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Violating the top OSHA citation may cost your SNF money

Nurse Leader Weekly, December 23, 2004

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If the Occupational Safety and Health Administration (OSHA) knocks on your facility's door tomorrow, do you know where inspectors' trained eyes will turn? Although ergonomics is a big focus for OSHA during nursing home inspections, ergonomics violations are not the top trouble spot for skilled nursing facilities (SNF).

Instead, citations related to the bloodborne pathogens standards head OSHA's nursing home inspection list-by a long shot. Between October 2003 and September 2004, OSHA cited violations under the bloodborne pathogens standard a total of 305 times during 120 inspections as of November, according to OSHA's Web site. SNFs paid a total of $127,767 for these citations.

"Keep in mind that those statistics [show citations by] federal OSHA only. There are 24 states that enforce their own occupational safety laws, and 26 states have federal OSHA offices enforcing safety laws," says Sam Church, BA, MA, managing director of The Safety Department, a consulting agency in Pittsburgh.

Although the bloodborne pathogens standard is broad, don't feel overwhelmed. You already know how important documentation is for reimbursement and resident care, and OSHA compliance is no different. The following documentation gaffes can be cause for citation in OSHA's eyes, according to Church:

* Omitting a standard requirement from your written policies and procedures. Your exposure control plan must address all bloodborne pathogens standard requirements. "Even if you're doing [every safety procedure] right, if it's not written down correctly, it's a violation," warns Church.

* Training lapses. If your facility fails to educate employees who were absent from the facility's annual required bloodborne pathogens refresher training-and you don't have proof that your SNF trained those employees at another time-OSHA could issue a citation.

* Employer certifications. This important component is a required element of your policies and procedures. An individual must sign the policies and procedures to certify that the facility in fact adheres to its written practices and provides adequate training. That way, OSHA can hold a person accountable for the organization's actions, Church explains. "This is similar to what you've seen with the Sarbanes-Oxley Act."

* Policies and practices don't match. If staff fail to practice an element of your facility's policies and procedures, it is also a violation.

But that's not all you should document. The federal OSHA standard requires you to assemble a staff committee to review bloodborne pathogens safety, such as testing safer needle devices or evaluating needleless techniques, says Libby Chinnes, RN, BSN, CIC, infection control consultant in Charleston, SC.

Keep a record of your staff committee's meetings and actions. Many facilities document this information as an addendum to their exposure control plans, Chinnes says. They include which safety devices staff reviewed, which staff participated, and which devices they adopted.

Source: Adapted from Briefings on Long-Term Care Regulations (December 2004), published by HCPro, Inc.

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