Text For Citation: 01 Item/Group: 001 Hazard:

Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to physical threats and assaults by patients: (a) UHS of Centennial Peaks LLC, dba Centennial Peaks Hospital, at 2255 S 88th Street, Louisville, CO: On and preceding 12/7/18, the employer did not furnish employment and a place of employment which were free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to physical threats and assaults by patients. Employees, including nurses and mental health counselors, were exposed to incidents of violent behavior by patients that resulted in serious injuries including bites, sprains, lacerations, bruising, scratches, concussion, and injuries to the head, torso, and legs from punches, kicks, forceful grabs, pushes, and tripping. Employees were exposed to the hazard of physical threats and assaults during routine interactions with patients who had known histories of violent behavior. The employer had not established or implemented effective measures to protect employees from assaults or other physical violence in the workplace. Abatement Note: Among other methods, feasible and acceptable means to abate the WPV hazards at Centennial Peaks Hospital included implementation of a comprehensive and effective WPV prevention program which includes engineering and administrative controls, as well as training to materially reduce WPV hazards. These controls include: Engineering Controls: 1. Provide a reliable and readily available communication device (e.g., personal panic alarm or walkie-talkie) to all employees who may work in close proximity to patients, including but not limited to nurses, MHCs, housekeeping staff, and case workers. Provide training on this equipment and ensure that the equipment is maintained in working order at all times. 2. Re-configure the nurses? stations in the units to include design features that prevent patients from jumping over, reaching into or over or otherwise entering into the workstations. Ensure items in the workstations, such as but not limited to hole punchers, staplers, telephones, cords, pens, computers, computer peripherals, and other items are not accessible by the patients, so they cannot be used as weapons. Administrative Controls: 3. Designate staff on each shift to monitor and respond to any incident of violence. Designated staff (e.g., Code Green Team, security staff, or crisis intervention specialists) must not be given other assignments that would prevent them from immediately responding to an incident. Staff must have the physical capability and training to effectively respond to aggressive patients. 4. Maintain staffing that is adequate for census and patient acuity, taking into consideration patient aggression and history of violence. Provide all direct patient care staff with advanced CPI training to effectively implement team restraint techniques. 5. Develop and implement the WPV policies identified in the written comprehensive WPV Prevention Program (WVPP) including: (1) Evaluation and assessment of WPV incidents or trends, including a worksite-specific hazard analysis that analyzes the worksite for risks, including but not limited to, potential weapons, potential for employees to be cut off from communication, delays in activating emergency alert systems, potential for physical entrapment of employees. The assessment should also include a records review and employee surveys to further assess potential risks; (2) Provide clear written procedures for how employees should respond to patients making threats, showing aggression, and assaults; (3) The WVPP must also provide for the participation of direct care staff such as MHCs and RNs, e.g., through the committees that discuss WPV incidents; (4) Implement administrative and engineering controls to reduce or eliminate WPV hazards, including an assessment of appropriate staffing levels for each unit; and (5) Annually review the WVPP and update as necessary. Solicit employee feedback during the review process. 6. Establish a system to communicate to all affected staff members any incidents of WPV and/or escalating behavior to ensure that the on-coming staff members are notified and aware of a patient?s previous acts of violence or aggression. Information sharing should occur during shift change as well as with other staff (such as food service employees) who may come in contact with aggressive patients. Assure that affected staff have dedicated time to review all intake information on a patient before working with them. Training: 7. Ensure all staff members who may come into contact with patients in the course of their work are trained in all elements of a comprehensive WVPP, including opportunities for them to be involved in evaluating and improving the program. Training should specifically include: (1) When and how to call for assistance, including how to use emergency communication systems such as walkie-talkies and/or panic buttons to initiate a response and use of the PA system (or other means) to summon additional help; (2) Uniform and effective methods for responding to a ?Code Green? or other type of WPV incident; (3) Hands-on exercises for de-escalation and restraints that include practice drills, and assault scenario drills to improve staff skills and confidence in responding to Codes, emphasizing the importance of team restraint. Include training tactics that teach self-extrication and escape; (4) How to contribute to a post-incident debriefing and/or root cause analysis; and (5) Properly wearing/storing badges/communication devices so they cannot be taken by patients. The hands-on exercises, practice drills and assault scenario drills should occur at least bi-annually and more frequently based on employees? abilities. A staff member is not considered available to assist with incidents of WPV if they are not able to complete the training and/or they are not comfortable implementing the appropriate actions while working with aggressive patients. Post Incident: 8. Conduct an investigation and debriefing after each act of WPV, including near misses, with the attacked and/or injured employee and other involved employees, including root cause or similar analysis, lessons learned, and corrective actions to prevent re-occurrence. Maintain accurate records of patient assault upon staff. Provide the attacked and/or injured employee and other involved employees an opportunity to provide feedback about specific measures that could prevent such future incidents. Review and evaluate each WPV related incident, and monitor for trends in areas with high rates of incidents such as the Pikes Peak and Crestone Peak units.