NURSING HOME GUIDELINES
FREQUENTLY ASKED QUESTIONS
What are OSHA's Ergonomics for the Prevention of Musculoskeletal Disorders: Guidelines for Nursing Homes?
On April 5, 2002, Secretary of Labor Elaine L. Chao announced a four-pronged approach to reduce ergonomic injuries often referred to as musculoskeletal disorders, or MSDs, in the workplace. One of the prongs is the development of industry-specific and task-specific ergonomics guidelines. These guidelines provide information to nursing home employers and employees about potential ergonomic hazards and ways to reduce those hazards.
Why did OSHA choose nursing homes?
Providing care to nursing home residents is physically demanding work. Nursing home residents often require assistance to walk, bathe, or perform other normal daily activities. The experience of many nursing homes suggests that injury prevention efforts focused on resident lifting and repositioning methods can have success in reducing work-related injuries and associated workers' compensation costs. Providing a safer and more comfortable work environment has also resulted in additional benefits for some facilities, including reduced staff turnover and associated training and administrative costs, reduced absenteeism, increased productivity, improved employee morale, and increased resident comfort. By sharing industry best practices through guidelines and building upon the progress in the nursing home industry, OSHA hopes that other nursing home providers will take steps to address ergonomics problems in their facilities.
What is the goal of the guidelines?
The goal of the guidelines is the prevention and reduction of the number and severity of work-related MSDs in nursing homes. OSHA makes two primary recommendations in the guidelines to accomplish this goal:
No. The guidelines are particularly sensitive to resident rights and safety. Nursing homes that lift and reposition residents with mechanical devices have found this practice to be safer for their employees and safer for their residents. These facilities have also found that resident dignity, independence, and security are improved. Of course, there may be some situations where the condition of the resident will not be compatible with using a mechanical lift; in those situations it may not be possible to use mechanical devices.
Does OSHA recommend that nursing homes implement every recommendation in the guidelines?
No. OSHA recognizes that every nursing home is unique. Employers should adapt the recommendations contained in the guidelines to the size and circumstances of their workplace. OSHA recognizes that small nursing homes may not have the need for as comprehensive a program as would result from implementation of every action and strategy described in the guidelines. OSHA hopes, however, that small nursing home facilities will find many of the recommendations contained in the guidelines useful in their ergonomics efforts.
Does OSHA offer additional help for small nursing homes?
Yes. A free consultation service is available to provide occupational safety and health assistance to businesses. OSHA Consultation is funded primarily by federal OSHA but delivered by the 50 state governments, the District of Columbia, Guam, Puerto Rico, and the Virgin Islands. The states offer the expertise of highly qualified occupational safety and health professionals to employers who request help to establish and maintain a safe and healthful workplace. Developed for small and medium-sized employers in hazardous industries or with hazardous operations, the service is provided at no cost to the employer and is confidential. Information on OSHA Consultation can be found at www.osha.gov/dcsp/smallbusiness/consult.html, or by requesting the booklet Consultation Services for the Employer (OSHA 3047) from OSHA's Publications Office at (202) 693-1888.
Are the guidelines relevant only to the nursing home industry?
Although these guidelines are designed specifically for nursing homes, OSHA hopes that employers with similar work environments, such as assisted living centers, homes for the disabled, homes for the aged, and hospitals will also find this information useful. In outreach material, OSHA will communicate the utility of the recommendations made in the guidelines to a wide variety of industries. OSHA notes, however, that the recommendations in the guidelines are directed specifically at the nursing home industry. While employers in other industries may find the information useful, they should be careful to review whether the recommendations are appropriate for their industry and worksite.
Can an OSHA compliance officer cite a nursing home facility for not implementing the guidelines?
No. The guidelines are completely voluntary. They are not a new standard or regulation and do not create any new OSHA duties. Under the OSH Act, the extent of an employer's obligation to address ergonomic hazards is governed by the general duty clause, which requires employers to provide their employees with a workplace free from recognized hazards likely to cause death or serious physical harm. An employer's failure to implement the guidelines is not a violation, or evidence of a violation, of the general duty clause. OSHA has included language in the guidelines making it clear that the guidelines are strictly voluntary.
How can I get a copy of the guidelines?
The guidelines are available for downloading from OSHA's web site at www.osha.gov. A printed copy of the guidelines is also available from the OSHA Publications Office, Room N-3101, Department of Labor, 200 Constitution Avenue, NW, Washington, DC 20210, or by telephone at (800) 321-OSHA (6742). You may fax your request for a copy of the guidelines to (202) 693-2498. Finally, you can also order a printed copy of the guidelines from OSHA's web site.
Will OSHA provide training to nursing home employers?
Yes. OSHA's Office of Training and Education is developing a course to address nursing home ergonomics. The course will be offered at Training Institute Education Centers located throughout the country. For a schedule of courses, and to find an Education Center near you, contact the OSHA Training Institute, 2020 South Arlington Heights Road, Arlington Heights, Illinois, 60005, (847) 297-4810, or visit OSHA's training resources webpage at www.osha.gov/dcsp/ote/index.html.
Who should I contact if I have additional questions about the guidelines?
If you have additional questions about the guidelines, you should contact the OSHA Directorate of Standards and Guidance, Room N-3718, Department of Labor, 200 Constitution Avenue, NW, Washington, DC 20210, telephone (202) 693-1950.
GUIDELINE DEVELOPMENT PROCESS
What process did OSHA use to develop the guidelines?
OSHA reviewed existing ergonomics practices and programs, State OSHA programs, as well as available scientific information, to develop the guidelines. OSHA also met with stakeholders to gather information on the ergonomic problems present in the nursing home environment and the practices that have been used successfully in the industry. OSHA disseminated draft guidelines for public comment on August 30, 2002. On November 18, 2002, OSHA held a stakeholder meeting in the Washington, DC area to discuss the draft. OSHA thanks the many organizations and individuals involved for their thoughtful comments, suggestions, and assistance.
Did OSHA visit any nursing homes while developing the guidelines?
Yes. OSHA visited both large and small nursing homes while developing the guidelines and learned how these nursing homes implemented injury prevention efforts and reduced their work-related injuries and workers compensation costs. OSHA feels that the experience of these nursing homes has practical application for the nursing home industry as a whole. OSHA's site visit to Wyandot County Nursing Home led to the case study of Wyandot's ergonomics efforts in the guidelines.
Did OSHA consider the Department of Labor's Guidelines for Ensuring and Maximizing the Quality, Objectivity, Utility, and Integrity of Information Disseminated by the Department of Labor (IQG) when drafting the guidelines?
Yes. When preparing the guidelines, OSHA reviewed the IQG. The IQG establishes "information quality" as a Departmental performance goal. "Quality" involves "utility" (the usefulness of the information), "objectivity" (whether the information is accurate, clear, complete, and unbiased), and "integrity" (the security of the information). In order to ensure that the guidelines adhered to the principles established in the IQG, OSHA reviewed all of the statements in the guidelines to make certain that they were clear, accurate, and presented in a manner that was unbiased and maximized their usefulness to the public. OSHA also reviewed the references in the document to ensure they adhered to the principles of the IQG.
DESCRIPTION OF THE GUIDELINES/RESPONSE TO COMMENTS
How are the guidelines structured?
The guidelines are divided into five main sections.
Yes. This structure differs from the format of the draft guidelines, which were divided into three main sections (Management Practices; Worksite Analysis; Control Methods). Several stakeholders commented that the draft guidelines were too long and the language was too intimidating. Some were concerned that OSHA included too much information in the draft guidelines and thus de-emphasized its most important recommendations. The structure of the final guidelines responds to these concerns. The final guidelines are shorter than the draft guidelines. In addition, OSHA has stressed at the beginning of the document the two primary recommendations OSHA makes in the guidelines: (1) manual lifting and repositioning of residents should be minimized in all cases and eliminated where feasible; and (2) employers should implement a systematic process to address ergonomic problems in their facilities. The structure of the final guidelines also appropriately emphasizes the process of identifying ergonomics problems and implementing solutions. Finally, OSHA used simpler language in the document to make it more user-friendly.
Did OSHA review and consider the comments received from stakeholders on the draft guidelines?
Yes. OSHA reviewed all of the comments received on the draft and made a number of changes to the document in response to those comments. For example:
Some commenters asked OSHA to discuss only resident lifting and repositioning tasks. Why did OSHA include a discussion of activities other than resident lifting and repositioning in the guidelines?
While manual lifting and repositioning of residents account for the majority of lost workday injuries and illnesses in nursing homes, some reports indicate that there are a significant number of work-related MSDs that occur in nursing homes in activities other than resident lifting and repositioning. OSHA believes that providing information on nursing home activities that are not related to resident lifting and repositioning activities can be useful to their ergonomics efforts. Discussing some non-resident lifting and repositioning tasks that may in certain circumstances present problems for employees is also consistent with OSHA's commitment to issue "industry-specific" guidelines for nursing homes, rather than "task-specific" guidelines. OSHA notes, however, that the recommendations in the guidelines are directed specifically at the nursing home industry. While employers in other industries may find the information useful, they should carefully review whether the recommendations are appropriate for their industry and worksite.
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