person.

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How can so many healthcare professionals think that healthcare is exempt from OSHA requirements or that compliance with The Joint Commission covers it?  Does OSHA even inspect hospitals?  How often and where?  Will you get cited for violations, and what about penalties? How much and for what? Who’s doing more healthcare inspections – States or Feds?  What are the top findings?  What about complaints?  The highest illness and injury rates IN THE NATION? 99,000 patient deaths per year from things they caught at the hospital??  You can’t be serious! Not at MY hospital!

IESO is working hard to support the upcoming 27th Annual Safety and Health Conference in Louisville, KY.  On Tuesday, May 10, Drs. Keith Spencer and Scott Harris will conduct an 8-hour HAZWOPER refresher as a pre-conference workshop available at no cost to all registered conference attendees.  Class size is limited, so register early.  Successful attendees will receive a joint certificate from IESO, LLC and UNC-Chapel Hill.

On Wednesday, May 11, Dr. Harris will present “OSHA in Healthcare – Is a Storm Coming?”  OSHA claims nosocomials to be among the leading causes of death in the United States, accounting for an estimated 1.7 million infections and 99,000 associated deaths in 2002.  If accurate, hospital-acquired infections, these things you catch while you’re there for something else, kill more people in the U.S. every year than AIDS, drug overdoses, food-borne illness, murder, highway, rail and plane crashes, lightning, tornadoes, West Nile Virus and workplace fatalities COMBINED.  This workshop explores OSHA coverage for Healthcare workers, the 2010 RFI, inspection rates and results and why OSHA may now be considering Healthcare a high-hazard general industry sector.

OSHA claims nosocomials to be “among the leading causes of death in the United States, accounting for an estimated 1.7 million infections and 99,000 associated deaths in 2002.”  If accurate, hospital-acquired infections, these things you catch while you’re there for something else, kill more people in the U.S. every year than AIDS, drug overdoses, food-borne illness, murder, highway, rail and plane crashes, lightning, tornadoes, West Nile Virus and workplace fatalities COMBINED.

OSHA has publicly stated, “The healthcare sector as a whole experiences 1.3 times the injury and illness rate for private industry, with hospitals even higher, at 1.8, and nursing homes fully double.”  They describe healthcare as having “a weak culture of worker safety” related to a lack of data on the prevalence of infections among healthcare workers (HCWs) and “a lack of effort by healthcare employers” in tracking or documenting them.  OSHA thinks too many of an estimated 16.5 million HCWs are getting sick at work and that voluntary standards are not working, largely due to poor safety programs and lack of regulatory oversight.

The 31st annual UNC Winter Institute is scheduled for January 31 to February 4, 2011 in Fort Lauderdale, FL.  The Institute is designed for industrial hygienists, safety and environmental managers, occupational physicians and nurses and anyone else involved in EHS management.  25+ courses will cover everything from regulations to industrial hygiene to environmental health, all eligible for recertification points toward your CHMM, CIH, CSP and other professional certs.

IESO will be there instructing Fundamentals of Environmental Health and the all-new OSHA 30-Hour General Industry for Healthcare course.  Many healthcare personnel have noted that the standard 30-hour OSHA course has little in common with their needs, and so this course was designed from the ground up by IESO to meet the specific needs of the healthcare industry. Our first-of-its-kind course will familiarize you with applicable OSHA standards while focusing on hazard recognition and prevention.  Special emphasis is placed on those areas that are the most hazardous, using OSHA standards as a guide.  It meets all OSHA requirements for time and content, and attendees who successfully pass the course will receive their 30-hour completion card.

Dr. Scott Harris of IESO, L.L.C. is chairing the search committee for healthcare speakers at the 2012 ASSE Professional Development Conference (PDC) scheduled for June 3-6 in Denver, CO.  The Healthcare Practice Specialty (HPS) serves safety, health and environmental (SH&E) professionals who work in healthcare institutions such as hospitals and nursing homes and other segments of the healthcare industry. Potential topics might include hazmat for healthcare, mass casualty planning, National Integrated Accreditation for Healthcare Organizations (NIAHO), ISO management systems, patient handling ergonomics, nosocomials and infection control, electrical safety and arc flash studies or any other relevant topics of interest to healthcare SH&E representatives.  You do not have to be an ASSE member or healthcare employee to present.

Whether giving or getting arc flash training, have you considered whether the trainer is “qualified,” “effective,” “proficient” or “competent” for the job?  Is the training content “adequate?”  How can we tell?  Does it matter?

Many OSHA standards require employee training, but are vague on trainer qualifications.  HazCom requires only “effective” training.  HAZWOPER specifies that trainers have “the training and/or academic credentials and instructional experience necessary to demonstrate competent instructional skills and a good command of the subject matter.”  The Bloodborne Pathogens standard requires only that the training record include “the names and qualifications of the persons conducting the training.”  No definition of credentials or “effective” training other than by performance failures, i.e., accidents.  “Competent” or “proficient” are often decided by incident investigations or lawsuits.  Remember, paperwork is the first place “they” look!

A Presidential Directive established the National Incident Management System (NIMS) as the “common language” for coordinated multi-agency responses for all Federal, state and local responders, including healthcare.  Hospitals are required by The Joint Commission (TJC) to implement 17 specific NIMS activities ranging from formal adoption to updated EOPs to mutual aid agreements, training and multi-agency exercises.  Coordination, planning and communication are key elements.

TJC specifies certain FEMA courses (IS-700, IS-800, ICS 100 and ICS 200), with the intended role of the responder dictating the type and depth of training required.  Trainers should have demonstrated experience as an Incident Commander in a NIMS environment.  HICS (Healthcare Incident Command System) training alone does NOT meet the NIMS requirements, but can supplement the program.  HICS incorporates standard Incident Command System (ICS) principles, but with modifications for healthcare.  IESO recommends “NIMS for Executives” for healthcare executives who need a working awareness of NIMS and their correct role in an event as facilitators.

In the May 6, 2010 Federal Register, OSHA published a Request for Information (RFI) to collect information from the healthcare industry on “occupational exposure to infectious agents in settings where healthcare is provided.”  This includes hospitals, outpatient clinics, clinics in schools and correctional facilities and “healthcare-related” settings ranging from laboratories that handle potentially infectious materials to medical examiner offices to mortuaries.  OSHA is specifically interested in current infection control strategies and practices and will use the information to “determine what action, if any, the Agency may take to further limit the spread of occupationally-acquired infectious diseases in these settings.”  The deadline for comments is August 4, 2010.  Download our Healthcare Alert for a brief summary.

Hospitals are covered under the OSHA/NFPA 70E requirements.  Arc flash/blast incidents can cause severe employee injury and loss of electrical power to key functions of patient care, while the cost of injury treatment may exceed $1,000,000 per case with permanent disability and probable litigation.  As one Director of hospital engineering services recently told us, “There are systems in the hospital that we just can’t shut down, and must perform our inspections on live parts.”

We recently published an article on our website in which we continue to recommend the rigorous analysis prescribed by IEEE 1584, and warn against “quickie” or generic 70E arc flash solutions. An industrial facility asked IESO to evaluate arc flash results from another firm that reportedly used a customized program for arc flash analysis.  The facility management was concerned about the lack of time the consultant spent on-site, the minimal review of electrical components and the generic results.  Our review revealed highly inaccurate information on 90% of the labels including incident energy ratings underestimated by 200-450%, clearly endangering employee safety.

A regulation change by OSHA in 2003 all but banned lift platforms.  Are you still using them?  Many are.  Do you have the required written approval?  Can you even get it?  Download our illustrated safety alert for the latest details on how to handle this issue.

Lift platforms, sometimes called safety platforms, are essentially work platforms attached to a forklift and used to raise personnel.  Think of them as a poor man’s aerial lift.  Such platforms are in common use and range in our experience from commercially produced and well designed to homemade models that would not even pass for a good deer stand.  Since May 1971 OSHA permitted elevation of personnel by a “safety platform firmly secured to the lifting carriage and/or forks” of the powered truck as long as there was adequate protection from falling objects and a means for personnel on the platform to shut off power to the truck.

The 33rd annual Occupational Safety and Health Summer Institute in Norfolk, VA is scheduled for July 26-30, 2010.  The Institutes, part of the North Carolina OSHERC continuing education program at the University of North Carolina at Chapel Hill, are designed for industrial hygienists, safety and environmental managers, occupational physicians and nurses and anyone else involved in EHS management.  There are about 30 courses covering everything from regulations to healthcare hazmat to environmental health, all eligible for recertification points toward your CHMM, CIH, CSP or other professional certs.

IESO will be there instructing Environmental Regulations for Occupational Health and Safety Professionals, and co-teaching two new courses, Managing Hazmat Responses in Healthcare and Environmental Health and Safety Management Systems in Healthcare.

IESO, LLC announces a new OSHA 30-Hour General Industry course customized for healthcare. Many healthcare personnel have noted that the standard 30-hour OSHA course seems to have little in common with their needs.  This healthcare-customized course will familiarize you with applicable OSHA standards while focusing on hazard recognition and prevention.  Special emphasis is placed on those areas that are the most hazardous, using OSHA standards as a guide.  What is unique about this course is that it was designed from the ground up to meet the specific needs of the healthcare industry, and we firmly believe it is currently the first and only one of its kind. It meets all OSHA requirements for time and content, and attendees who successfully pass the course will receive their 30-hour completion card.

On October 21, 2009 OSHA announced a proposed rule to address combustible dust explosions.  The rule would cover an estimated 16 million employees at approximately 426,000 facilities.  OSHA first addressed this issue in 1987 by promulgating 29 CFR 1910.272 for grain handling facilities.  In the 10 years prior to adopting that rule, there were 20.5 grain handling-related dust explosions per year in the U.S.  For the next 10 years there were 10.3, and from 1998-2007 there were 6.3 per year.

Following the 2008 Imperial Sugar explosion in Georgia, which killed, hospitalized or severely burned numerous employees, OSHA has been aggressively working toward drafting a comprehensive rule to address the larger issue of dust explosions in general industry, not just grain handlers.  Between 2007-2009, OSHA conducted 813 targeted inspections on affected facilities, issuing 3,662 citations primarily via the General Duty Clause.  In summarizing their findings, OSHA noted that 32 industry or consensus standards (i.e., NFPA, ASME, ANSI) address combustible dust, but that no single, comprehensive rule or standard exists.

The 30th annual UNC Winter Institute in St. Petersburg, FL is scheduled for February 14-19, 2010.  The Institute is designed for industrial hygienists, safety and environmental managers, occupational physicians and nurses and anyone else involved in EHS management.  There are about 30 courses covering everything from regulations to healthcare hazmat to environmental health, all eligible for recertification points toward your CHMM, CIH, CSP or other professional certs.

IESO will be there instructing Fundamentals of Environmental Health, and co-teaching two new courses, Managing Hazmat Responses in Healthcare and Environmental Health and Safety Management Systems in Healthcare.

The TradeWinds Island Resort in St. Pete Beach is a long-time favorite of attendees.  Please take a few minutes and review the agenda.  We believe you’ll find something really useful there and have a great time in a great place while improving your work skills and your network.

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Do you have structures with lightning protection?  Is it properly installed?  How can you tell?  While conducting a recent mock VPP audit, IESO discovered that a lightning protection system being installed did not comply with NFPA 780, the Standard for the Installation of Lightning Protection Systems.

Down-conductors were exposed inside the structure and improperly bonded to surrounding ground systems, which could have caused a sideflash during a strike.  Anchor points were set in mortar joints,

rather than brick and concrete, and numerous down-conductors had bends of 90 degrees in less than the required 8-inch span.  These “tight” bends greatly reduce carrying efficiency and increase the risk of sideflash as the bolt attempts to “find the path of least resistance.”  Imagine the system doing exactly what it should do by capturing a strike, then routing several hundred million volts and 20,000 amps INSIDE your facility fully exposed to employees, equipment and raw and finished materials, in this case flammable liquids!

Philips Lighting in Danville, KY will develop and implement their OHSAS 18001 program using in-part the first-ever Bluegrass State Skills (BSSC) grant awarded for a health and safety management system.  The $25,000 grant from the Kentucky Cabinet for Economic Development was the product of a cooperative effort between IESO and BSSC and their legal department.  Historically the grant program excluded health and safety from eligibility, but IESO successfully negotiated a great outcome for our client.

An article on Oil Spill Chemical Countermeasures recently published by Dr. Scott Harris, the Senior Risk Manager at IESO, LLC, appears in the July-August newsletter from the North Carolina Occupational Safety and Health Education and Research Center at the University of North Carolina at Chapel Hill (NC OSHERC).  The NC OSHERC is one of 17 regional education centers established by NIOSH to develop and support safety and health professionals, and is part of the UNC Gillings School of Global Public Health.

IESO, LLC recently published an arc flash article (http://iesollc.com/wordpress/2009/06/22/arc-flash-safety-history-and-requirements/) on our website.  We continue to recommend the rigorous analysis proscribed by IEEE 1584, and warn against “quickie” or generic solutions.  This safety alert illustrates a real-world example of why that is.

An industrial facility recently asked IESO, LLC to evaluate arc flash results from another consultant who reportedly used a customized program developed in-house.  The facility management team was concerned about the lack of time that the consultant spent on-site (less than five hours), the minimal review of electrical components and the generic results.  Labels for all electrical components were identical whether for buss plugs, MCC panels or substation switchgears, and the facility staff had serious doubts that they got what they paid for.

History and Awareness

Arc flash was first identified by Dr. Ralph Lee in his 1982 “The Other Electrical Hazard: Electric Arc Blast Burns.”  Dr. Lee found that as many as 80% of electrical injuries resulted from arc flash rather than from shock, which had always been thought to be the major risk associated with live electrical work.

By 1990 the threat of arc flash was well established, and OSHA updated 29 CFR 1910 Subpart S to recognize the need for arc flash safety.  NFPA 70E, the Electrical Safety Workplace Standard, was revised to include the calculations necessary to establish arc flash protection boundaries, and equipment manufacturers began to offer arc-resistant switchgear as a means to minimize arc flash hazards.

Some insurance companies, for example IF Group (http://www.if-insurance.com/web/industrial/Pages/default.aspx), recently added a “Plastics in Construction” clause to their coverage requirements for industrial clients.  They are concerned about composite panels with combustible isolation materials such as polyurethane (PU), polystyrene (EPS) or polyisocyanureate (PIR), and indicate recent severe losses related to this.

In the case of IF Group, the new clause is still a recommendation, but it looks certain to become a requirement, since they are already referring to it as a “regulation.”  Other Carriers may or may not follow suit, but if they see risk or exposure on the issue, expect them to aggressively manage it with this or a similar tool.  Either way, none of us want plastics fires in the workplace, and those that have seen them especially understand that.

Independent audits and reviews are one very good way of evaluating a program objectively and accurately to determine vulnerabilities and risk. These plans and programs come in many forms and serve many purposes, ranging from EPA and OSHA compliance and Emergency Action Plans to Risk Management Plans, Worst-case Scenarios and Off-site Consequence Analysis to SPCC and RCRA contingency plans.

A related critical risk management tool follows an environmental incident, such as a spill or explosion, and is frequently referred to as an Emergency Response Review or “Hotwash.” Following the review, you may be asked to develop a “lessons learned” or “after-action report” to help do the job better and safer the next time. EPA or other Agencies often require this following an emergency response in which they were involved.