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

OSH ACT of 1970 Section (5)(a)(1): The employer did not furnish employment and a place of employment which was free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees are exposed to the hazard of workplace violence: a) Campus Wide: On or about July 11, 2016, Nurses and Mental Health Technicians who provide inpatient care, especially in the close observation and adolescent units, during the course of de-escalating aggressive patients or while trying to prevent patients from injuring themselves are exposed to serious physical injuries such as from bites, bruises, or strains and sprains. Among other methods, feasible abatement measures include, but are not limited to the following: a. Evaluation and modification to the Management of Aggression policy and the Workplace Violence policy to include the following. i. Clear written description of how to report incidents of workplace violence, including intimidation and verbal abuse. Provide guidelines on when to call police. ii. A clear written statement that employees will not experience retaliation for reporting incidents of threats or violence or for calling police. iii. Information on how and where employees affected by WPV can seek emotional support and mental health care including after hours. b. Develop workplace violence controls, including implementation of the following engineering and administrative controls and methods used to prevent potential workplace violence incidents. These controls and methods should include the following: i. Develop a workplace violence safety committee for the campus. Involve frontline employee with exposure to WPV including psychiatrists, social workers, nurses, and mental health technicians. a. Review workplace violence incidents during the meetings to ensure effective and timely follow-up. b. Develop a system for affected employees to report workplace violence safety concerns and suggestions anonymously. c. Develop a system to provide communication and feedback to affected employees about their workplace violence safety concerns and suggestions. d. Develop a system of flagging patients with a history of violence; and e. Determine the appropriate number of staff needed in each unit based on acuity of the workplace violence hazard to ensure a safe workplace for employees. Ensure the staffing levels are met daily and on each shift. ii. Provide all affected employees with reliable and readily available means of communication that are effective throughout the facility. Develop a policy to maintain the effectiveness of the communication devices such as walkie-talkies. Inform all employees of this policy and train them on the use of the equipment. Enforce the policy as necessary. iii. Perform a workplace hazard assessment of the units especially Close Observations and C1 to ensure nurse�s stations are secure. Evaluate the configuration of the nurse�s station desk, including the height and depth, to prevent patients from jumping over the desk and assaulting staff members. Ensure all items that could be used as weapons are secured or removed from the nurse�s station desk and other areas accessible to patients. iv. Evaluate the need and appropriateness of devices affected employees can use to protect themselves during a crisis such as but not limited to blocking pads. v. Ensure affected employees utilize a buddy system while providing service to patients with a history of violence. c. Development of a recordkeeping system designed to report any violent incident. The reports should be in writing and maintained for review after each incident and at least annually to analyze incident trends. i. Require and ensure that affected employees report all acts of violence to a supervisor or manager, regardless of severity. Investigate all violent incidents as soon as possible. ii. Review and analyze all crisis interventions with staff involved to determine root cause, what actions worked correctly and any necessary improvements. iii. Make any necessary changes to the patient�s Crisis Plan quickly. iv. Implement appropriate recommendations resulting from workplace violence incident investigations. d. Evaluation of training needs and implementation of appropriate workplace violence training. Determine the appropriate length of time between refresher classes and ensure affected employees received the training within that timeframe. The training should include the employer's workplace violence prevention program, crisis prevention, de-escalation techniques, the employer�s policies and requirements for recording and documenting a patient�s aggressive behavior, and how and when to complete an Employee Accident Report. e. Annually review the workplace violence prevention program, including updating the program as necessary. Such review and updates should set forth any mitigating steps taken in response to any workplace violence incidents. Solicit and include employee input in the review.