OSHA Inspection: UNIVERSITY PARK NURSING CENTER

Issued

Oct 20, 1993

Abate by

Feb 17, 1995

Penalty

Initial $1,375 · Current $850 Reduced

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)  University Park Nursing Center, Nursing Department
Nursing assistants (NA); licensed practical nurses (LPN);
and registered nurses (RN) while performing routine
patient transfer activities.  The injury records for
1991, 1992, and 1993 document a pattern of such injuries.
The following conditions contributed to the existence of this
hazard:
1.   A formal written policy endorsed by the Administrator
which outlines the authority and specific
responsibilities of the staff in the implementation,
compliance, and enforcement of the various provisions of
the facility's back injury prevention program.
2.   There is no internal monitoring of staff compliance with
verbal policy and procedures of the back injury
prevention program.
3.   A few NA's had not received training concerning
transferring residents.
4.   There were insufficient assisting devices available for
performing a total assistance from floor level.
5.   There is no established maintenance program for the
mechanical lifts.
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

Oct 20, 1993

Abate by

Oct 30, 1993

Penalty

Initial $825 · Current $500 Reduced

Issued

Oct 20, 1993

Abate by

Oct 30, 1993

Issued

Oct 20, 1993

Abate by

Nov 22, 1993

Issued

Oct 20, 1993

Abate by

Nov 7, 1993

Issued

Oct 20, 1993

Abate by

Nov 7, 1993

Issued

Oct 20, 1993

Abate by

Oct 30, 1993

Issued

Oct 20, 1993

Abate by

Nov 7, 1993