OSHA Inspection: HARVARD MEMORIAL HOSPITAL

Issued

Oct 28, 1997

Abate by

Jun 30, 1998

Penalty

Initial $1,750

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 serious physical harm to employees. Employees
were exposed to the
hazards associated with lifting, transferring, and ambulating residents
who were heavy, non-
weight bearing, uncooperative, disoriented, or mobility impaired. These
exposures occurred
because assistive devices, such as gait belts and mechanical lifts, were
not used as necessary and
training was ineffective. These exposures caused, aggravated, or
precipitated employee injuries
to the trunk, upper extremities, and lower extremities. This exposure
occurred at Harvard
Memorial Hospital in the long term care wing during routine transfers and
care of the residents
by the nursing staff.  The nursing staff comprises registered nurses (RN),
licensed practical
nurses (LPN), certified nursing assistants (CNA), and nursing assistants
(NA).
Among other methods, a feasible and acceptable abatement method to correct
these hazards
would be the implementation of an effective program to address the hazards
associated with
resident lifts and transfers. An effective program includes, but it not
limited to, these four
elements:
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
lifting/transferring and other strenuous activities. Ensure that the
program 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, and OSHA 200 logs,
compiled through the
medical management program to identify those tasks that are most
physically
stressful and may
be related to employee injuries and illnesses.
2. Conduct ergonomic evaluations of those tasks which are associated with
the highest
frequencies of employee back injuries, such as lifting, 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 the use of
correct number of personnel
during the specified  lifting tasks.
3. Conduct periodic  workplace surveys to evaluate the implementation and
effectiveness of
transfer methods.
III. Hazard Prevention and Control
1. Assure that assist devices, such as mechanical lifts, are available in
sufficient quantity to
ensure transfers are performed according to the ergonomic program.
2. Use gait belts routinely for residents who require assistance
ambulating.
3. Develop and implement a maintenance program for lift assist devices.
Ensure that sufficient
backup equipment is available during periods when primary equipment is out
of service.
4. Where feasible, reduce the number of lifts by eliminating
wheelchair/dining chair transfers
at mealtimes.5. Perform baseline assessments of the lifting skills and
abilities of all new hires and contractors,
if used, prior to assignment to work area.
6. Assure that a sufficient number of personnel are available where
multiple employee resident
lift and transfers are required. This includes the assurance that the
nursing staff is fully aware
of this policy and are required to request assistance in multiple employee
transfer situations.
7. Assure that the 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
the staff is following the practices.
IV.  Training and education
1. Supervisory nurses will be trained to effectively evaluate the transfer
techniques
practiced by
the nursing staff.
2. Orientation training for new employees will include practice and
discussion of proper
lifting/transferring techniques.  On the job orientation will include the
opportunity for the
training officer to observe the trainee during lifting/transferring
procedures.
3. Training and education will include use and understanding of mechanical
lifting devices. At
least every year, or when the devices are changed or needed for use with a
new resident, each
employee should demonstrate competence with the use of the lift/transfer
devices.
4. Refresher training and education will be provided that includes
practice and discussion of
proper lifting/transferring techniques.
5. Employees returning to work after time off from a work related injury
will be reevaluated in
lifting/transfer techniques and retrained as necessary.
ABATEMENT CERTIFICATION REQUIRED FOR THIS ITEM.