OSHA Inspection: UHS OF DENVER, INC.

Issued

Apr 1, 2019

Abate by

May 16, 2019

Penalty

Initial $11,934 · Current $11,934

General-duty citation text

OSH ACT of 1970 Section (5)(a)(1): 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 physical threats and assaults by patients:  a) On or about October 2, 2018, and at times prior, the employer, UHS of Denver, Inc. dba Highlands Behavioral Health System (HBHS), failed to keep the workplace free of hazards.  Employees in direct contact with patients (including BHAs, RNs, Intake Clinicians and other direct care providers) have suffered serious workplace violence (WPV) related injuries such as concussions, broken skin, bruising, scratches, sprains and strains, and injuries to the head and torso while performing their job duties, including but not limited to providing care to patients and placing patients in therapeutic holds. The majority of affected employees are BHAs, who are responsible for direct patient care.  Two-thirds of the documented incidents occurred during the evening and weekend shifts.  Among other methods, feasible and acceptable means to abate the WPV hazards at HBHS include implementation of a comprehensive and effective WPV prevention program ( which includes engineering and administrative controls, as well as training to materially reduce WPV hazards.  These controls include:    Engineering Controls    1.     Re-configure the nurses? stations in the units, to include design features that prevent patients from jumping over, reaching into or over or otherwise entering into the workstations.  Ensure items in the workstations, such as but not limited to hole punchers, staplers, telephones, cords, pens, computers, computer peripherals, and other items are not accessible by the patients, so they cannot be used as weapons.    2.     Provide all staff members with a reliable and readily available communication device, such as a walkie-talkie or panic alarm button, in order to rapidly and reliably summon assistance to minimize or eliminate employee injury from WPV.  In addition, provide training and procedures on use and limitations of the equipment.    Administrative Controls     3.     Ensure that trained security or in-house monitoring staff continuously monitor security cameras for all units.      4.     Develop, integrate, and implement WPV policies and programs into one written comprehensive WPV Prevention Program (WVPP). This WVPP must include: (1) A worksite-specific hazard analysis that analyzes the worksite for risks, including but not limited to, potential weapons, potential for victims to be cut off from communication, delays in activating emergency alert systems, potential for physical entrapment of victim. The assessment should also include a records review and employee surveys to further assess potential risks; (2) The WVPP must address patient-on-employee violence and describe hazard prevention and control measures, providing clear written procedures for how employees should respond to patients making threats, showing aggression, and assaults; (3) The WVPP must also provide for the participation of direct care staff such as BHAs and RNs, e.g., through the committees that discuss WPV incidents; (4) Provide copies of the WVPP and make it readily available to all staff; (5) Annually review the WVPP and update as necessary. Solicit employee feedback during the review process; and (6) Provide bi-annual training on the WVPP to all staff.     5.     Designate specific staff with specialized training in security and/or hire trained security officers to monitor patients for potential aggression on all shifts and to assist in preventing and responding to violent events occurring in the units. Staff must have the physical capability to effectively respond to aggressive patients. The staff designated to monitor and respond to patient aggression should not be given other assignments such as patient rounds, which would prevent the designated person from immediately responding to an alarm or other notification of a violent incident. Conduct periodic drills for psychiatric crisis/patient aggression (currently known as ?Code Green?) to allow all designated staff to practice and evaluate their skills in real-life settings.     6.     Establish a system to communicate to all affected staff members any incidents of WPV and/or escalating behavior to ensure that the on-coming staff members are notified and aware of a patient?s previous acts of violence or aggression.  Information sharing should occur during shift change as well as with other staff (such as food service employees) who may come in contact with aggressive patients.  Assure that affected staff have dedicated time to review all intake information on a patient before working with them.      Training    7.     Ensure all staff members who may come into contact with patients in the course of their work are trained in all elements of a comprehensive WVPP, including opportunities for them to be involved in evaluating and improving the program. Training should specifically include: (1) When and how to call for assistance, including how to use emergency communication systems such as walkie-talkies, the overhead pager, and/or panic buttons; (2) Uniform and effective methods for responding to a ?Code Green? or other type of WPV incident; (3) Hands-on exercises for de-escalation and restraints that include practice drills, and assault scenario drills to improve staff skills and confidence in responding to Codes, emphasizing the importance of team restraint. Include training tactics that teach self-extrication and escape.  Assess the frequency needed for this training based on employees? abilities; (4) How to contribute to a post-incident debriefing and/or root cause analysis; and (5) Properly wearing/storing badges/communication devices so they cannot be taken by patients. The hands-on exercises, practice drills and assault scenario drills should occur at least bi-annually. A staff member is not considered available to assist with incidents of WPV if they are not able to complete the training and/or they are not comfortable implementing the appropriate actions while working with aggressive patients.       Post Incident:    8.     Conduct an investigation and debriefing after each act of WPV, including near misses, with the attacked and/or injured employee and other involved employees, including root cause or similar analysis, lessons learned, and corrective actions to prevent reoccurrence. Maintain accurate records of patient assault on staff.  Provide the attacked and/or injured employee and other involved employees with an opportunity to provide feedback about specific measures that could prevent such future incidents. Review and evaluate each WPV related incident, both on a case-by-case basis and to monitor for trends in areas with high rates of incidents such as the acute units.