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The revised guidelines broaden the agency’s previous 1996 and 2004 guidelines, and stress the importance of developing a written workplace violence prevention program, incorporating management commitment and employee participation, worksite analysis, hazard prevention and control, training, record-keeping, and program evaluation.
OSHA noted that over 23,000 significant injuries were due to violent assaults at work in 2013, with more than 70 percent of those assaults occurring in health care and social service settings. Between 2012 and 2015, OSHA conducted 148 inspections in response to workplace violence complaints. Of those, 101 were in health care or social service settings.
The agency concluded that health care and social service workers are almost four times as likely to be injured as a result of violence in the workplace as the average private-sector worker.
“This is the first update in over a decade and it could not have come sooner,” said Jordan Barab, deputy assistant secretary of labor for occupational safety and health. The latest guidance “incorporates new research, conducted within the last decade, into the root causes of workplace assaults in these settings and how to manage the unique challenges of working with patients or clients who may display violent behavior,” Barab said.
“Although there is no formal OSHA standard regarding workplace violence, the agency has invested significant resources into providing health care and social service employers with an all-encompassing set of guidelines to enable these employers to create high-quality workplace violence prevention programs,” said Valerie Butera, a labor and employment attorney in the Washington, D.C., office of Epstein Becker Green. OSHA has already announced that it intends to increase enforcement efforts in these industries, she added. “If OSHA conducts an inspection and finds that an employer’s workplace violence prevention program is lacking, the agency could issue the employer a citation under the general duty clause for failing to provide workers with a safe and healthy work environment.”
Seven states have laws requiring health care employers to run workplace violence-prevention programs in the absence of a federal standard, according to the American Nurses Association. They are California, Connecticut, Illinois, Maryland, New Jersey, New York (public sector only) and Oregon.
Additionally, California is developing comprehensive violence prevention regulations, required by state law to be adopted by July 1, 2016.
Health Care, Social Service Workers Face Significant Risks
Health care and social service workers face an increased risk of work-related assaults resulting primarily from violent behavior of their patients and clients, according to OSHA. The guidelines cover workers in hospitals, nursing homes, long-term care facilities, psychiatric facilities, drug abuse treatment centers, pharmacies, neighborhood clinics, mental health centers, community care group homes and workers who make home visits.
Studies show that inpatient and acute psychiatric services, geriatric long-term care settings, high-volume urban emergency departments and residential social services present the highest risks, according to OSHA. Workers who are at the greatest risk include those who work directly with people who have a history of violence, drug and alcohol abuse; transport patients and clients; work alone in a facility or a patient’s home; work in poorly lit areas; work in neighborhoods with high crime rates; work when understaffed; and work with inadequate onsite security or mental health personnel.
Violence Prevention Programs
Violence prevention programs should have clear goals and objectives, be suitable for the size and complexity of operations, and be adaptable to specific situations and facilities, OSHA said.
Management commitment and worker participation are essential elements of an effective violence prevention program, according to OSHA. Employers are advised to include management and employees in the creation and operation of a workplace violence prevention program through regular meetings—possibly as a team or committee, the agency said.
Conducting a worksite analysis involves a mutual step-by-step assessment of the workplace to find existing or potential hazards that may lead to violent incidents. The completed analysis should be used to identify and implement hazard prevention and control measures needed to reduce or eliminate the possibility of an incident occurring. In addition, the analysis should assist in the identification or development of appropriate training, OSHA said. “Education and training are key elements of a workplace violence protection program, and help ensure that all staff members are aware of potential hazards and how to protect themselves and their co-workers through established policies and procedures. Such training can be part of a broader type of instruction that includes protecting patients and clients, such as training on de-escalation techniques,” OSHA said.
Finally, recordkeeping and evaluation of the program are necessary to determine its overall effectiveness and identify any deficiencies or changes that should be made.
“Health care and social service employers are well-advised to review OSHA’s new guidelines and to work closely with employees to develop a program appropriate for their worksites,” said Butera. “Taking this step will provide critically important protection for employees, increase employee engagement in safety and health efforts, and reduce the possibility of receiving a citation for an inadequate workplace violence prevention program.”
Roy Maurer is an online editor/manager for SHRM.
Follow him @SHRMRoy
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