By Nick Hulse, Associate, Fisher Phillips and Kevin Troutman, Partner, Fisher Phillips
In a recent news release, the Department of Labor (“DOL”) urged healthcare facilities to employ effective safety and health programs to protect those who protect us. According to the DOL’s release, U.S. healthcare workers experienced a 249 percent increase in injury and illness rates in 2020. Identifying the safety risks that healthcare workers are routinely exposed to and addressing them is crucial to reducing those rates.
Repurpose Your COVID-19 Prevention Plan
While OSHA’s emergency temporary standard covering the healthcare industry expired in December, employers in the healthcare industry should not scrap the COVID-19 prevention plan that the ETS required. Employers spent considerable time developing and implementing the required COVID-19 prevention plan, and they should not let that work go to waste.
While some components of the COVID-19 prevention plan may not translate post-COVID-19, many components of the plan can be repurposed. Generally, the COVID-19 prevention plan can be repurposed into a general infectious disease plan that can be quickly implemented in the event of an infectious disease outbreak. Further, the plan can be implemented during certain parts of the year, for example, during influenza season each year.
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Continue to Conduct Periodic Hazard Assessments
The ETS also required employers to conduct a workplace-specific hazard assessment to identify hazards that may exist due to COVID-19. This hazard assessment process is important outside of COVID-19. Employers should take what they learned from conducting the workplace-specific hazard assessment and continue conducting hazard assessments periodically. Hazard assessments are a crucial tool in identifying the hazards that employees are exposed to. These hazard assessments should be documented.
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However, it is not enough to simply identify hazards. Any recognized hazards should be appropriately addressed. Hazards that may need to be addressed include exposures to bloodborne pathogens, drug residue, respiratory illness, and ergonomic injuries. Hazards can be addressed through the use of personal protective equipment (“PPE”), administrative controls, engineering controls, and safe work practices. Employees must be trained on any new PPE, policies, or procedures implemented to address identified hazards.
Implement a Comprehensive Injury and Illness Prevention Program
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COVID-19 placed employee safety at the forefront of many organizations. As we move past the COVID-19 pandemic, employers should not allow this focus on employee safety to fall to the wayside. The most effective method of ensuring that employee safety is properly addressed is to implement a comprehensive injury and illness prevention program. The injury and illness prevention program should also be reviewed periodically to ensure that it continues to address recognized hazards.
An injury and illness prevention program can be effective at reducing injuries, illnesses, and fatalities. Adopting an injury and illness prevention program will also improve compliance with existing regulations.
A strong injury and illness prevention program will involve management leadership and active employee participation. Allowing employees to participate in the implementation of the injury and illness prevention program ensures that all hazards are identified and addressed. Many times, employees are much more equipped to identify hazards that they are exposed to, and they bring an important perspective to developing and implementing the program.
An effective injury and illness prevention program should contain the following elements:
- A person with authority and responsibility for implementing the program.
- A system for ensuring employees comply with safe and healthy work practices.
- A system for communicating with employees in a form readily understandable by all affected.
- Procedures for identifying and evaluating workplace hazards.
- Procedures to investigate occupational injury or illness.
- Procedures for correcting unsafe or unhealthy conditions, work practices, and procedures.
- Provide employee training and instruction.
- Recordkeeping and documentation.
Safety Communications
The stresses of dealing with the challenges of COVID-19 likely impacted the lines of communication between management and employees. As we begin to move past the COVID-19 pandemic, employers should focus on re-establishing these lines of communication. Safety communications should be in a form readily understandable by all employees and should be a two-way system of communication that encourages employees to identify hazards in the workplace.
Consider scheduling employee meetings at which safety is freely and openly discussed. These meetings can increase employee morale by giving them a seat at the table and addressing their concerns. These meetings can also serve as another opportunity to identify workplace hazards.
Train and/or Re-Train Employees
It is no secret that healthcare workers were stretched thin throughout the COVID-19 pandemic, and in many areas, they continue to be. Due to this, training and retraining employees on safety issues not related to COVID-19 were less prevalent. While employees may have been trained on the ever-changing COVID-19 rules and regulations, they may not have received as much training on blood-borne pathogens, for example.
Training employees is one of the most important elements of any safety program because it allows employees to learn their job properly, reinforces workplace safety rules, and is crucial for implementing safety programs. A well-developed and documented safety program are useless if employees are not trained on the requirements of the program and the employees’ responsibility in implementing the program. Employers should refocus on training employees on their workplace safety rules, required PPE, and their safety program.
Concluding Thoughts
The COVID-19 pandemic brought employee safety to the forefront. Employees found empowerment through social media that allowed them to pressure employers to address safety concerns. Further, OSHA specifically targeted the healthcare industry with specific safety requirements. The COVID-19 pandemic can be a springboard for ensuring the ongoing safety of healthcare workers. Many healthcare employers focused on identifying COVID-19 related hazards and correcting them. These employers should bring this same energy to identifying and addressing other safety concerns as we move past the COVID-19 pandemic.
Healthcare workers are rightfully lauded for their heroism throughout the COVID-19 pandemic. There is no better way to thank these workers for their work than to ensure that they remain safe from workplace hazards. Employers should implement a comprehensive injury and illness prevention program and utilize hazard assessments to identify and address recognized hazards. Preventing exposure to these recognized hazards is an important step in moving past COVID-19.