Tag Archives: “proposed rule”

Joint Commission Requirements for NIMS in Healthcare

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.

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OSHA Looking Hard at Healthcare Worker Infectious Diseases

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.

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OSHA Regulation Alert: Combustible Dust Rule is coming

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.

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Proposed EPA Greenhouse Gas Reporting Rule

On March 10, 2009 EPA announced a proposed rule (“Mandatory Reporting of Greenhouse Gases”) that would apply to an estimated 13,000+ suppliers of fossil fuel and industrial chemicals, manufacturers of motor vehicles and engines and large direct emitters of greenhouse gases (GHGs) with emissions equal to or greater than a threshold of 25,000 metric tons per year.  Those familiar with existing reporting programs should think “Form R” for GHGs.  The quickest way to get familiar with it is to review the EPA fact sheet.

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