OSHA Inspection: ATLAS DEVELOPMENT CO. DBA MOUNT CARMEL NURSING CTR

Issued

Oct 26, 1992

Abate by

Sep 15, 1994

Penalty

Initial $5,000 · Current $1,000 Reduced

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 repetitive lifting and other strenuous
operations.  This exposure caused, aggravated, or precipitated employee
injuries to the trunk and upper extremities.  The exposure occurred at
the following operation:
a)  Nursing Department:  Nursing personnel including
nursing assistants (NA) and licensed practical nurses
(LPN), while performing routine patient transfer
activities.  The injury records for 1989, 1990 and 1991
document a pattern of such injuries.
The following conditions contributed to the existence
of this hazard:
1.  Administrative procedures did not provide for
effective communication to employees of information
relating to resident transfer methods.  This
information is necessary to reduce the risk of
employee injury.  This condition was evidenced by
inadeaquate  transfer information on resident care
plans, by the practice of employees performing solo
transfer of residents, and manual transfer methods
that involve high stress lifting.
2.  Management involvement in addressing ergonomic
hazards was inadequate as evidenced by the absence
of effective implemented written program outlining
ergonomic program goals, policies, procedures, and
workplace evaluation techniques.
3.  The training program did not include an adequate
opportunity for employees to practice transfer
methods in realistic situations.
4.  Assist devices were inadequate as to variety,
quantity, maintenance and policy of use.
5.  An injury prevention program had not been developed
and implemented that would allow for expert review
of workplace conditions, work practices, and work
routines that contribute to employee injuries.
AMONG OTHER METHODS, A FEASIBLE AND ACCEPTABLE ABATEMENT METHOD TO CORRECT
THIS HAZARD WOULD BE IMPLEMENTATION OF AN EFFECTIVE PROGRAM FOR DEALING     W
RESIDENT TRANSFER.  AT A MINIMUM INCLUDE THE FOLLOWING ELEMENTS IN THE
PROGRAM:
I    Management Commitment
1.  Implement an ergonomics program.  Ensure that the
program includes a clear statement of management's
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 or
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
employee's 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 arm rests and removable
or swing away foot rests are available in
sufficient
quantity to ensure resident transfers are
performed according to the ergonomic program.  When
selecting a particular type of assist device
include consideration of resident comfort and 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 transfers 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
toileting facilities.
5.  Analyze equipment considered for purchase to
determine that it is ergonomically appropriate for
the work settings.
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 that 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 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 minmum:
(a)  A review of the back injury prevention
policy.
(b)  A discussion of the general rules of
body mechanics, along with those
musculosketal
disorders which result from
overexertions encountered during lifting
and patient transfer tasks.
(c)  Hands-on demonstrations 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
occurence of a back injury, along with a
description of the medical and
rehabilitation
services and return-to-work
programs which are available to these
employees.
4.  Refresher training will be provided that includes
practice and discussion of proper resident transfer
techniques.  Employees who miss training sessions
will be provided with 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 employeee
should demonstrate competence in use of these
devices.
V  Medical Management for Worker Injuries
1.  Implement a medical management program that
addresses the following issues:
1. Injury and illness recordkeeping
2. Early recognition and reporting of injuries
3. Systematic evaluation and referral
4. Conservative treatment
5. Conservative return to work
6. Systematic monitoring
7. 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 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 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 frequencies or
weight and use of mechanical lifting devices and aids.
All proposed control 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 back injury prevention program and upon
verification of the program's effectiveness in reducing
the occurence of musculoskeletal injuries among nursing
department personnel.

Issued

Oct 26, 1992

Abate by

Nov 3, 1992

Penalty

Initial $2,000 · Current $500 Reduced

Issued

Oct 26, 1992

Abate by

Nov 3, 1992

Penalty

Initial $2,000 · Current $500 Reduced

Issued

Oct 26, 1992

Abate by

Nov 3, 1992

Issued

Oct 26, 1992

Abate by

Nov 3, 1992

Penalty

Initial $2,000 · Current $500 Reduced

Issued

Oct 26, 1992

Abate by

Nov 3, 1992

Issued

Oct 26, 1992

Abate by

Nov 3, 1992

Penalty

Initial $2,000 · Current $500 Reduced

Issued

Oct 26, 1992

Abate by

Oct 29, 1992

Penalty

Initial $2,000 · Current $500 Reduced

Issued

Oct 26, 1992

Abate by

Nov 3, 1992

Penalty

Initial $2,000 · Current $500 Reduced

Issued

Oct 26, 1992

Abate by

Nov 3, 1992

Penalty

Initial $14,000 · Current $3,000 Reduced

Issued

Oct 26, 1992

Abate by

Nov 3, 1992

Penalty

Initial $1,000 · Current $500 Reduced

Issued

Oct 26, 1992

Abate by

Nov 3, 1992

Issued

Oct 26, 1992

Abate by

Nov 3, 1992