In recognition of:
- The importance of providing a safe and healthful work environment for employees in long-term care
facilities and the need to implement a comprehensive program for safety and health for the long-term
care community, and
- The value of employers, employees, safety/risk management, mentors, professional associations and
the government in bringing their respective skills to bear in a cooperative, focused, and voluntary
effort to promote worker safety and health,
The St. Louis Area Office and Kansas City Area Office of the Occupational Safety
and Health Administration, U.S. Department of Labor, the Missouri On-Site Safety and Health Consultation
Service, and Health Systems, Inc., agree to the joint implementation of this OSHA Partnership
Agreement.
The goal of this partnership is to reduce total case injury and illness rates (TCIIR) and Days Away,
Restricted, and Transferred (DART) rate by 10% at the end of the 3-year period. Under this
agreement:
Health Systems Inc. agrees that their facilities will:
- Provide documentation to OSHA that their safety and health program meets the core elements of
OSHA's Framework for a Comprehensive Health and Safety Program in Nursing Homes, and/or avail
themselves of the Missouri On-Site Safety and Health Consultation Service (if eligible);
- Consider and evaluate work practices and engineering controls. In addition, they will document
consideration of these controls and implement any changes that the participating facility considers
economically feasible and would contribute to a decrease in injuries/ illnesses;
- Conduct self-audits to ensure that the elements of the safety and health program are being
implemented by using a standardized form such as the OSHA Consultation-33, Safety and Health Program
Assessment Worksheet;
- Identify training needs and ensure attendance and participation of appropriate personnel at
supplemental training sessions that are necessary to achieve the partnership goals.
- Provide timely data for OSHA to track the progress toward the partnership goals. The data
collected will include OSHA 300 data, total numbers of hours worked, and total Days Away,
Restricted, and Transferred (DART) Rate rates with breakdown of data by:
job title,
injury/illness description,
cause of the incident,
and employee status (FT, PT, PRN, or temp agency).
Baseline data will include the years 2004-2006. OSHA will be provided with data for the individual
participating long-term care facilities, as well as aggregate or summary data for the participating
facilities combined.
- Eligible long-term health care facilities covered under this partnership will explore membership
in OSHA's Voluntary Protection Program. Interested facilities will avail themselves of the Voluntary
Protection Program Participants' Association mentoring program;
The St. Louis and Kansas City Area Offices of the Occupational Safety and Health
Administration the Missouri On-Site Safety and Health Consultation Service will provide training to
participants which will address issues relating to the occupational safety and health of employees at
residential care facilities. Topics may include ergonomics related to resident transfers, workplace
violence related to resident aggression, bloodborne pathogens, tuberculosis, incident investigations
and accurate recordkeeping.
The St. Louis Area Office will also conduct recordkeeping verification monitoring visits to ensure
the accuracy of the injury and illness data.
This agreement places a high priority on reducing the hazards that contribute most to the high
injury and illness rates prevalent in the long-term care facility industry.
Core Elements for the OSHA Strategic Partnership (OSP):
A. Identification of Partners:
The primary partners are OSHA, Health Systems Inc., and the Missouri On-Site Safety and Health
Consultation Service.
OSHA participation includes the St. Louis and Kansas City Area Offices.
B. Purpose/Scope:
Bureau of Labor Statistics (BLS) data revealed that “Nursing and Residential Care Facilities” had a
total recordability injury and illness rate (TCIIR) of 9.1 and a Days Away, Restricted, and Transfer
(DART) rate of 5.7 for 2005. The TCIIR is nearly twice the national average for all private-sector
employers (4.6 in 2005), and over twice the nationwide DART rate (2.4).
The partners and stakeholders agree that injuries caused by resident transfers and workplace
violence related to resident aggression are two of the primary causes of injuries responsible for
high injury and illness rates in their workplaces.
Long-term care facilities also find that they have difficulty attracting and retaining employees.
Although there are many factors that may contribute to this situation, it is thought that improving
the overall safety and health working conditions, with adequate employee participation, may also
improve the high turnover rate associated with nursing homes.
C. Goals/Strategies:
The partnership goal is to reduce total case injury and illness rates (TCIIR) and Days Away,
Restricted, and Transferred (DART) rate by 10% at the end of the 3-year period. This will be
accomplished through a 3-year partnership in which Health Systems Inc. facilities will develop and
implement an effective comprehensive safety and health program or enhance a current program.
D. Performance Measures:
The primary measurement system will be evaluation of data from the participating nursing homes to
include OSHA 300 data and employee hours worked. Tracking of such data will occur annually at a
minimum.
The past three years of injury and illness data will be provided by Health Systems Inc to the St.
Louis Area Office in order to target particular problems, and establish the baseline for measuring
progress toward goals.
Ongoing evaluation and monitoring of the implementation of the elements of a comprehensive safety
and health program will be achieved through self audits using a standardized form such as the OSHA
Consultation-33, Safety and Health Program Assessment Worksheet on an annual basis.
Additional items to be tracked include provision of training and education in selected topics
provided by the St. Louis Area Office, the Kansas City Area Office, and the Missouri On-Site Safety
and Health Consultation Service. Training topics may include ergonomics related to resident
transfers, workplace violence related to resident aggression, bloodborne pathogens, tuberculosis,
incident investigations and accurate recordkeeping.
E. Annual Evaluation:
Measurement data will be evaluated at one-year intervals starting one year from the approval date of
this partnership. Health Systems Inc. will also provide additional data necessary to complete the
OSHA annual evaluation (see Appendix A), including numbers of self-inspections conducted, numbers of
hazards eliminated, number of employees trained, training hours, etc. Participants will evaluate the
overall effectiveness of the partnership, training provided through the partnership, and aggregate
data.
F. Benefits:
OSHA and the Missouri On-Site Safety and Health Consultation Service will provide Health Systems,
Inc with training presentations in issues affecting the occupational safety and health of employees.
The state consultation service will assign a higher priority to facilities under this partnership
that request their services.
G. OSHA Verification:
Partnering facilities remain subject to OSHA inspections and investigations in accordance with
established agency procedures. The long-term care facilities included in this partnership may be
scheduled for inspection under the current and future targeting systems developed by OSHA, complaint
inspections, referral inspections, and inspections related to investigations of fatalities and
catastrophes.
The St. Louis Area Office will conduct recordkeeping verification monitoring visits to ensure the
accuracy of the injury and illness data. Limited employee interviews will be conducted as part of
this process. At least two recordkeeping verification monitoring visits will be conducted among all
participating facilities annually.
If a Health Systems, Inc. facility receives a planned, complaint or referral inspection, and
citations are proposed, they may be considered for a penalty reduction. The good faith penalty
reduction would be in recognition of an employer's effective safety and health program. A penalty
reduction of up to 25% will be considered if the inspection does not result in a high gravity
serious, willful or repeat violation.
H. OSP Management and Operation:
OSHA and the Missouri consultation program shall be responsible for conducting training as specified
in this agreement. Health Systems Inc. shall provide timely data on workplace injuries and illnesses
and employee hours worked. This data will be provided on an annual basis. Health Systems Inc. will
also provide additional data necessary to complete the OSHA annual evaluation, including numbers of
self-inspections conducted, numbers of hazards eliminated, number of employees trained, training
hours, etc.
I. Employee Involvement and Employee Rights:
This partnership does not preclude employees and/or employers from exercising any right provided
under the OSH Act, nor does it abrogate any responsibility to comply with rules and regulations
adopted pursuant to the Act.
Information regarding this partnership will be communicated to employees through meetings, employee
newsletters, new employee orientation, in-services, and other means utilized by the participating
facilities such as bulletin boards or posters.
A system will be developed to increase the number of employee suggestions to management in regard to
safety and health concerns.
Employees will be involved in the development, implementation, and evaluation of safety rules,
policies, and procedures.
Facilities that have or develop safety and health committees should ensure that these committees are
represented by a cross section of facility departments and disciplines.
Safety and health committee members, if applicable, department heads, and employee(s) will be
included in accident and incident investigations.
J. Term of Partnership:
This agreement will terminate three years from the date of the signing. If any signatory of this
agreement wishes to terminate their participation prior to the established termination date, written
notice of the intent to withdraw must be provided to all other signatories.
The failure to provide timely data as requested by the OSHA Area Office may result in termination of
this agreement.
If OSHA chooses to withdraw its participation in the partnership, the entire agreement is
terminated. Any signatory may also propose modification or amendment of the agreement.
Signed this day of _______________, 2007:
Bill McDonald, CSP
Area Director, St. Louis Area Office |
|
Barb Theriot
Area Director, Kansas City Area Office |
|
Robert Simmons
Director, Missouri Onsite Consultation Program |
|
Tracey Smith, M.D.
Health Systems, Inc. |
|
Appendix A
OSHA Strategic Partnership Program
Annual Partnership Evaluation Report |
| Partnership Name |
Health Systems, Inc.
|
| Describe any benefits your facility
has experience as a result of participation in this partnership |
|
| Describe any improvements
in your safety and health management system in the past year related to: |
| Goal |
Strategy |
Measure |
MANAGEMENT COMMITMENT/
EMPLOYEE INVOLVEMENT |
|
|
WORKSITE ANALYSIS |
|
|
HAZARD PREVENTION AND CONTROL |
|
|
EMPLOYEE TRAINING |
|
|
| Describe any future plans you have
related to the above four elements of an effective safety and health program |
|
|
2.
Section 1 General Partnership Information |
| Date of Evaluation Report |
|
| Evaluation Period: |
Partnership start date |
|
Evaluation Period
End Date |
|
| Evaluation Contact Person |
|
| Contact Person
Phone # |
|
| Partnership Coverage |
| # Active Employers |
1 |
# Active Employees of the partner employer |
|
| # "contractor employers" at site |
|
Total # "contractor" Employees at site |
|
| Industry Coverage (note range or
specific SIC and NAICS for each partner) |
| Partner |
SIC |
NAICS |
| Nursing Home Partner (circle applicable SIC/NAICS) |
8051/8052/8059 |
623110 |
| |
|
|
| Contractor Employer |
|
|
| |
|
|
| |
|
|
| |
|
|
| |
|
|
| |
|
|
|
3. Section 2 Activities Performed |
| Note whether an activity was
required by the OSP and whether it was performed |
| |
Requested or was subjected to: |
Received/ performed |
| a. Training |
|
|
| b. Consultation Visits |
|
|
| c. Safety and Health Management Systems
Reviewed/Developed |
|
|
| d. Technical Assistance |
|
|
| e. VPP-Focused Activities |
|
|
| f. OSHA Enforcement Inspections |
|
|
| g. Offsite Verifications |
|
|
| h. Onsite Non-Enforcement Interactions |
|
|
| i. Participant Self-Inspections |
|
|
| j. Other Activities |
|
|
| 2a. Training (if performed,
provide the following totals) |
| Training sessions conducted by OSHA staff |
|
| Training sessions conducted by non-OSHA staff |
|
| Employees trained |
|
| Training hours provided to employees |
|
| Supervisors/managers trained |
|
| Training hours provided to supervisors/managers |
|
| Briefly describe activities and total
Numbers of employees affected, or explain if activity provided for but not performed |
|
| 2b. Consultation Visits (if
performed, provide the following total) |
| Consultation visits to partner sites |
|
| Comments/Explanations (briefly
describe activities, or explain if activity required but not performed) |
|
| 2c. Safety and Health Management
Systems (if performed, provide the following total) |
| Systems implemented or improved using the 1989 Guidelines as a
model |
|
| Comments/Explanations (briefly
describe activities, or explain if activity required but not performed) |
|
| 2d. Technical Assistance
(if performed, note type and by whom by putting the total numbers of your employees in the
applicable column) |
| |
Provided by OSHA Staff |
Provided by Partners |
Provided by Other Party |
| Conference/Seminar Participation |
|
|
|
| Interpretation/Explanation of Standards or OSHA Policy |
|
|
|
| Abatement Assistance |
|
|
|
| Speeches |
|
|
|
| Other (please specify) |
|
|
|
| Comments/Explanations (briefly
describe activities, or explain if activity required but not performed) |
|
| 2e. VPP/SHARP-Focused Activities (if
your facility is in process of working to become a VPP or SHARP participant please mark the box
with a "Y") |
| Partner site actively seeking VPP or SHARP participation? |
|
| Applications submitted? |
|
| VPP or SHARP on-site evaluation completed? |
|
| Comments/Explanations (briefly
describe activities, or explain if activity required but not performed) |
|
| 2f. OSHA Enforcement Activity (if
performed, provide the following totals for any programmed, unprogrammed, and verification-related
inspections at this establishment) |
| OSHA enforcement inspections conducted |
|
| OSHA enforcement inspections in compliance |
|
| OSHA enforcement inspections with violations cited |
|
| Average number of citations classified as Serious, Repeat, and
Willful |
|
| Comments/Explanations (briefly
describe activities, or explain if activity required but not performed) |
|
| 2g. Offsite Verification (if
performed provide the following total) |
| Offsite verifications performed |
|
| Comments/Explanations (briefly
describe activities, or explain if activity required but not performed) |
|
| 2h. Onsite Non-Enforcement
Verification (if performed provide the following total) |
| Onsite non-enforcement verifications performed |
|
| Comments/Explanations (briefly
describe activities, or explain if activity required but not performed) |
|
| 2i. Participant Self-Inspections
(if performed provide the following totals) |
| # of Self-inspections performed |
|
| # of Hazards and/or violations identified and corrected/abated |
|
| Comments/Explanations (briefly
describe activities, or explain if activity required but not performed) |
|
| 2j. Other Activities (briefly describe other
activities performed) |
|
|
4.
Section 3 Illness and Injury InformationA |
BASELINE DATA
List your company's number of injuries/illnesses from your OSHA 300 logs for the following years.
| |
2004 |
2005 |
2006 |
| a. Total Number of Deaths |
__________ |
__________ |
__________ |
b. Total Number of Cases with Days Away From Work |
__________ |
__________ |
__________ |
c. Total Number of Cases with Job Transfer or Restrictions |
__________ |
__________ |
__________ |
d. Total Number of Recordable Cases |
__________ |
__________ |
__________ |
e. Total Number of Days of Job Transfer or Restrictions |
__________ |
__________ |
__________ |
f. Total Number of Days Away From Work |
__________ |
__________ |
__________ |
g. Total Number of Hours Worked by All Employees |
__________ |
__________ |
__________ |
h. Total # cases related to slips, trips, falls |
__________ |
__________ |
__________ |
i. Total # cases related to patient handling |
__________ |
__________ |
__________ |
j. Total # cases related to bloodborne pathogens |
__________ |
__________ |
__________ |
k. Total # cases related to tuberculosis |
__________ |
__________ |
__________ |
l. Total # cases related to violent acts/assaults |
__________ |
__________ |
__________ |
OUTCOME DATA
List your company's number of injuries/illnesses from your OSHA 300 logs for the following years.
| |
2007 |
2008 |
2009 |
| a. Total Number of Deaths |
__________ |
__________ |
__________ |
b. Total Number of Cases with Days Away From Work |
__________ |
__________ |
__________ |
c. Total Number of Cases with Job Transfer or Restrictions |
__________ |
__________ |
__________ |
d. Total Number of Recordable Cases |
__________ |
__________ |
__________ |
e. Total Number of Days of Job Transfer or Restrictions |
__________ |
__________ |
__________ |
f. Total Number of Days Away From Work |
__________ |
__________ |
__________ |
g. Total Number of Hours Worked by All Employees |
__________ |
__________ |
__________ |
h. Total # cases related to slips, trips, falls |
__________ |
__________ |
__________ |
i. Total # cases related to patient handling |
__________ |
__________ |
__________ |
j. Total # cases related to bloodborne pathogens |
__________ |
__________ |
__________ |
k. Total # cases related to tuberculosis |
__________ |
__________ |
__________ |
l. Total # cases related to violent acts/assaults |
__________ |
__________ |
__________ |
3a. What is your company's total case injury/illness incidence rate for the years (TCIIR)? |
__________ |
__________ |
__________ |
3c. What is your company's days away, restricted and transferred incidence rate for the years
(DART)? |
__________ |
__________ |
__________ |
| Comments (note any decreases or increases in
trends) |
|
|
5.
Section 4 Improvement Plans, Benefits, and Recommendations |
| Changes and Challenges
(check all applicable) |
| |
Changes |
Challenges |
| Management Structure |
|
|
| Employee Involvement |
|
|
| Worksite Analysis |
|
|
| Hazard prevention and control |
|
|
| Employee Training |
|
|
| Data Collection |
|
|
| Other (specify) |
|
|
| Comments on improvement
plans and needs to implement those plans |
|
| Partnership Benefits
(check all applicable) |
| Increased safety and health awareness |
|
| Improved relationship with OSHA |
|
| Improved relationship with employers |
|
| Improved relationship with employees or unions |
|
| Decreased injuries/illnesses |
|
| Other (specify) (i.e. reduced costs, improved morals,
increased productivity, lower EMR, etc) |
|
| Comments |
|
| Status Recommendation |
| Plan to continue with the partnership |
|
| Plan to terminate participation in the partnership |
|
| Continue with the following provisions: |
|
|
| Suggestions for Partnership Improvement) |
|
|
|
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