Preparing for OSHA’s New Enforcement Initiative

General Counsel Agenda

Valerie Butera, a Member of the Firm in the Labor and Employment practice, in the firm’s Washington, DC, office, authored an article in The Advisory Board Company’s General Counsel Agenda titled “Preparing for OSHA’s New Enforcement Initiative.”

Following is an excerpt:

The guidance memo requires federal OSHA Regional Offices and State Plans to evaluate the number of work-related injuries and illnesses at inpatient health care and nursing home facilities in their areas and target those facilities for inspections. Compliance officers are instructed to focus on five major hazards:

  • Musculoskeletal disorders (“MSDs”) relating to patient or resident handling;
  • Workplace violence;
  • Bloodborne pathogens;
  • Tuberculosis; and
  • Slips, trips, and falls.

OSHA also reminded compliance officers that they can and should expand the scope of an inspection when additional hazards come to their attention during an inspection. For example, additional hazards may include exposure to multi-drug resistant organisms, such as Methicillin-resistant Staphylococcus aureus (“MRSA”), and exposures to hazardous chemicals, such as sanitizers, disinfectants, anesthetic gases, and hazardous drugs.

See below to download the full article in PDF format. (General Counsel Agenda, Third Quarter, 2015, The Advisory Board Company, September 2015, available at: