The Occupational Safety and Health Administration’s new instructions to inspectors includes the following section on musculoskeletal disorders (MSDs).
Ergonomics: MSD Risk Factors Relating to Patient/Resident Handling
This section provides guidance for conducting inspections in workplaces in NAICS Codes 622 and 623 as they relate to risk factors for MSDs associated with patient/resident handling. These inspections shall be conducted in accordance with the Field Operations Manual and other relevant OSHA reference documents.
Establishment Evaluation. Inspections of MSD risk factors will begin with an initial determination of the extent of patient/resident handling hazards and the manner in which they are or are not addressed. This will be accomplished by an assessment of establishment incidence and severity rates and whether the establishment has implemented a process to address these hazards in an effective [program].
Certified Safety and Health Officials (CSHOs) should ask for the maximum census of patients/residents permitted and the current census during the inspection. Additionally, CSHOs should inquire about the degree of ambulation of the patients/residents, as this information may provide some indication of the level of assistance given to patients/residents or the degree of hazards that may be present.
Note: If there is indication from injury records, or from employer or employee interviews that other sources of ergonomics-related injuries exist (e.g., MSDs related to office work, laundry, kitchen, or maintenance duties), the compliance officer must include the identified work area and affected employees in the assessment.
Program Evaluation. Compliance officers should evaluate program elements, such as the following:
Program Management:
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Is there a system for hazard identification and analysis?
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Is there a system for development of strategies to address identified hazards?
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Who has the responsibility and authority for administering this system?
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What are the credentials or experience of the individual responsible for administering the program?
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What input have employees provided in the development of the establishment’s lifting, transferring, or repositioning procedures?
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Is there a system for monitoring compliance with the establishment’s policies and procedures and following up on deficiencies?
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Are there records of recent changes in policies/procedures and an evaluation of the effect they have had (positive or negative) on resident handling injuries and illnesses?
Program Implementation:
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How is patient/resident mobility determined and how is the mobility determination communicated to staff?
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What is the decision logic for selection and use of lift, transfer, or repositioning devices?
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When and under what circumstances may manual lift, transfer, or repositioning occur?
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Who decides how to lift, transfer, or reposition patients/residents.
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Is there is an adequate quantity and variety of appropriate lift, transfer, or reposition assistive devices available and operational? Note that no single lift assist device is appropriate in all circumstances. Manual pump or crank devices may create additional hazards.
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Are there adequate numbers of supplies such as: slings, batteries, and charging stations for lifting devices? (Note: There should be a minimum of 1 sling per resident that needs the device and some extras to account for laundering and repair. There should be adequate numbers of batteries to accomplish all necessary lifts during a shift). There should be appropriate types and sizes of slings specific for all patients/residents.
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Are there appropriate quantities and types of the assistive devices (such as, but not limited to slip sheets, mechanical lifts, sit-to-stand assists, walk assists, or air-hover transfer pads) available within close proximity and maintained in a usable and sanitary condition?
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Are their policies and procedures appropriate to eliminate or reduce exposure to the manual lifting, transferring, or repositioning hazards at the establishment?
Employee Training:
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Have employees (nursing and therapy) been trained in the recognition of ergonomic hazards associated with manual patient/resident lifting, transferring, or repositioning, the early reporting of injuries, and the establishment’s process for abating those hazards.
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Have the employees (nursing and therapy) been trained in proper techniques and procedures to avoid exposure to ergonomic risk factors and can they demonstrate competency in performing the lift, transfer, or repositioning task using the assistive device.
