Tag: #OSHA

OSHA Releases Several Proposed Rules

The Occupational Safety and Health Administration (OSHA) this week released several proposed rules on the Federal Register. The proposed rules appear to have a direct impact on long term care and include the following:  

  1. Federal Register: Occupational Exposure to COVID-19 in Healthcare Settings 
    • ​OSHA is proposing to remove OSHA’s COVID-19 Emergency Temporary Standard and its associated recordkeeping and reporting provisions from the Code of Federal Regulations. 
    • ​OSHA proposes to clarify its interpretation of the General Duty Clause, 29 U.S.C. 654(a)(1), to exclude from enforcement known hazards that are inherent and inseparable from the core nature of a professional activity or performance. 
    • ​OSHA is proposing to remove some medical evaluation requirements in the Respiratory Protection Rule for certain types of respirators. This proposed change would only impact filtering facepiece respirators and loose-fitting powered air-purifying respirators. 
An additional proposed rule was withdrawn: 
    • ​​​OSHA is withdrawing the proposal to amend the OSHA 300 Log by adding a column that employers would use to record work-related musculoskeletal disorders. Withdrawal of the proposal does not change any employer’s obligation to complete and retain occupational injury and illness records under OSHA’s regulations. Withdrawal of the proposal also does not change the recording criteria or definitions used for these records. 
Please send any questions to regulatory@ahca.org. AHCA will submit comments to the Federal Register.

Simplifying Oxygen Signage Requirements

Managing life safety compliance is a complex, multi-faceted task. It requires knowledge in multiple codes, utilization of the proper code editions, and determination of which requirements are applicable to your building. This blog post will break down the requirements around oxygen signage.

The Healthcare Facilities Code® (NFPA 99) contains most of the requirements related to oxygen systems, storage and signage. CMS has adopted the 2012 edition of NFPA 99. Oxygen signage requirements fall into two categories: signage for oxygen storage and signage when oxygen is in use.
When oxygen cylinders or containers are stored within an enclosure, a precautionary sign is required on the door or gate that is readable from a distance of five feet away. The signage must include the following wording:
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This requirement is intended to apply to rooms and enclosures where multiple cylinders are being stored. It is not necessary to place signage everywhere an oxygen cylinder is located in a building. For example, cylinders available for emergency use on carts, at nurse stations, and staged in small quantities are not subject to oxygen storage signage requirements.
The signage requirements that apply when oxygen is being utilized in the building depend on the facility’s smoking policy. A facility that prohibits smoking is only required to provide precautionary signage at the building’s major entry points. However, a facility that allows smoking must provide precautionary signage wherever supplemental oxygen is in use, including the aisles and walkways leading to such areas.  In all cases, the signage must be readable from a distance of five feet away. The annex section of NFPA 99 suggests signage be no smaller than 8 X 11 inches and include the following wording and symbol:
Oxygen2.png
Finally, if liquid oxygen is used in the building and transfilling occurs – where liquid oxygen is transferred from a base reservoir container to portable liquid oxygen containers – signage must be posted at the transfilling location indicating that transfilling is occurring and smoking is not permitted in the immediate area.
The detailed requirements for oxygen signage can be found in Chapter 11 (Gas Equipment) of NFPA 99. NFPA provides a free viewer where you can access codes and standards on their website. Hardcopy and user-friendly on-line subscriptions are also available for a fee at www.nfpa.org.
AHCA is always available to support members with life safety compliance questions. Inquiries can be emailed to emergencyprep@ahca.org.

Maintaining Your Respiratory Protection Program in LTC Centers: Actions and Frequencies

Long term care (LTC) centers must adhere to specific requirements for compliance with the Occupational Health and Safety Administration (OSHA) Respiratory Protection Standard (29 CFR 1910.134). The nature of airborne hazards, the presence of respiratory threats, the specific respiratory protection program, and the resulting compliance requirements will vary between organizations. Employers must recognize that once a Respiratory Protection Program (RPP) is established, ongoing maintenance is necessary to ensure compliance with the OSHA standard.

https://www.ahcancal.org/News-and-Communications/Blog/Pages/Maintaining-Your-Respiratory-Protection-Program-in-LTC-Centers-Actions-and-Frequencies.aspx

Navigating “Safety” in Long Term Care Centers: Separating the Roles of OSHA and the CMS requirements for Emergency Preparedness

Continuation: 

In this third article regarding the connection between the Occupational Safety and Health Administration (OSHA) and the Centers for Medicare & Medicaid Services (CMS) Life Safety and Emergency Preparedness (EP) Requirements, the focus will be on how OSHA’s regulations overlap with CMS’ EP requirements, found in 42 CFR 483.73 (Appendix Z).
It’s important to note that CMS’ EP requirements do NOT apply to assisted living, however any OSHA requirements do apply.

A Roadmap to OSHA Requirements = A Vital Guide for Long Term Care Providers

Understanding and adhering to Occupational Health and Safety Administration (OSHA) standards is a critical responsibility for long term care providers. To assist in this crucial task, AHCA/NCAL has released “A Roadmap to OSHA Requirements,” a comprehensive resource designed to simplify OSHA​regulations for providers.​

This roadmap is a practical guide, offering detailed insights into relevant OSHA standards and how they intersect with CDC guidelines and CMS requirements. The roadmap doesn’t just cover existing regulations; it also provides previews of upcoming OSHA changes that could impact long term care. This preview is essential for staying abreast of future regulatory requirements and maintaining a safe environment for your staff.

AHCA/NCAL’s roadmap is an invaluable tool for long term care providers seeking to navigate the complexities of OSHA compliance. It also underscores the long term care communities commitment to maintaining high standards of workplace safety and health.

Explore “A Roadmap to OSHA Requirements” to enhance your organization’s compliance and safety practices. Access this vital resource on the AHCA/NCAL website: A Roadmap to OSHA Requirements.​

https://www.ahcancal.org/Survey-Regulatory-Legal/Documents/A%20Roadmap%20to%20OSHA%20Requirements.pdf

Respiratory Protection in Long Term Care

Most long term care (LTC) centers had no need for respirators before the pandemic because any patients with airborne infectious diseases were transferred and cared for in appropriate and capable alternate facilities. Moving forward, however, respirators and the compliance obligations that come with them are now part of the expected infection control and employee safety programs in most LTC centers. Importantly, OSHA has an entire standard devoted to respirators, the Respiratory Protection Standard (29 CFR 1910.134). While the OSHA standard can be complicated and is highly dependent on the type of hazard and respirator used, the following highlights the basic requirements that affect most LTC centers.

Read more at https://www.ahcancal.org/News-and-Communications/Blog/Pages/Respiratory-Protection-in-Long-Term-Care.aspx

Personal Protective Equipment, Hazard Assessment Standard, and the Hierarchy of Controls

The Hierarchy of Controls
When conducting a hazard assessment to determine PPE, it is important to understand that PPE is only one control measure. In fact, PPE is the last safety measure to consider as you see in the illustration below. In long term care, we use a mix of measures to minimize occupational hazards. In OSHA’s vocabulary, this mix is known as the “hierarchy of controls,”  which consists of FIVE levels: elimination, substitution, engineering controls, administrative controls, and personal protective equipment (PPE).
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The most effective measures are at the top of the hierarchy, with elimination and substitution being the preferred methods. These involve removing the hazard entirely or replacing it with something less hazardous. Engineering controls come next, focusing on designing and isolating hazards. Examples of such controls in LTC might be negative pressure rooms or barrier walls for protection against airborne infectious agents. Administrative controls involve changing work practices and policies, including infection control procedures and hand-washing protocols.