OSHA has announced a National Emphasis Program (NEP) to encourage compliance with safety and health standards at nursing and residential care facilities through programmed inspections. The NEP is in effect until April 5, 2015.
All nursing and residential care facilities in NAICS codes 623110, 623210, and 623311 (formerly SIC codes 8051- Residential Care Facilities, 8052-Intermediate Care Facilities, and 8059-Nursing and Residential Care Facilities, Not Elsewhere Classified) with a DART rate of over 10.0 may be targeted under the NEP. The program will not focus on residential mental health and substance abuse facilities or assisted living facilities without on-site nursing care operations. All State-plan states must adopt the NEP or an equivalent program.
The NEP provides detailed guidance to compliance officers on conducting OSHA inspections under the program. In general, compliance officers are directed to focus on the following areas: ergonomics; slips, trips, and falls; bloodborne pathogens; tuberculosis; and workplace violence. Other issues such as methicillin-resistant staphylococcus aureus (MRSA) and Hazard Communication also may be examined.
Nursing and residential care employers should ensure they are in compliance with applicable OSHA standards and that their facilities are prepared for an inspection. Employers should:
- Review the NEP thoroughly to understand what OSHA will examine during an inspection.
- Calculate their DART rates (days away, restricted work activity, and job transfer) to determine if they may be on the NEP targeted inspection list.
- Review company policies and procedures addressing ergonomics and bloodborne pathogens, and other subjects identified in the NEP.
- Communicate to facilities about the NEP and its contents. Ensure each facility’s written plans and programs (bloodborne pathogens and hazard communication, especially) are complete, up-to-date, accessible and being followed.
- Ensure each facility has documented the steps taken to address musculoskeletal disorders (MSDs) in the workplace and has identified a person who understands these measures and can explain them to an OSHA compliance officer.
- Develop a protocol for facilities to follow if an OSHA inspector arrives unannounced; train managers and supervisors, and receptionists on that protocol.