Understanding Healthcare Security and OSHA’s Role

This advice will help you not only abide by the letter of the rule, but also its spirit.

2 More Directives You Need to Know About

There have been several other recent developments concerning OSHA and workplace violence, two of the more relevant being the Sept. 8, 2011, release of OSHA Directive CPL 02-01-052, “Enforcement Procedures for Investigating or Inspecting Workplace Violence Incidents” (https://www.osha.gov/OshDoc/Directive_pdf/CPL_02-01-052.pdf) and the April 5, 2012, OSHA Directive CPL 03-00-016 “National Emphasis Program – Nursing and Residential Care Facilities“.

In the former, OSHA provides very detailed instructions on how their field offices and inspectors are to assess and interpret organizational procedures and existing security countermeasures as related to the prevention of workplace violence events and threats to staff. It highlights the steps that should be taken when a review of such incidents takes place. Additionally, it clearly defines workplace violence and classifies it into one of four common types (see “4 Common Types of Workplace Violence“).

OSHA also identifies what it considers to be high-risk industries for workplace violence. The No. 1 industry is that of healthcare and social service, followed by late-night retail settings. Workplace violence inspection scheduling and criteria are discussed in depth, and clear, real-life examples are given to demonstrate how this type of event should be assessed.

This guide also includes a number of important appendices, such as additional resources regarding workplace violence prevention information. It also includes lists of
potential abatement methods that employers should consider to mitigate or reduce the impact of workplace violence and lists of scientific studies of such abatement methods and their details for research opportunities.

Workplace Violence Is Now a Recognized Hazard

The second OSHA Directive, focusing on nursing and residential care facilities, does not have nearly the amount of detailed information as the previous one, but it does clearly state that “Workplace violence (WPV) is a recognized hazard in nursing and residential care facilities. NIOSH defines workplace violence as violent acts (including physical assaults and threats of assaults) directed toward persons at work or on duty.”

[10, CDC] Enforcement Procedures for Investigating or Inspecting Workplace Violence Incidents, CPL 02-01-052, establishes agency enforcement policies and provides uniform procedures that apply when conducting inspections in response to incidents of workplace violence.

OSHA Instruction, CPL 02-01-052,22 directs CSHOs who conduct programmed inspections at worksites that are in industries with high incidence of workplace violence, such as health and residential care facilities, to investigate for the potential or existence of this hazard. The relevance of this simple paragraph is significant, because as it’s now an officially recognized hazard, organizations have an even greater identified duty to act to prevent workplace violence incidents from occurring, lest they be found negligent of the General Duty Clause.

This directive has taken a momentous stride in defining what is a hazard, where it is commonly encountered and what steps should be taken to mitigate such events. By connecting the Directive on Workplace Violence to the General Duty Clause, this seemingly innocuous document has done much to bridge the gap between the letter of the rule and the spirit in which it was originally written.

Clearer Directions Help Healthcare Protection Professionals

OSHA has many standards that deal with the healthcare industry, including those on personal protective equipment, exposure to hazardous materials (such as chemicals and blood borne pathogens) and respiratory protection to name a few. The advantage that most of these have is the clarity in which they can be interpreted by safety professionals and the techniques and resources required to enforce them.  It is only recently, however, that such clarity has become available to the healthcare security profession and the everyday struggles that we have with workplace violence and its aftermath.

Perhaps with this better understanding and clearer direction from OSHA we can all be better equipped to prevent the issues rather than suffer the consequences of both an incident as well as the regulatory penalties afterwards. For us, providing a safe environment for our patients, visitors and fellow healthcare professionals should be a passion and not a penance.

Bryan Warren CHPA, CPO-I is the director of Carolinas HealthCare System corporate security and past IAHSS (Int’l Association for Healthcare Security & Safety) president.

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