OSHA Inspection: INTEGRATED HEALTH SERVICES OF HERSHEY AT WOODLANDS

Issued

May 12, 1994

Abate by

Jan 17, 1995

Penalty

Initial $1,350 · Current $1,350

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
employees were exposed to the
hazards of lifting patients in an unsafe manner and other strenuous
operations. This exposure caused,
aggravated, or precipitated employee injuries to the trunk and upper
extremities. This exposure
occurred at the following operation:
(a)Integrated Health Services of Hershey at Woodlands, Nursing Department:
Certified
Nursing Assistants (CNA); licensed practical nurses (LPN); and registered
nurses
(RN) while performing routine patient transfer activities. The injury
records for 1992,
1993, and 1994 document a pattern of such injuries.
The following conditions contributed to the existence of this hazard:
1.There is very little internal monitoring of staff compliance with verbal
and
written
policy and procedures of the back injury prevention program.
2.All CNA's have not received training concerning transferring residents,
nor had
others received annual training concerning transferring residents.
3.CNA's have performed two-person assisted transfers of residents by
themselves
because of a shortage of help, while  other employees were performing
other duties at
the time.
4.There is no established maintenance program for the mechanical lifts.
Patient
handling devices were not maintained in fully operational condition, which
meant they
were not available for performing total transfer lifts of residents.
5.There is no established program for retraining LPN's and CNA's after a
back pain
incident.
Among others one feasible and acceptable abatement method to correct this
hazard is to institute an
effective Back Injury Prevention Program. An effective program may include
elements such as, but
not limited to the following:
I.  Management Commitment
1.Implement an ergonomics program.  Ensure that the program includes a
clear
statement of managements commitment to effectively deal with the problem of
employee injuries related to resident transfers and other strenuous
activities.  Ensure
that the program is written; addresses the area of employee involvement;
and provides
a mandatory mechanism for regular program review and evaluation.
II.  Worksite Analysis
1.Analyze medical, safety and insurance records including the OSHA-200 log
and
information compiled through the medical management program;
2.Identify those employee jobs that are the most physically stressful and
may be related
to employee injuries;
3.Conduct detailed ergonomic evaluations of those tasks which are
associated with the
highest frequencies of employee back injuries, such as resident lifting or
laundry
handling, including the identification of specific elements in those tasks
which are
capable of being modified through the use of mechanical lifting devices
and aids and
changes in lifting methods, including where necessary, the use of multiple
personnel
during specified lifting tasks.
4.Conduct periodic workplace surveys to evaluate the implementation and
effectiveness
of resident transfer methods.
III. Hazard Prevention and Control
1.Ensure that patient chairs and other furniture are designed to
facilitate
safe transfer.
For example, select chairs that allow for proper positioning of employees
feet during
a resident transfer and which are at heights compatible with other
equipment. Give
consideration to location of controls and the range of height adjustments
for beds.
2.Assure that assist devices such as hoists, transfer boards and
wheelchairs with
removable armrests and removable or swing away foot rests are available in
sufficient
quantity to ensure resident transfers are performed according to their
ergonomic
program. While selecting a particular type of assist device include
consideration of
resident comfort and safety, and employee safety and preference.
3.Develop and implement a maintenance program for resident moving and lift
assist
devices.  Ensure that sufficient back up equipment is available during
periods when
primary equipment is out of service.
4.Reduce the number of resident transfer to the maximum extent feasible by
use of
equipment such as ramp scales that require no resident transfers and use
of shower
chairs that are compatible with toilet facilities.
5.Analyze equipment considered for purchases to determine that it is
ergonomically
appropriate for the work setting.
6.Establish official procedures and guidelines describing specific
step-by-step techniques
for the various routine lifting and patient transfer tasks performed by
nursing
department personnel.
7.Perform baseline assessments of the lifting skills and abilities of all
new hires prior to
assignment to specific patient care areas.
8.Assure that sufficient number of personnel are available where multiple
employee
patient lifting and transfer is required, and the nursing staff is fully
aware of the
policy relating to and not reluctant to request assistance in multiple
employee transfer
situations.
9.Assure that the existing policy and criteria relative to multiple
employee lifts is
sufficiently protective, and is being clearly communicated to the nursing
staff,
including supervisory personnel and the staff is following the policies.
IV. Training
1.Supervisory nurses will be trained to properly evaluate the resident
transfer techniques
practiced by the nursing staff.
2.Orientation training for new employees will include practice and
discussion of proper
resident transfer.
3.Mandatory in service 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 back injury prevention policy.
(b)A discussion of the general rules of body mechanics, along with those
musculoskeletal disorders which result from over exertions encountered
during
lifting and patient transfer tasks.
(c)Hands-on demonstration and performance of the specific lifting and
patient
transfer techniques in the work setting with specific emphasis on the use
and
understanding of mechanical lifting devices and aids.
(d)A discussion of the benefits of exercise in reducing the incidence of
work
induced back injuries, including 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 back injury, along with a description of the medical and
rehabilitation services and return-to-work programs which are available to
employees.
4.Refresher training will be provided that includes practice and
discussion of proper
resident transfer techniques.  Employees who miss training sessions will
be provide
equivalent training sessions.  Employees returning to work after time off
from a work
related injury will be re-evaluated in resident transfer techniques and
retrained as
necessary.
5.All employees expected to use lift assist devices will be trained in the
proper use and
limitations of the equipment before they are expected to use the devices.
At least
every year each employee should demonstrate competence in use of these
devices.
V.  Medical Management for Worker Injuries
1.Implement a medical management program that addresses the following
elements:
(a)Injury and illness recordkeeping.
(b)Early recognition and reporting of injuries.
(c)Systematic evaluation and referral.
(d)Conservative treatment.
(e)Conservative return to work.
(f)Systematic monitoring.
(g)Adequate staffing and equipment.
Abatement Note:
Step 1 - Effective administrative protection, including the establishment
of a formal back injury
prevention policy, mandatory in-service training and baseline assessments
of new hires, shall be
provided as an interim protective 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 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 lifting devices and aids.
All proposed measures shall
be approved by a person knowledgeable in the evaluation of workplace
conditions which cause lifting
disorders and injuries.
Step 3 - Abatement shall have been completed by the implementation of a
back injury prevention
program and upon verification of the program's effectiveness in reducing
the occurrence of
musculoskeletal injuries among nursing department personnel.

Issued

May 12, 1994

Abate by

May 30, 1994

Penalty

Initial $1,350 · Current $675 Reduced

Issued

May 12, 1994

Abate by

May 22, 1994

Issued

May 12, 1994

Abate by

Jun 14, 1994

Issued

May 12, 1994

Abate by

May 17, 1994

Issued

May 12, 1994

Abate by

Jul 29, 1994

Issued

May 12, 1994

Abate by

Jun 14, 1994

Hazardous substances 8400

Issued

May 12, 1994

Abate by

Jul 29, 1994

Hazardous substances 8400

Issued

May 12, 1994

Abate by

Jun 14, 1994

Hazardous substances 8400