Exposure to unsafe workplaces due to an ineffective safety and health program.

OSHA has noted a strong correlation between effective safety and health programs and a low incidence of occupational injuries and illnesses. Therefore, it is recommended that facilities develop and manage a safety and health program appropriate for the potential hazards present at their site. The different modules of this eTool suggest specific topics to address. The main elements of a safety and health program include:

• Management Leadership and Employee Participation.
  
  
• Workplace Analysis.
  
  
• Accident and Record Analysis.
  
  
• Hazard Prevention and Control.
  
  
• Safety and Health Training.
  
  
• Regular Program Review.

• Safety and Health Programs. OSHA Safety and Health Topics Page.
   
• Safety and Health Program Management Guidelines; Issuance of Voluntary Guidelines. OSHA Federal Register Notice 54:3904-3916, (1989, January 26). OSHA Voluntary guidelines to help employers develop a facility safety and health program.

Possible fire safety hazards from:

No marked exits from building, or exits that are locked or blocked; (e.g., crowded hallways, filled with equipment). Employees not aware of emergency plan. Fire hazard in construction areas with no exits or fire protection.

Employers must comply with OSHA Standards on Exit Routes, Emergency Action Plans, and Fire Prevention Plans, 29 CFR 1910 Subpart E, including:

• The number of exit routes must be adequate [29 CFR 1910.36(b)].
   
  • Two exit routes. At least two exit routes must be available in a workplace to permit prompt evacuation of employees and other building occupants during an emergency [29 CFR 1910.36(b)(1)].
     
  • More than two exit routes. More than two exit routes must be available in a workplace if the number of employees, the size of the building, its occupancy, or the arrangement of the workplace is such that all employees would not be able to evacuate safely during an emergency [29 CFR 1910.36(b)(2)].
     
  • A single exit route. A single exit route is permitted where the number of employees, the size of the building, its occupancy, or the arrangement of the workplace is such that all employees would be able to evacuate safely during an emergency [29 CFR 1910.36(b)(3)].
    
    For assistance in determining the number of exit routes necessary for your workplace, consult National Fire Protection Association standard, NFPA 101-2006, Life Safety Code.
     
• Exit routes must be free and unobstructed. No materials or equipment may be placed, either permanently or temporarily, within the exit route. The exit access must not go through a room that can be locked, such as a bathroom, to reach an exit or exit discharge, nor may it lead into a dead-end corridor. Stairs or a ramp must be provided where the exit route is not substantially level [29 CFR 1910.37(a)(3)].
  
  
• Each exit must be clearly visible and marked by a sign reading "Exit" [29 CFR 1910.37(b)(2)].
  
  

Employers need to comply with OSHA Standard 29 CFR 1910.38, Emergency action plans, and 29 CFR 1910.39, Fire prevention plans. See Dietary Fire Safety Module for further discussion of OSHA requirements.

• Address emergency evacuation with special consideration to evacuating physically impaired patients.
  
  
• Review emergency evacuation plans with employees initially, or whenever their responsibilities or plan changes [29 CFR 1910.38(f)].

Construction or Maintenance Operation Areas:

• Exit routes must be maintained during construction, repairs, or alterations. Any area under construction or under maintenance must:
   
  • Not be occupied in whole or in part until all exits required for that part are completed and ready for use [29 CFR 1910.37(d)(1)].
     
  • Continuously maintain existing exits and any existing fire protection, or other measures which provide equivalent safety [29 CFR 1910.37(d)(2)].
     
  • Not expose employees to hazards of flammable or explosive substances or equipment used during construction, repairs, or alterations, that are beyond the normal permissible conditions in the workplace, or that would impede exiting the workplace [29 CFR 1910.37(d)(3)].
     
  • Have travel from exits to outside continuously free and clear of obstruction. No materials or equipment may be placed, either permanently or temporarily, within the exit route [29 CFR 1910.37(a)(3)].

• Fire Safety. OSHA Safety and Health Topics Page.

Employers not maintaining records that help:

• Document trends in illness and injury.
  
  
• Develop information regarding the causes and prevention of occupational accidents and illnesses.

Recordkeeping forms 300, 301, 300A are available. Recordkeeping Policies and Procedures Manual. OSHA Directive CPL 02-00-135, (2004, December 30).   Highlights of OSHA's Recordkeeping Rule. OSHA Fact Sheet, 64 KB PDF, 2 pages.   OSHA Recordkeeping Help. OSHA Fact Sheet, 75 KB PDF, 2 pages.

• Recordkeeping. OSHA Safety and Health Topics Page.

Lack of information necessary to adequately implement Bloodborne Pathogens program and address Bloodborne Pathogen Hazards.

The Bloodborne Pathogens Standard [29 CFR 1910.1030], requires both medical and training records be maintained [29 CFR 1910.1020].

Medical Records must be preserved and maintained for each employee with occupational exposure to bloodborne pathogens [29 CFR 1910.1030(h)(1)].

• For at least the duration of employment plus 30 years, and must be kept confidential (not disclosed without written permission of employee, except by law) and separate from other personnel records and must also include:
  
  
  • The employee's name and social security number, hepatitis B vaccination status, including the dates of vaccination and medical records related to the employee's ability to receive vaccinations.
• If an exposure incident occurs, reports are added to the medical record to document the incident, including testing results following the incident, follow-up procedures, and the written opinion of the health care professional.

Training Records: Employers must establish and maintain a training record for all exposed employees for 3 years, from the date the training occurred which includes [29 CFR 1910.1030(h)(2)]:

• The names and job titles of all persons attending the training sessions, the dates, and content of the training sessions, and the trainer's name and qualifications.
  
  
• If the employer ceases to do business:
  
  
  • Training and medical records must be transferred to the next employer or successor employer.
    
    
  • If there is no successor employer, the employer must notify the Director of the National Institute for Occupational Safety and Health (NIOSH) for specific directions for the records at least 3 months prior to intended disposal.
  
  
• Both medical and training records must be available to [29 CFR 1910.1030(h)(3)(ii)]:
  
  
  • Director of NIOSH.
    
    
  • Assistant Secretary of Labor for Occupational Safety and Health.
    
    
  • Employees or employee representatives (someone having written consent of the employee).

Revised Bloodborne Pathogens Standard: As mandated by the Needlestick Safety and Prevention Act, OSHA has revised its Bloodborne Pathogens Standard 29 CFR 1910.1030, effective date April 18, 2001. The Revised Exposure Control Plan requirements make clear that employers must implement the safer medical devices that are appropriate, commercially available, and effective [29 CFR 1910.1030(c)(1)(iv)(A)], and get input from those responsible for direct patient care in [29 CFR 1910.1030(c)(1)(v)]. The updated standard also requires employers to maintain a log of injuries from contaminated sharps [29 CFR 1910.1030(h)(5)].

• Model Plans and Programs for the OSHA Bloodborne Pathogens and Hazard Communications Standards. OSHA Publication 3186, (2003). Also available as a 521 KB PDF, 29 pages.

Employers and employees are unable to participate effectively to assure a safe and healthful workplace.

• OSHA Employee Workplace Rights. OSHA Publication 3021-08R, (2003). Discusses employee rights and responsibilities and encourages employees to work cooperatively with employers to promote safe and healthful workplaces that add value to everyone: businesses, workplaces, and workers' lives.
   
• Employer Rights and Responsibilities following an OSHA Inspection. OSHA Publication 3000-09R, (2003), 159 KB PDF, 27 pages.  Describes employer rights and responsibilities under the OSH Act of 1970.

New OSHA Workplace Poster. OSHA Publication 3165. Also available as a 123 KB PDF, 1 page. Job Safety and Health Protection Poster, required to be posted in the workplace, describes employee responsibilities and rights. OSHA Poster, summarizes the major provisions of the OSHA Act of 1970 and tells employees how to file a complaint. OSHA requires employers to display the OSHA Poster in a conspicuous place where notices to employees are customarily posted [29 CFR 1903.2].

• For additional information on employee and employer rights and responsibilities, see:
  • Protecting Nursing Home Workers OSHA's Safety and Health Response. Includes a section on employer and employee rights and responsibilities.
  • Employer Responsibilities. A Spanish version is also available.
    
    
  • Employee Responsibilities. A Spanish version is also available.
     
  • Employee Rights. A Spanish version is also available.

Resident Rights:

• For additional information on the issues of residents rights, which is beyond the scope of this eTool, see:
  • Protecting Nursing Home Workers OSHA's Safety and Health Response. Includes a section on resident rights.
     
• For additional information on nursing homes, see:
   
  • Administration on Aging. US Department of Health and Human Services (DHHS). For over 35 years, the Administration on Aging has provided home and community-based services to millions of older persons through the programs funded under the Older Americans Act--home-delivered meals programs or nutrition services in congregate settings, or transportation, adult day care, legal assistance or health promotion programs. If you have visited a nursing home, you may have talked to one of our Ombudsmen, who provide an on-going presence in long-term care facilities, monitoring care and conditions and providing a voice for those who are unable to speak for themselves. The National Family Caregiver Support Program provides a variety of services to help people who are caring for family members who are chronically ill or who have disabilities.
     
    • National Clearinghouse for Long Term Care. Provides information and resources to help you and your family plan for future long-term care (LTC) needs.
      
      
  • Centers for Medicare and Medicaid Services (CMS)
     
    • Medicare. People with Medicare, family members, and caregivers should visit Medicare.gov, the Official U.S. Government Site for People with Medicare, for the latest information on Medicare enrollment, benefits, and other helpful tools.
       
    • Medicaid. Title XIX of the Social Security Act is a Federal/State entitlement program that pays for medical assistance for certain individuals and families with low incomes and resources.
      
      
  • Guide to Choosing a Nursing Home. Centers for Medicare & Medicaid Services (CMS), (2004). Also available as a 665 KB PDF, 67 pages. Medicare and Medicaid US Department of Health and Human Services publishes a guide to assist in selecting the right nursing home facility.
    
    
  • Nursing Home Overview. Centers for Medicare & Medicaid Services (CMS). Also available as a 26 KB PDF, 5 pages. Provides information on payment and patient rights, and a nursing home checklist, which will help you evaluate the nursing homes that you visit.

Exposure of employees to contaminated work surfaces at the nurses station from spilled lab samples such as blood or urine.

For additional information, see the Utility Module: Contaminated Work Environments and Appropriate Disinfectants.