OSHA Inspection: ST. LUKE'S HOSPITAL

Issued

Jul 25, 1988

Abate by

Apr 25, 1989

Penalty

Initial $420 · Current $420

Hazardous substances 8301

General-duty citation text

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:
a) Nursing department employees engaged in the manual pulling, lifting
and moving of patients were exposed to an increased risk of
musculoskeletal injuries. The hospital's injury and illness records
(OSHA-200 Logs) for 1987 and 1988 documented that there was a pattern
of back injuries among this group of employees that were caused or
aggravated by the exertions involved in the performance of these
tasks, on or about June 21, 1988.
A feasible and acceptable abatement method to correct this hazard is
the implementation of a comprehensive back injury prevention program.
This program should include at a minimum, the following elements:
1) A formal written policy endorsed by the Hospital Administrator or
President which outlines the authority and specific responsibilities
of the staff in the implementation, compliance and enforcement of
the various provisions of the hospital's back injury prevention
program.
2) Investigation and analysis of back injury cases as a means of
identifying specific, activities and patient care areas where
greatest number of incidents are occurring.
3) Detailed ergonomic evaluations of those tasks which are associated
with the highest frequencies of employee back injuries, including
the identification of specific elements in those tasks which are
capable of being modified through the use of mechanical lifting
devices and aids or changes in lifting methods, including where
necessary, the use of multiple personnel during specified lifting
tasks.
4) Official procedures and guidelines describing specific step-by-step
techniques for the various routine lifting and patient transfer tasks
performed by nursing department personnel.
5) Preplacement assessments of the lifting skills and abilities of all
new hires prior to assignment to specific patient care areas. (NOTE:
To minimize abuse of such placement procedures it is necessary to
identify the high-risk jobs and quantify the required job-demands.
Workers should be matched to jobs as a function of the specific job
demands and work capacities.)
6) Mandatory inservice back injury prevention training for all nursing
department employees who may be involved in lifting and patient
transfer tasks. Training sessions should include, at a minimum:
a) A review of the hospital's back injury prevention policy.
b) A discussion of the general rules of body mechanics, along with those
musculoskeletal disorders which may result from overexertions
encountered during lifting and patient transfer tasks.
c) Hands-on demonstrations of the specific lifting and patient transfer
techniques described in the hospital's procedures and guidelines with
specific emphasis on the use of mechanical lifting devices and aids.
d) A discussion of the benefits of exercise in reducing the incidence of
work induced back injuries, including the identification of sources
of information on specific exercises and available exercise programs.
e) A review of the procedures to be followed by employees subsequent to
the occurrence of a back injury, along with a description of the
medical rehabilitation services and return-to-work programs which are
available to these employees.
7) Internal monitoring of staff compliance with the policy and
procedures of the back injury prevention program.
ABATEMENT NOTE:
STEP 1 - Effective administrative protection, including the
establishment of a formal back injury prevention policy,
mandatory inservice training and preplacement assessments of
new hires, shall be provided as an interim protection measure
until feasible engineering and permanent administrative
controls can be implemented which will reduce employee exposure
to nominal risk.
STEP 2 - Submit to the Area Director a written, detailed plan of
abatement outlining a schedule for the implementation of
engineering and administrative measures to control employee
injury due to manual lifting and employee transfer tasks.
Engineering controls to reduce musculoskeletal stresses
include, but are not limited to, task redesign, reduction of
lifting frequency or weight and use of mechanical lifting
devices and aids. The plan shall include at a minimum, target
dates for the following actions which must be consistent with
the dates required by this citation:
1) Investigation and analysis of back injury cases to identify where
the greatest number of of incidents are occurring.
2) Ergonomic evaluations of the those tasks associated with the highest
frequencies of back injuries.
3) Development of procedures and guidelines for routing lifting and
patient transfer tasks.
4) Evaluation of mechanical lifting devices and aids.
5) Procurement, installation and implementation of selected procedures
and lifting devices.
6) Monitoring to assure effective utilization of the control measure(s).
Ninety (90) day progress reports are required during the abatement
period.
STEP 3 - Abatement shall have been completed by the implementation of
the back injury prevention program and upon verification of
the programs' effectiveness in reducing the occurrence of
musculoskeletal injuries among nursing department personnel.

Issued

Jul 25, 1988

Abate by

Oct 2, 1988

Penalty

Initial $640 · Current $640

Hazardous substances 1190

Issued

Jul 25, 1988

Abate by

Oct 2, 1988

Hazardous substances 1190

Issued

Jul 25, 1988

Abate by

Oct 2, 1988

Hazardous substances 1190

Issued

Jul 25, 1988

Abate by

Jul 28, 1988

Hazardous substances 1190

Issued

Jul 25, 1988

Abate by

Jul 28, 1988

Hazardous substances 1190

Issued

Jul 25, 1988

Abate by

Aug 25, 1988