A. Purpose:
Because of the high incidents of injuries, particularly musculoskeletal disorders related to patient
handling, slips, trips, and falls, in nursing homes, it is the purpose of this partnership for the
participants to work cooperatively and collaboratively to reduce the number of such injuries. It is,
also, the purpose of this partnership to bring awareness about muscular injuries, bloodborne
pathogens, tuberculosis exposure and workplace violence to participants through education and
information. Other areas of concern based on previous inspection data would be Bloodborne Pathogens,
Tuberculosis Exposure, and Workplace Violence. These are areas that OSHA and LDOL OSHA Consultation
can provide training and information to nursing homes in order to make a significant reduction in
accidents and serious injuries and illnesses.
LNHA will send a letter and a copy of the partnership agreement to member nursing home operators in
the state of Louisiana notifying them of the partnership opportunity.
LNHA member homes that wish to partner will have thirty (30) days from the date of receipt to sign
the partnership agreement.
B. Definition:
Nursing home owner / manager (hereafter referred to as "nursing home operators") is any entity that
owns and / or manages a nursing home.
C. Goals and Objectives:
By entering into this partnership, the nursing home operators agree to adhere to requirements
intended to ensure continuous awareness of the facility’s safety and health program with the intent
to minimize injuries and illnesses. OSHA hereby agrees to verify that partnership requirements are
met and program goals are being attained by reviewing evidence of regular and effective safety
audits and inspections, accident investigations, and injury / illness data. The project goals are:
- To further reduce nursing home injuries and illnesses by 3% in the state of Louisiana among
participants through the development of an effective partnership.
- To provide information and materials to aid the employer in ensuring or improving internal safety
and health programs.
- To better utilize the Baton Rouge area office and Louisiana Department of Labor (LDOL) OSHA
Consultation resources by using partnership tools to achieve a higher level of worker safety and
health.
- To maximize Federal and State inspection resources by promoting more active employer and employee
participation and responsibility for safety and health management.
- To promote a cooperative relationship between OSHA, LDOL OSHA Consultation, and LNHA.
- To provide participating nursing homes with the most up to date research, information and tools
to combat the injury / illness problems affecting the industry.
D. Requirements for the Partnership:
The partnership is a collaboration under which the participating nursing home operator and his/her
successors make a commitment that the nursing home will create (with the help of OSHA / LDOL OSHA
Consultation) and maintain a written safety / health program and that the safety / health program
will contain elements of management leadership, employee involvement, hazard analysis, hazard
prevention / control and safety / health training. In addition, participating nursing homes hereby
agree to the following:
- Employees will be trained in hazard recognition and avoidance specific to the nursing home
industry, applicable OSHA safety / health standards, the nursing home’s safety / health policies and
on their rights and responsibilities under the OSH Act of 1970. The guidance for this training will
be the OSH Act, OSHA regulations, other industry safety and health standards, and the nursing home’s
policies and procedures. The goal of this training is that employers and employees will understand
safety and health regulations and safe work practices and will work together to reduce or eliminate
workplace hazards. Nursing home operators are encouraged to involve employees in identification and
correction of safety and health concerns. Nursing home operators will assure that root causes of
injuries and illnesses are identified and corrective / preventative action is taken.
- Nursing home operator or his / her designee shall conduct semi-annual inspections / audits. These
inspections shall be documented to ensure that safety and health requirements are being followed at
the site. Each audit will address the hazardous conditions identified and the corrective action
taken / planned. Participating nursing homes will begin internal comprehensive audits within 6
months of signing the partnership agreement. The nursing home operator will submit the inspection
data to the LNHA and / or its designee for compilation. The LNHA will submit the tabulated data to
OSHA annually.
- Partner nursing home operators agree to promote effective employee involvement in day-to-day
implementation of the facility’s safety and health program. To this end, the nursing home operator
agrees to ensure employees participation during safety and health meetings, site inspections, and
other meaningful activities, which are not limited to hazard analysis and methods of abatement.
- Partner nursing home operators will provide OSHA 300 log annual summary data for 2003 and 2004
along with the employee hours worked for those years. In each subsequent year of the partnership
(Year 2005 and 2006), nursing home operators will submit OSHA 300 log annual summary data along with
the employee hours worked for those years to be used as a comparison to the baseline data.
- Nursing home operators who partner with OSHA may promote the agreement and status of the
partnership.
- Each partner nursing home will ensure that at least one employee attends OSHA and LDOL OSHA
Consultation outreach training program. The outreach training sessions will target industry specific
hazards and will provide information for the partners to use to create comprehensive safety and
health programs.
- Each Partnership nursing home should establish (if not already in place) a written lifting policy
/ program. The lifting policy / program should consider the elements listed below. A sample lifting
policy / program for nursing staff can be viewed in Appendix A of this partnership agreement.
- Statement of Purpose for creating / establishing lifting policy
- Lift, transfer and repositioning policy
- Identification of "high risk" residents for lifting / transfers
- Identification of "high risk" tasks and areas of facility
- Employee education / training sessions
- Employee evaluation programs
- Incident / accident review
- Annual program review / updates
- Any participant with employees represented by a collective bargaining unit will afford the
bargaining unit employees and their representative full and equal opportunity to participate in this
cooperative agreement. The employee-authorized representative should be included early in the
process and be kept appraised of conditions as they occur. A bargaining unit official shall be
offered the opportunity to participate in the signing ceremony when and where it occurs.
E. Inspection Scheduling / Targeting Strategy:
- For each year of the partnership, the OSHA’s Baton Rouge Area Office will conduct verification
inspections on a maximum of 5% of the participating nursing homes. These nursing home operators will
be randomly selected. All verification inspections conducted by OSHA will be focused. Focus
inspections shall concentrate on an evaluation of the employer’s safety and health program,
self-audits and employee training. Except as otherwise expressly or specifically allowed by
applicable law and / or regulations, verification inspections and employee interviews conducted in
this partnership shall be focused and shall be limited to the following hazards:
- Patient handling
- Slips / Trips / Falls
- Bloodborne Pathogens and TB
- Workplace Violence
- Partnering LNHA nursing home operators will not be subjected to programmed inspections where a
successful on-site verification inspection has been conducted and completed in the prior 12 months.
Federal OSHA may preclude those nursing home operators interested in and who qualify for the
Pre-SHARP (OSHA Consultation) from Program and Target inspections for a period of eighteen months.
- Verification inspections of the new participating nursing home operators will be delayed for a
period of 6 months from the date the nursing home operator enters into the partnership.
- Unprogrammed inspections conducted in response to referrals, accidents, and fatalities shall be
conducted without delay in accordance with established Agency procedures. Complaint inspections
shall be conducted without delay in accordance with established Agency procedures.
F. Partnership Incentives:
The OSHA Baton Rouge area office and LDOL OSHA Consultation will carry out various outreach
activities to promote comprehensive employer safety and health programs through cooperative
partnerships with nursing home operators. These activities may include the following:
- The Baton Rouge OSHA Area Office, the LDOL OSHA Consultation and / or other partnership entities
will conduct information and training sessions. These sessions will focus on interested nursing home
operators. The purpose of these sessions will be to discuss program specifications, obligations of
OSHA and partnership entities, partnership as a choice, benefits of an effective workplace safety
and health program, and OSHA regulatory requirements. Such information and training sessions shall
be held minimally once a year in each of the LNHA seven regions for the duration of the partnership.
OSHA and the LDOL shall work with LNHA to ensure continuing education credits are available through
the Board of Examiners for Nursing Facility Administrators.
- OSHA and LDOL OSHA Consultation shall enlist the support and help of various organizations such
as NIOSH, CDC and other safety / health related organizations to conduct and / or develop outreach /
training session materials and to promote awareness of and in this partnership.
- OSHA and LDOL OSHA Consultation shall compile an inventory of resources for use in the
development of safety and health programs for partnership participants. A CD-ROM containing sample
programs and related supportive materials will be provided to each facility upon their entrance into
the partnership. This shall include but is not limited to the following:
- Development of a comprehensive safety / health checklist to be used uniformly by all partners
nursing homes.
- To make available at no charge to partner members the use of training / educational materials
(i.e., safety videos, software programs, OSHA publications, OSHA training kits from the GPO, etc.).
- Outreach sessions on OSHA Safety topics in all seven of the LNHA Regions in 2005 and at least
annually thereafter.
- For this partnership OSHA shall provide safety / health resources (i.e., methods of
compliance, hazard control information) and technical assistance not only at the Baton Rouge area
office level (i.e., the compliance assistant specialist) but also from OSHA’s Regional and National
offices. This will be done to assist employers in the development and maintenance of effective
safety and health programs. This shall include a designated person at the Area level to assist
partner nursing homes with general safety / health issues and OSHA Recordkeeping questions.
- OSHA will seek support from nursing home operators known to have successful policies in safety
and health to share with the rest of the participants.
- OSHA will promote recognition for safety and health excellence throughout the industry at every
opportunity.
- Upon request by a LNHA partnership member, the initial inspection by the LDOL OSHA Consultation
shall be of a comprehensive nature. LDOL OSHA Consultation shall conduct annual consultation visits
for all nursing home operators for the duration of the partnership.
- LDOL OSHA Consultation shall provide information to assist the LNHA and partner nursing homes in
applying for all training and equipment (i.e., mechanical patient lifts) grants that are offered by
state and federal government agencies.
- OSHA and LDOL OSHA Consultation shall assign priority service to requests from partnership
members for onsite consultation visits and requests for information.
G. Disqualifications:
- If a partner nursing home is not operating in good faith and the program is deemed to be
ineffective during its operational time period, the partnership may be discontinued. In the event of
this determination, nursing home operators who have entered into this partnership with OSHA will be
formally notified. This determination is based on the presumption that the goals of the partnership
are not being met and the attempts among the parties to improve it and make it effective have
failed.
H. Evaluation of the Project:
This partnership will include an annual evaluation to review the status of this partnership and
determine whether modifications are needed. The evaluation will address the following:
- Number of nursing homes covered by the partnership.
- Number attending outreach activities.
- Incident / frequency rate of partner nursing homes will be compared to baseline (2001 and 2002)
data collected.
- Number of hazards identified and corrected on partner sites.
I. Termination:
Either party may terminate the partnership agreement and withdraw upon written notice. The
partnership agreements will terminate on January 31, 2007. If this partnership is considered
successful it may be renewed for two more years, from January 31, 2007 through January 31, 2009.
J. Recognition
At the conclusion of the partnership, nursing homes that participated in the partnership will
receive a certificate from the area office in recognition for their efforts towards safety and
health from OSHA and LDOL OSHA Consultation.
K. Information:
In the interest of accurate reporting, the parties of this partnership shall have an opportunity to
collaborate on and review statistics and reports produced as a result of this partnership and shall
agree on any press releases or public dissemination of information derived from the partnership
before said dissemination.
Appendix A
SAMPLE Safe Resident Handling and Movement Policy |
1. PURPOSE: This policy describes ways to ensure that employees use safe resident handling and
movement techniques are used at __________________________ nursing facility. Particularly for those
residents designated as high-risk for safe resident handling and movement.
2. POLICY: ___________________________________ Nursing Facility wants to ensure that its residents
are cared for safely, while maintaining a safe work environment for employees. To accomplish this a
Back Injury Prevention Program for Nurses and Nurse Aides will be implemented in order to ensure
required infrastructure is in place to comply with components of this safe resident handling and
movement policy. This infrastructure includes resident handling and movement equipment, employee
training, and a "Culture of Safety" approach to safety in the work environment. Direct resident care
staff on high-risk resident care areas should assess high-risk resident handling tasks in advance to
determine the safest way to accomplish them. Additionally, mechanical lifting equipment and / or
other approved resident handling aids should be used where available to prevent manual lifting and
handling of residents except when absolutely necessary, such as in a medical emergency.
3. PROCEDURES:
- Compliance: It is the duty of employees to take reasonable care of their own health and safety,
as well as that of their co-workers and their residents during resident handling activities by
following this policy. Non-compliance will indicate a need for retraining.
- Safe Resident Handling and Movement Requirements:
- Avoid hazardous resident handling and movement tasks whenever possible. If unavoidable, assess
them carefully prior to completion.
- Use mechanical lifting devices and other approved resident handling aids for high-risk resident
handling and movement tasks except when absolutely necessary, such as in a medical emergency.
- Use mechanical lifting devices and other approved resident handling aids in accordance with
instructions and training.
- Training:
- Management will complete and document Safe Resident Handling and Movement training initially
(orientation), annually and as required to correct improper use/understanding of safe resident
handling and movement. Supervisors should maintain training records for three (3) years.
- Mechanical Lifting Devices and Other Equipment/Aids:
- Mechanical lifting devices and other equipment / aids will be accessible to staff.
- Mechanical lifting devices and other equipment / aids will be maintained regularly and kept in
proper working order.
- Mechanical lifting devices and other equipment / aids shall be stored conveniently and safely.
- Back Injury Prevention Program:
The Back Injury Prevention Program for Nurses / Nurse Aides will be implemented for all high-risk
residents, including the following key program elements:
- Workplace lifting safety assessments
- Use of lifting equipment and devices
- Resident Assessment Criteria and Care Planning for Safe Resident Handling and Movement
- Flow charts / diagrams for Safe Resident Handling and Movement
- Back Injury Resource Nurses
- After Action Review Process
- Reporting of Injuries / Incidents:
- Nursing staff shall report all incidents/injuries resulting from resident handling and movement
to Occupational Health
- Supervisors shall maintain Accident Reports and supplemental injury statistics as required by the
facility.
4. DEFINITIONS:
- High-Risk Resident Handling Tasks: Resident-handling tasks that have a high-risk of
musculoskeletal injury for staff performing the tasks. These include but are not limited to
transferring tasks, lifting tasks, repositioning tasks, bathing residents in bed, making occupied
beds, dressing residents, turning residents in bed, and tasks with long duration.
- High-Risk Resident Care Areas: Resident wings with a high proportion of dependent residents,
requiring full assistance with resident handling tasks and activities of daily living. Designation
is based on the dependency level of residents and the frequency with which residents are encouraged
to be out of bed. These areas include Spinal Cord Injury Units, Nursing Home Care Units and other
specified areas.
- Manual Lifting: Lifting, transferring, repositioning, and moving residents using a caregiver’s
body strength without the use of lifting equipment / aids to reduce forces on the caregiver’s
musculoskeletal structure.
- Mechanical Resident Lifting Equipment: Equipment used to lift, transfer, reposition, and move
residents. Examples include full body sling lifts, stand assist lifts, and mechanized lateral
transfer aids.
- Resident Handling Aids: Equipment used to assist in the lift or transfer process. Examples
include gait belts with handles, stand assist aids, sliding boards, and surface friction-reducing
devices.
- Culture of Safety: Describes the collective attitude of employees taking shared responsibility
for safety in a work environment and by doing so, providing a safe environment of care for
themselves as well as residents.
5. DELEGATION OF AUTHORITY AND RESPONSIBILITY:
- Facility Administrator shall:
- Support the implementation of this policy.
- Support a "Culture of Safety" within this medical center.
- Furnish sufficient lifting equipment/aids to allow staff to use them when needed for a safe
resident handling and movement.
- Furnish acceptable storage locations for lifting equipment / aids.
- Provide routine maintenance of equipment.
- Provide staffing levels sufficient to comply with this policy.
- Supervisors shall:
- Ensure high-risk resident handling tasks are assessed prior to completion and are completed
safely, using mechanical lifting devices and other approved resident handling aids and appropriate
techniques.
- Ensure mechanical lifting devices and other equipment/aids are available, maintained regularly,
in proper working order, and stored conveniently and safely.
- Ensure employees complete initial and annual training, and training as required if employees show
non-compliance with safe resident handling and movement or equipment use. Maintain training records
for a period of three (3) years.
- Refer all staff reporting injuries due to resident handling tasks Director of Nurses
- Maintain Accident Reports and supplemental injury statistics as required by the facility.
- Support a "Culture of Safety" within the facility.
- Employees shall:
- Comply with all parameters of this policy.
- Use proper techniques, mechanical lifting devices and other approved equipment / aids during
performance of high-risk resident handling tasks.
- Notify supervisor of any injury sustained while performing resident handling tasks.
- Notify supervisor of need for re-training in use of mechanical lifting devices, other equipment /
aids and lifting / moving techniques.
- Notify supervisor of mechanical lifting devices in need of repair.
- Support a "Culture of Safety" within their facility.
- Engineering / Maintenance Services shall maintain mechanical lifting devices in proper working order.
- Where applicable, Union officials shall support policy intent and monitor program effectiveness
in partnership with Administration.
 |
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Partnership Charter
Between the
United States Department of Labor
Occupational Safety and Health Administration
Region VI, Baton Rouge Area Office
the
Louisiana Department of Labor OSHA Consultation
and the
Louisiana Nursing Home Association |
The United States Department of Labor Occupational Safety and Health Administration, the Louisiana
Department of Labor OSHA Consultation and the Louisiana Nursing Home Association mutually recognize
the importance of providing a safe and healthful work environment for Louisiana’s nursing home
employees. To advance our mutual goal, we strongly agree on the need to develop a working
relationship that fosters mutual trust and respect for each organization’s respective role in this
process. We recognize and embrace the responsibilities inherent in those roles. We are committed to
work as partners to achieve nursing home workplace safety and health through the following shared
strategies and objectives.
- Implement continuing and open communication policy between OSHA and the Louisiana Nursing Home
Association in a manner that encourages respect and understanding.
- Share knowledge of the best industry technology, innovations, and work practices that improve
jobsite safety and health performance.
- Cooperate in the development and continuous improvement of safety and health training programs
for the nursing home industry and OSHA personnel.
- Improve safety and health programs by involving employees in every aspect of the site inspection
process.
- Promote principles of good faith and fairness as the foundation of our relationships.
- Recognize that either party to the partnership may withdraw from the agreement at any time after
submitting written notification of intent to the other partner.
Agreed this day, _________________________, 2005
Greg Honaker
Area Director
U.S. Dept. of Labor/OSHA
Baton Rouge Area Office |
Joseph A. Donchess
Executive Director
Louisiana Nursing Home Association |
Karen Reiners Winfrey
Assistant Secretary/Director
Office of Workers’ Compensation
Louisiana Department of Labor |
Ray Naquin
Treasurer
Louisiana Nursing Home Association |
Willis Callihan
Safety and Health Director
Office of Workers’ Compensation
Louisiana Department of Labor |
|
Clovis Mills
OSHA Consultation Manager
Louisiana Department of Labor |
|
|
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