OSHA Compliance: Priorities and Challenges

Successful OSHA compliance requires understanding enforcement priorities and delivering training that meets facilities’ needs.

By Dan Hounsell, Senior Editor
May 24, 2023

The Occupational Safety and Health Administration (OSHA) has historically kept a low profile in most hospitals and other healthcare facilities. Most healthcare workers have never been through an inspection conducted by an OSHA official. 

But with the large number of worker injuries in healthcare facilities and numerous high-profile incidents of workplace violence involving healthcare workers, it seems likely that OSHA compliance officials will take a closer look at the role that the agency is playing in safeguarding front-line healthcare workers and technicians responsible for maintenance and engineering activities in these facilities. 

OSHA’s role 

Given the number of federal agencies and accrediting organizations involved in healthcare, it is understandable that facility managers might have questions about OSHA’s role. 

"The Joint Commission requirements for accreditation are based on the Centers for Medicare and Medicaid Services, or CMS, conditions of participation,” says Scott Cormier, vice president of emergency management, environment of care and safety with Medxcel. “Those include OSHA requirements, as well as requirements from other organizations, such as the National Fire Protection Association. They really work hand in hand. 

“The difference you'll see is the attention to detail that OSHA will give on an OSHA survey for their requirements versus the Joint Commission or other accrediting organizations. They're looking at a whole lot of standards, such as critical care and record keeping and training.” 

At what point does OSHA tend to enter the picture for facility managers? 

"They tend to get involved either when there is some type of complaint or issue that has been escalated to OSHA,” says Kathy Tolomeo, director of compliance strategies for the healthcare solutions division of JLL. “Even though they can come to healthcare entities, it usually takes something to trigger OSHA to come to an organization. 

“The challenge that we also see is that we have so many different authorities having jurisdiction, and then you also bring in the accrediting organizations like Joint Commission and DNV. They are not authorities having jurisdiction. They have been hired by the Centers for Medicare and Medicaid. But the challenge that they bring in is that they can survey to pretty much all regulatory codes, guidelines, etc., that impact healthcare." 

Among the toughest challenges for healthcare facilities managers is knowing which agency or organization to pay closest attention to. 

"We have to stick with the more stringent requirements in order to satisfy all of our authorities having jurisdiction,” Tolomeo says. “Never forget to look at the local and state regulations to see if they're more stringent than those federal regulations. Again, you need to comply with the most stringent regulation and the most stringent interpretation. 

Understanding priorities 

For healthcare facilities managers familiar with the annual list of the top 10 most frequently cited OSHA standards in all types of facilities, the list of the most frequently cited OSHA standards in healthcare will not be surprising. It includes respiratory protection, hazard communication, lockout/tagout and hazardous chemicals safety management. 

While the temptation for managers might be to focus on specific OSHA standards, Tolomeo advises managers to take a more systematic approach. 

"In looking at the top 10, what it came down to with an OSHA-type focus is taking a look at what their educational training program is,” Tolomeo says. “Have they standardized it as an organization? Once you have that standardized training program to ensure compliance with the OSHA regulations, those should also assist organizations in being ready as a healthcare facility not only for OSHA but also for Joint Commission.” 

One rising priority for OSHA is workplace violence that has become all too commonplace in healthcare facilities. 

"Workplace violence in healthcare is a major focus with OSHA,” Cormier says. “As a matter of fact, the Department of Labor is looking at promulgating regulations specific to healthcare workplace violence. This is something they did back in 2015, and with the changes in administrations, that never went forward. With this new administration, they are now looking at it.” 

Challenges for managers 

OSHA compliance is a high priority for healthcare facilities managers, given its impact on facility operations and conditions, as well as the safety of patients and staff. But for many managers, the responsibility is just one of many competing priorities. 

"The biggest challenge facility managers are facing is that these duties -- OSHA and safe workplace violence, emergency management -- are add-on or additional duties that are put on their task lists along with managing the facility, which by itself is a full-time job,” Cormier says. “The pattern we've looked at in healthcare is that the facility manager is that key person to do these other duties as assigned.” 

Complicating the OSHA compliance challenge is the fact that managers must coordinate their efforts with a range of other involved parties in their organizations. 

"Not only are they responsible for their own area, but because it falls under the physical environment, sometimes those categories expand,” Tolomeo says. “Hazardous materials and waste may also either fall under a facilities manager or may fall under the responsibility of EDS manager or director. 

“In those cases, CMS and accrediting organizations like the Joint Commission are starting to provide standards or conditions of participation that require that the organization provide sufficient education for those individuals who are responsible for it. The question is, are they really getting the right level of training that they need to be able to be able to manage those?” 

While managers need training in OSHA compliance, they also must complete the compliance chain by ensuring front-line technicians and other workers also receive training on key areas of safety compliance. 

"One of the gaps that they have is whenever they create a program of policy or process, getting that down to that local worker, getting the training, doing the follow-up, is one of the hardest things to do,” Cormier says. “You can create a policy for that, but OSHA is not going to just look for the policy. They're going to ask if all of your employees know what to do during an active shooter. Do you conduct training? After you've conducted training, have you done exercises? Have you done an after-action report to see that what you wrote is actually doable? What are you doing to onboard people? How often are you doing training?” 

Dan Hounsell is senior editor of the facilities market. He has more than 30 years of experience writing about facilities maintenance, engineering and management. 

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