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HealthcareNovember 18, 2021
OSHA Increases Inspections in Healthcare Facilities: How to Ensure Your Facility Meets the Standard
The U.S. Occupational Safety and Health Administration (OSHA) has recently announced plans for onsite inspections at healthcare facilities by implementing the Healthcare COVID-19 Emergency Temporary Standard (ETS).
A recent article in Healthcare Facilities Today details the standard and what it means for the healthcare industry. This standard was filed in June 2021 to help mitigate the spread of COVID-19 among high-risk environments, and requires healthcare employers to follow specific safety and infection prevention requirements. From July 6 onward, all types of healthcare facilities have been subject to OSHA enforcement if they are not compliant with ETS requirements. The ETS applies to the following areas, especially where suspected or confirmed COVID-19 patients are treated:
- -Healthcare services and hospitals
- -Healthcare support services
- -Assisted living facilities, long-term care, and nursing homes
- -Emergency responders
- -Home healthcare workers
- -Ambulatory care settings
The standard addresses policies and procedures, personal protective equipment (PPE), and administrative controls to reduce the risk of infection. In order to meet OSHA’s requirements, healthcare organizations must ensure their facilities are in compliance. This blog post will explore three ways to ensure standards are met.
- Ensure a Written Plan is in Place
One key element of maintaining compliance is ensuring there is a written plan in place. The health and safety policies and procedures required in a written plan include the following: performance of a formal hazard assessment, development of a written COVID-19 prevention plan, PPE requirements, masking and social distancing, cleaning and disinfection procedures (e.g. implementing proper disinfection against the virus with an EPA-registered disinfectant solution like the Halo Disinfection System®), and training on COVID-19 prevention. The plan should also detail adequate building ventilation, daily screenings, vaccination and paid leave, anti-retaliation policies, recordkeeping, COVID-19 fatality and hospitalization reporting, and preparing for enforcement.
- Perform Internal Audits
Healthcare employers should perform internal audits of their current processes and programs to determine if they comply with the ETS. While many organizations have likely already have implemented general COVID-19 prevention policies, the ETS requires a more thorough and specific adherence, so internal audits are thus necessary. Some examples of additional protocols for the ETS include the mini respiratory protection program (which improves worker protections with limited provisions for the safe use of respirators that can be implemented quicker and easier than the more comprehensive respiratory protection program), paid leave requirements, additional training, more thorough recordkeeping, and reporting obligations.
- Require Vaccinations and or Weekly Testing
The White House has recently announced additional requested updates to the ETS that will affect healthcare facilities. The Centers for Medicare & Medicaid Services will be required to mandate vaccinations or weekly testing for healthcare workers, service providers, and volunteers in healthcare settings that receive Medicare or Medicaid reimbursement. Employers must only support COVID-19 vaccinations for employees by providing time and paid leave for vaccinations and their potential side effects.
What Enforcement Will Look Like
OSHA’s Inspection Procedures for the COVID-19 ETS outlines enforcement actions and details how compliance safety and health officers will perform COVID-19 related inspections and issue citations. Inspections will focus on protections in place for unvaccinated or not fully vaccinated workers, as it’s recommended to implement multiple layers of controls to limit exposure.
Inspections will begin with a program and document review. Inspectors will require access to the written plan to determine if a workplace hazard assessment has been performed, and to ensure the right policies and procedures are in place to minimize risk. Inspectors will interview the COVID-19 safety coordinator to evaluate their participation in implementing, monitoring, and reporting on the plan. Finally, the inspectors will walk through the facility to assess areas like health screening, distancing, ventilation, PPE use, and more.
Citations may be issued if a facility doesn’t have a COVID-19 plan in place and if other standard requirements have not been met. To support OSHA enforcement, the White House included in its $3.5 trillion reconciliation bill a proposed increase in fines ($70,000 for serious infractions and $700,000 for willful or repeated violations) to employers that violate a section of the labor law dealing with hazards, death, or serious physical harm to employees.
Ensuring Compliance and Safety with a Proven Disinfection Solution
In order to ensure continued compliance with the ETS, facility managers must pay diligent attention to health and safety protocols. And it’s crucial that effective disinfectant processes take place regularly to ensure environments are clear of dangerous pathogens like SARS-CoV-2.
Halosil’s proven HaloMist™ (EPA Reg. No. 84526-6) solution is trusted by healthcare facilities across the US as an EPA List N disinfectant approved for use against SARS-CoV-2, and also as an EPA List K disinfectant for C. diff, with a 99.9999% reliability of killing C. diff spores in the clinical environment. The Halo Disinfection System® offers highest possible effectiveness of hospital disinfectants on the market today. Contact Halosil today to learn more.