osha

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 [Master name: Solid Color Background]




          OSHA Recordkeeping National Emphasis
                       Program
Steve Ohman, Manager
Spectrum Health Occupational & Employee Health Services
616-391-7741
Stephen.ohman@spectrum-health.org

January 25, 2011
Employer Advisory Council




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[Master: Solid Color Background]




History & Background – Spectrum Health
Who We Are
     We are the largest employer in West Michigan with 16,000
     staff members, 1,500 physicians, and 2,350 volunteers.
     Our service area covers a population of 9.5 million. In
     FY09, we had a net system revenue of $2.7 billion.


     We have three businesses: Priority Health, Spectrum
     Health Medical Group and Spectrum Health Hospital

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     Group.
History & Background – Spectrum Health
Priority Health
   Priority Health is a nationally recognized health benefits company
   that provides half a million Michigan residents with access to
   affordable and excellent health care. Priority Health has offices in
   Grand Rapids, Farmington Hills, Holland, Jackson, Kalamazoo,
   Saginaw and Traverse City.
Spectrum Health Medical Group
  We established the Spectrum Health Medical Group to recognize the
  critical role physicians play as an equal partner with our hospitals and
  health plan. It was established to bring together our employed
  physicians into one group, in the form of a not-for-profit corporation.
  The group is supported by a common vision, infrastructure, systems
  and processes.
 History & Background – Spectrum Health

Spectrum Health Hospital Group
  The Spectrum Health Hospital Group reflects the full range
  of health care services provided in our inpatient, outpatient
  and continuing care settings. It includes all of our hospitals,
  outpatient facilities, and continuing care and long-term care
  facilities within a geographically designated 13-county
  referral area.

  In FY09, Spectrum Health Hospital Group had 60,500 acute
  admissions and served hundreds of thousands of patients
  at its more than 140 service sites.
History & Background – Spectrum Health
Hospitals
Spectrum Health Blodgett Hospital, East Grand Rapids
Spectrum Health Kelsey Hospital, Lakeview
Spectrum Health Medical Center, Grand Rapids
■ Butterworth Hospital
■ Fred and Lena Meijer Heart Center
■ Helen DeVos Children’s Hospital
■ Lemmen-Holton Cancer Pavilion

Spectrum Health Reed City Hospital, Reed City
Spectrum Health Special Care Hospital, Grand Rapids
Spectrum Health United Hospital, Greenville
History & Background – Spectrum Health
Outpatient Care
Ambulatory Surgery Centers Laboratory Occupational Health Radiology Rehabilitation
Sleep Disorders Urgent Care
Continuing Care
   With 600 beds and 1,200 patients a day, Spectrum Health Continuing Care is the largest
   provider of integrated post-acute care in West Michigan. It includes:
Spectrum Health Hospice
Spectrum Health Infusion Pharmacy Services
Spectrum Health Neuro Rehabilitation Services
Spectrum Health Rehab & Nursing Centers
Spectrum Health Special Care Hospital
Spectrum Health Visiting Nurse Association
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OSHA’s New Enforcement Emphasis

Recordkeeping National Emphasis Program (NEP)
•Launched    10/09 to “assess” accuracy of injury recordkeeping
•Obama     admin increased OSHA’s size and enforcement actions
•1   year later – 200 inspections launched with 70% violations found
•Targeted   industries: Mfg; Large worksites & high injury rates
•$100,000+    fines tripled in last year
•Overall   emphasis = increased fines and focus on recordkeeping issues
•MSU    Study found 68% of recordable injuries not documented


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OSHA’s New Enforcement Emphasis

National Emphasis Program (NEP)
•Launched    10/09 to “assess” accuracy of injury recordkeeping
•Obama     admin increased OSHA’s size and enforcement actions
•1   year later – 200 inspections launched with 70% violations found
•Targeted   industries: Mfg; Large worksites & high injury rates
•$100,000+    fines tripled in last year
•Overall   emphasis = increased fines and focus on recordkeeping issues
•Severe    Violator Enforcement Program (pub 6/18/10)
•MSU    Study found 68% of recordable injuries not documented
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OSHA’s New Enforcement Emphasis

RK National Emphasis Program (NEP) Components

1.Records review (logs; WC records;
personnel records, etc. Medical Access
Order needed)
2.Interviews   (staff; mgmt; healthcare
providers)
3.Inspections
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OSHA’s New Enforcement Emphasis

Recommendations
•OSHA    Logs are up to date (medical>restricted>LT)
•Cross   check logs against other injury/illness records
•Review   recordkeeping standards and interpretations
•Get   the facts early and often (OSHA’s 7 day rule)
•Review   injury/illness reporting disincentives


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OSHA’s New Enforcement Emphasis

Pressures (from many directions)
•OSHA    numbers are used for performance indicators
•Incentives   & financial bonuses sometimes tied to rates – OSHA target
•Encouraging    not reporting injuries (= increased severity)
•Hard
    to understand a case being recordable even though no-fault of
management &/or employee & unforeseen
•Facts   and good medical judgment are best allies
•Use leading indicators vs. trailing indicators (% of staff trained;
reductions in number of noisy machines; employee surveys, etc.)

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OSHA’s New Enforcement Emphasis

(MI)OSHA Log Recordkeeping
Each employer is required to keep records of work-related fatalities, injuries and
illnesses that meet one or more of the general recording criteria, including:
•Death,

•Days   away from work,
•Restricted   work,
•Transfer   to another job,
•Medical   treatment beyond first aid,
•Loss   of consciousness, or
•A significant injury/illness diagnosed by a physician or other licensed health care
professional.
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OSHA’s New Enforcement Emphasis

(MI)OSHA Log Recordkeeping
A case is considered work-related if an event or exposure in
the work environment either caused or contributed to the
resulting condition.
A case is considered work-related if an event or exposure in
the work environment significantly aggravated a pre-existing
injury or illness. (Significant aggravation is defined in Rule
1110(d)(i-iv.)
First Aid vs. Recordable (see handout)
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OSHA’s New Enforcement Emphasis

Recordkeeping –What’s Not Recordable??
•Injury/illness   did not result from event/exposure at work
•The injury or illness involves signs or symptoms that surface at work but result solely from
a non-work related event or exposure that occurs outside the work environment.
•The injury or illness results solely from voluntary participation in a wellness program or in
a medical, fitness, or recreational activity such as blood donation, physical examination, flu
shot, exercise class, racquetball, or baseball.
•The  injury or illness is solely the result of an employee eating, drinking, or preparing food
or drink for personal consumption(whether bought on the employer’s premises or brought
in). For example, if the employee is injured by choking on a sandwich while in the
employer’s establishment, the case would not be considered work-related.
•At
  the time of the injury or illness, the employee was present in the work environment as a
member of the general public rather than as an employee.

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OSHA’s New Enforcement Emphasis

Recordkeeping –What’s Not Recordable??
•The  injury or illness is solely the result of an employee doing personal tasks(unrelated to
their employment) at the establishment outside of the employee’s assigned working hours.
•The injury or illness is solely the result of personal grooming, self medication for a non-
work-related condition, or is intentionally self-inflicted.
•The injury or illness is caused by a motor vehicle accident and occurs on a company
parking lot or company access road while the employee is commuting to or from work.
•The  illness is a mental illness. Mental illness will not be considered work-related unless the
employee voluntarily provides the employer with an opinion from a physician or other
licensed health care professional with appropriate training and experience (psychiatrist,
psychologist, psychiatric nurse practitioner, etc.) stating that the employee has a mental
illness that is work-related.
•The illness is the common cold or flu (contagious diseases such as tuberculosis,
brucellosis, hepatitis A, or plague are considered work-related if the employee is infected at
work).
OSHA’s New Enforcement Emphasis

NEP Core Principles (or How to stay off the
list!)
1.OSHA     will err on the side of recordability
2.Establish   regular meetings to discuss determinations and log entries
3.Don’t   make a premature recordability determination/entry
4.Establish   procedure to review and update logs at least every three months
5.Compare     OSHA logs with WC claim data
6.Follow   OSHA’s (40+) letters of interpretation on record keeping
7.Review    safety incentive programs
8.Process   and communications on how to report an injury
9.Do   more than just record - use the data
     Thank You!

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