WHCA RETRO | April 2021 News

National Emphasis Program on Worker Safety – Is your Facility Ready?

Effective March 12, 2021, the Occupational Safety and Health Administration (OSHA) announced a national program to focus on enforcement efforts related to COVID-19 hazardous conditions and has targeted the long-term care sector under this directive. This directive provides OSHA with the authority to walk into a facility and perform an inspection, solely on the basis of the program emphasis. Facilities should be prepared for an inspection from Labor and Industries and should take some time to review their current COVID-19 protocols, as they relate to worker safety. WHCA and ERNWest have received numerous reports from facilities around the state who are finding themselves subject to these inspections. Below are some of the questions and materials that were requested during recent inspection.

1. Respiratory Protection Program. A written copy of your program must be provided. EVERY facility should have this document in place, along with a system for fit testing. If you have employees in your facility that interact with any COVID-positive residents, they MUST be protected with a tight-fitting (N95) type respirator. Make sure you’ve done everything possible to source appropriate PPE and have a fit testing kit on hand. Make sure to document these efforts and show inspectors proof if you’ve had difficulty obtaining these supplies in the past.
2. Fit testing documentation and medical evaluation forms. For facilities that performed these procedures in-house, make sure you have the correct documentation. Medical evaluation forms should be filled out and signed by a licensed healthcare provider or registered nurse whose scope of practice allows for this type of evaluation. Inspectors may question the RN on their knowledge of respiratory hazards. Make sure your RN has the proper qualifications to perform the medical evaluation.
3. OSHA 300 logs for 2020 & 2021. Inspectors will access your OSHA 300 logs and will ask you for instances of infected staff and residents. If you fail to record a case as “work related,” you should expect to have these logs scrutinized. The OSHA website has guidance on how to determine if a work-related exposure contributed to a positive COVID-19 case.
4. Program review. What does your written COVID-19 plan look like, and how do you plan to protect your workers in the event of an outbreak? What is your plan for distributing PPE to affected workers?
5. Use of airborne isolation areas. Have you created a space for COVID-positive residents to be housed outside of the general facility areas? What does your isolation area look like? Employees should be trained and be familiar with these protocols.
6. Employee roster, to include names, title, shift worked, personal phone number and emails for the purpose of conducting employee interviews. Make sure to document when employees tested positive and/or showed COVID symptoms.
7. Job description for caregivers.
8. Picture of N95 masks used. What are the brand and model numbers?
9. Decontamination procedure for re-use of N95 masks.
10. Type of hand sanitizer used in your facility.

To help answer any questions, ERNwest will be providing two free webinars, presented by Shamus Harmon of ERNWest. Shamus will lead you through the OSHA inspection process and basic requirements of the respiratory protection program. In addition, you can reach out to Darrell Beaman, Safety and Loss Control manager, with specific questions dbeaman@ernwest.com.

Respiratory Protection Inspections | Tuesday April 6, 11am
With the new National Emphasis Program from OSHA on COVID-19, and the results of recent DOSH inspections in long term care, it is as important as ever to be prepared for a DOSH inspection. This webinar will discuss how to prepare for the respiratory protection elements of a DOSH inspection.

Expect the Unexpected: DOSH Compliance and Inspections | Tuesday, April 22, 10am
Preparing for a DOSH compliance inspection can be overwhelming. This webinar will equip you by providing reasons for a DOSH visit, components of the inspection process, documents an inspector may request, and ways to best prepare you and your staff for a compliance inspection.