Health & Safety

SEIU, Flint Michigan, and YOU: Nurses in action to protect ourselves and our communities

It’s not an “over there” or “effecting them” issue; in fact, many communities are suffering at the hands of negligent leadership with respect to their drinking water.  The people of Flint are fighting for their health and for their communities, but most importantly, they are setting the stage for a national discussion on holding those we have elected to protect our infrastructure accountable, locally and nationally. Click here for a short presentation with helpful links to signs and symptoms you can look for in your day to day work (and home) environment.

The following summarizes some of the key points:

  • The timeline link shows the Flint drama unfolding from April 2014, when the water source was switched up through January of this year when the state of emergency was declared and the media coverage expanded from local, to regional and eventually to national coverage.
  • With the additional pressure by a vocal public, demanding awareness and scrutiny, a suspiciously corresponding outbreak of Legionaire’s Disease in the same region has been brought to light.
  • Mayo clinic has provided a guideline for signs and symptoms which you may leverage to say informed and vigilant.

FlintLivesMatterSo, what can we do about it as Nurses?

1/ Stay informed – Did you know that the National Patient Safety Foundation declared the week of March 13 – 19th as “National Patient Safety Week”, their website at has an informative blog containing news, and discussion pertaining to patient and community safety.

2/ Join the fight – This isn’t just about Flint. The Nurse Alliance of California wants you to know and be prepared for additional discoveries about local issues arising from leaders who are deliberately or ignorantly “asleep at the wheel”. Remember the Exide incident? The Natural Resources Defense Council (NDRC) has posted advice on preventing lead poisoning in children.


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Updates to OSHA’s Recordkeeping Rule

From Federal OSHA:

“OSHA will now receive crucial reports of fatalities and severe work-related injuries and illnesses that will significantly enhance the agency’s ability to target our resources to save lives and prevent further injury and illness. This new data will enable the agency to identify the workplaces where workers are at the greatest risk and target our compliance assistance and enforcement resources accordingly.”

— Assistant Secretary of Labor for Occupational Safety and Health, Dr. David Michaels

The Occupational Safety and Health Administration’s revised recordkeeping rule includes two key changes:

First, the rule updates the list of industries that are exempt from the requirement to routinely keep OSHA injury and illness records, due to relatively low occupational injury and illness rates. The previous list of industries was based on the old Standard Industrial Classification (SIC) system and injury and illness data from the Bureau of Labor Statistics (BLS) from 1996, 1997, and 1998. The new list of industries that are exempt from routinely keeping OSHA injury and illness records is based on the North American Industry Classification System (NAICS) and injury and illness data from the Bureau of Labor Statistics (BLS) from 2007, 2008, and 2009. Note: The new rule retains the exemption for any employer with ten or fewer employees, regardless of their industry classification, from the requirement to routinely keep records.

Second, the rule expands the list of severe work-related injuries that all covered employers must report to OSHA. The revised rule retains the current requirement to report all work-related fatalities within 8 hours and adds the requirement to report all work-related in-patient hospitalizations, amputations and loss of an eye within 24 hours to OSHA.

Establishments located in States under Federal OSHA jurisdiction must begin to comply with the new requirements on January 1, 2015. Establishments located in states that operate their own safety and health programs (State Plan States) should check with their state plan for the implementation date of the new requirements. OSHA encourages the states to implement the new coverage provisions on 1/1/2015, but some may not be able to meet this tight deadline.

The final rule will allow OSHA to focus its efforts more effectively to prevent fatalities and serious work-related injuries and illnesses. The final rule will also improve access by employers, employees, researchers and the public to information about workplace safety and health and increase their ability to identify and abate serious hazards.

Changes to reporting requirements: What needs to be reported to OSHA?

OSHA’s updated recordkeeping rule expands the list of severe injuries that employers must report to OSHA.

As of January 1, 2015, all employers must report

1. All work-related fatalities within 8 hours.

2. All work-related inpatient hospitalizations, all amputations and all losses of an eye within 24 hours.

You can report to OSHA by

1. Calling OSHA’s free and confidential number at 1-800-321-OSHA (6742).

2. Calling your closest Area Office during normal business hours.

3. Using the new online form that will soon be available.

Only fatalities occurring within 30 days of the work-related incident must be reported to OSHA. Further, for an in-patient hospitalization, amputation or loss of an eye, these incidents must be reported to OSHA only if they occur within 24 hours of the work-related incident.

More information on new reporting requirements.

Changes to recordkeeping requirements: Who is required to keep records? Who is exempt from keeping records?

OSHA regulations require certain employers to routinely keep records of serious employee injuries and illnesses. However, there are two classes of employers that are partially exempt from routinely keeping records. First, employers with ten or fewer employees at all times during the previous calendar year are exempt from routinely keeping OSHA injury and illness records. OSHA’s revised recordkeeping regulation maintains this exemption.

Second, establishments in certain low-hazard industries are also exempt from routinely keeping OSHA injury and illness records. Since 1982, this list has been comprised of establishments in the divisions of retail trade; finance, insurance and real estate; and the service industry if the three year average lost workday case rate for their major industry group was 75 percent or less of the overall three year average of the lost workday case rate for private industry. OSHA’s revised recordkeeping regulation provides an updated list of low-hazard industries that are exempt from routinely keeping OSHA injury and illness records. The new list of exempt industries is now classified by North American Industry Classification System (NAICS), which is the standard used by Federal statistical agencies in classifying business establishments for the purpose of collecting, analyzing and publishing statistical data related to the U.S. business economy. The injury and illness rate threshold is based on more recent BLS data.

More information on updated recordkeeping requirements.

Status of Changes in the State Plan States

Effective Dates for New Reporting Requirements in OSHA State Plans

This table is current as of December 11, 2014. The table will be updated as we receive further response from the States.


Anticipated/Actual Adoption Date

Effective Date: Reporting**

Effective Date: Industry Conversion**

Significant Differences from OSHA Standard













OSHA Injury and Illness Recordkeeping and Reporting Requirements

Under the OSHA Recordkeeping regulation (29 CFR 1904), covered employers are required to prepare and maintain records of serious occupational injuries and illnesses, using the OSHA 300 Log. This information is important for employers, workers and OSHA in evaluating the safety of a workplace, understanding industry hazards, and implementing worker protections to reduce and eliminate hazards.


On September 11, 2014, OSHA announced changes to the list of industries that are exempt from the requirement to routinely keep OSHA injury and illness records, and to the list of severe work-related injuries and illnesses that all covered employers must report to OSHA. These new requirements will go into effect on January 1, 2015 for workplaces under Federal OSHA jurisdiction. The guidance materials found on this page have been updated to reflect the new requirements.

For complete information on these changes, please visit:
Updates to OSHA’s Recordkeeping Rule

The OSHA law prohibits employers from retaliating or discriminating against a worker for reporting an injury or illness.

§  29 CFR 1904.39

Am I required to prepare and maintain records?

Employers with more than ten employees and whose establishments are not classified as a partially exempt industry must record work-related injuries and illnesses using OSHA Forms 300, 300A and 301, available here. Partially exempt industries include establishments in specific low hazard retail, service, finance, insurance or real estate industries and are listed in Appendix A to Subpart B and here.

Employers who are required to keep Form 300, the Injury and Illness log, must post Form 300A, the Summary of Work-Related Injuries and Illnesses, in a workplace every year from February 1 to April 30. Current and former employees, or their representatives, have the right to access injury and illness records. Employers must give the requester a copy of the relevant record(s) by the end of the next business day.

What forms should I use?

Recordkeeping Forms

What is recordable under OSHA’s Recordkeeping Regulation?

§  Covered employers must record all work-related fatalities.

§  Covered employers must record all work-related injuries and illnesses that result in days away from work, restricted work or transfer to another job, loss of consciousness or medical treatment beyond first aid (see OSHA’s definition of first aid below).

§  In addition, employers must record significant work-related injuries or illnesses diagnoses by a physician or other licensed health care professional, even if it does not result in death, days away from work, restricted work or job transfer, medical treatment beyond first aid, or loss of consciousness.

§  Injuries include cases such as, but not limited to, a cut, fracture, sprain, or amputation.

§  Illnesses include both acute and chronic illnesses, such as, but not limited to, a skin disease (i.e. contact dermatitis), respiratory disorder (i.e. occupational asthma, pneumoconiosis), or poisoning (i.e. lead poisoning, solvent intoxication).

§  OSHA’s definition of work-related injuries, illnesses and fatalities are those in which an event or exposure in the work environment either caused or contributed to the condition. In addition, if an event or exposure in the work environment significantly aggravated a pre-existing injury or illness, this is also considered work-related.

§  For further questions or clarifications, take advantage of the additional resources on this page (under “In Focus”) or call 1-800-321-OSHA (6742).

What is first-aid for purposes of OSHA recordkeeping?

§  Using a non-prescription medication at nonprescription strength (for medications available in both prescription and non-prescription form, a recommendation by a physician or other licensed health care professional to use a non-prescription medication at prescription strength is considered medical treatment for recordkeeping purposes)

§  Administering tetanus immunizations (other immunizations, such as Hepatitis B vaccine or rabies vaccine, are considered medical treatment)

§  Cleaning, flushing or soaking wounds on the surface of the skin

§  Using wound coverings such as bandages, Band-AidsTM, gauze pads, etc.; or using butterfly bandages or Steri-StripsTM (other wound closing devices such as sutures, staples, etc., are considered medical treatment)

§  Using hot or cold therapy

§  Using any non-rigid means of support, such as elastic bandages, wraps, non-rigid back belts, etc. (devices with rigid stays or other systems designed to immobilize parts of the body are considered medical treatment for recordkeeping purposes)

§  Using temporary immobilization devices while transporting an accident victim (e.g., splints, slings, neck collars, back boards, etc.)

§  Drilling of a fingernail or toenail to relieve pressure, or draining fluid from a blister

§  Using eye patches

§  Removing foreign bodies from the eye using only irrigation or a cotton swab

§  Removing splinters or foreign material from areas other than the eye by irrigation, tweezers, cotton swabs or other simple means

§  Using finger guards

§  Using massages (physical therapy or chiropractic treatment are considered medical treatment for recordkeeping purposes)

§  Drinking fluids for relief of heat stress

Where can I learn more about recordkeeping requirements?

§  Regulatory Text

§  Training Module

§  Training Presentations

Does OSHA provide training for the general public on recordkeeping requirements?

Yes. Through its national network of OSHA Training Institute (OTI) Education Centers, OSHA offers the OSHA #7845Recordkeeping Rule Seminar course. This half-day course covers the OSHA requirements for maintaining and posting records of occupational injuries and illnesses, and reporting specific cases to OSHA. Included in the course are hands-on activities associated with completing the OSHA Form 300 Log of Work-Related Injuries and Illnesses,OSHA Form 300A Summary of Work-Related Injuries and Illnesses, and the OSHA Form 301 Injury and Illness Incident Report. To search for specific course locations and dates, please visit the OTI Education Centers searchable schedule.

What if I still have questions?

§  FAQs

§  Q&A Search

§  Hearing Loss Chart*

§  Letters of Interpretation

§  OSHA contacts

§  Recordkeeping Advisor

Are there other resources related to OSHA recordkeeping requirements?

§  Compliance Directive (CPL 2-00-135)

§  NAM settlement agreement

§  SIC Manual

§  BLS injury and illness statistics

What is the OSHA Data Initiative (ODI)?


OSHA issues a proposed rule to improve workplace safety and health through improved tracking of workplace injuries and illnesses.

“With the information acquired through this proposed rule, employers, employees, the government and researchers will have better access to data, resulting in improved programs to reduce workplace hazards and prevent injuries, illnesses and fatalities. The proposal does not add any new requirement to keep records; it only modifies an employer’s obligation to transmit these records to OSHA. We encourage the public to review this proposed rule and look forward to their comments.”

— Dr. David Michaels Assistant Secretary of Labor for Occupational Safety and Health

The purpose of this rulemaking is to improve workplace safety and health through the collection of useful, accessible, establishment-specific injury and illness data to which OSHA currently does not have direct, timely, and systematic access. With the information acquired through this proposed rule, employers, employees, employee representatives, the government, and researchers will be better able to identify and abate workplace hazards. OSHA is proposing to amend its recordkeeping regulations to add requirements for the electronic submission of injury and illness information employers are already required to keep under Part 1904. The proposed rule amends 29 CFR 1904.41 to add three new electronic reporting requirements.

For information on OSHA’s current recordkeeping requirements, please visit the OSHA Recordkeeping Webpage.

The Occupational Safety and Health Administration announced that it will extend the comment period to October 14, 2014 on the proposed rule to improve workplace safety and health through improved tracking of workplace injuries and illnesses. The docket on the proposed rule can be accessed here. For more information on the extension, see the news release.

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Nurse Alliance Partners with PQC to Stand Up for Patients and Nurses

Screenshot 2014-11-19 14.06.36Los Angeles,CA-

On November 7, 2014, SEIU Local 721, and UHW West co-hosted the largest Ebola Preparedness Training in California yet, along with other stakeholders: the Partnership for Quality Care (PQC), Kaiser Permanente, and the Los Angeles County Department of Health, among others.

The PQC is an organization where management and unions can meet on neutral ground and talk about the issues facing healthcare in America today. This conference was a wonderful opportunity for management to meet with nurse union leaders and discuss the latest CDC guidelines, as well as demonstrate proper “donning and doffing” of personal protective equipment (PPE), just in case we still weren’t clear on it. 

Nurse Alliance of California’s very own Executive Director, Ingela Dahlgren, RN, sat on the panel of presenters which included luminaries in healthcare, infection control, management, and nurse leadership. The conference was attended by many frontline health care workers, including those from Local 721 and UHW West, as well as hospital management, and clinicians, as well as those who tuned in via the live telecast. 

The conference may be viewed in its entirety below.

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Dr. Toni Lewis of SEIU International Says Partnering with Healthcare Workers is Step One

Ebola: Partnering With Healthcare Workers is Step One

It comes as no surprise in our global transportation age that the Ebola virus — once isolated to Western Africa –would eventually reach the United States. But this week we were deeply concerned by the diagnosis of not just one, but two healthcare workers at Texas Health Presbyterian Hospital in Dallas. Now, our challenge is to share up-to-date information and collaborate in the way that all public health crises demand, to contain the Ebola virus and keep front-line healthcare workers and their patients healthy.

We urge employers to take responsibility for worker, patient and consumer safety, and institute protocols and a tailored worksite plan that don’t just meet, but exceed current recommendations from the U.S. Centers for Disease Control and Prevention (CDC).

Effective worksite plans should:

    • In consultation with front-line healthcare workers, develop detailed, site specific protocols and policies that corporate most recent CDC guidance and OSHA requirements.
    • Ensure that front-line workers have the necessary personal protective equipment and supplies.
    • Take into account the nature of caring for highly infectious patients and handling contaminated materials and be staffed accordingly to limit exposure to workers and patients.
    • Be tested with front-line workers at each step and include “what-if” scenarios to prepare for alternatives before any safety protocol is implemented.
    • Provide extensive hands-on training of advanced infection control and isolation techniques for all workers who could potentially be exposed to the virus. It takes practice to properly apply and remove the head-to-toe protective gear that environmental service workers use when cleaning or healthcare workers wear when caring for patients.
    • Emphasize the role of the “team supervisor” who directs and oversees the donning and taking off of personal protective equipment.
    • Include robust cultural competence measures to maximize effectiveness and to protect the rights and dignity of all patients and workers.

We would be remiss by not taking into account the extensive resources the United States already has in place, including public health expertise, advanced technology, and a strong, committed healthcare workforce. Our communities and our hospitals have been tested time and time again with major public health challenges and natural disasters–and, together, we have learned and prevailed.

Nurses and healthcare workers also have a great deal of experience responding to major health epidemics, including HIV/AIDS. When knowledge of the disease first surfaced more than 30 years ago, public fears were exacerbated by lack of education about how the virus is transmitted. At that time, it was common for a healthcare worker to handle a patient, or even draw blood, without wearing gloves. SEIU Healthcare members led a public campaign, including the establishment of the OSHA Blood borne Pathogen Standard, to educate and limit workers’ exposure to blood borne diseases, such as HIV and Hepatitis. Today, healthcare workers’ risk of exposure has significantly declined now that proper safety equipment and precautions have been implemented.

Learning from this and other experience with the more recent SARS and H1N1 influenza outbreaks, we can and should seize this heightened awareness about Ebola to raise quality standards at our hospitals and make environmental safety improvements in other public venues, like airports, to drastically reduce exposure and further disease outbreak.

Already, SEIU members are springing into action and partnering with hospitals, healthcare agencies to step up Ebola preparedness. On Tuesday, Oct. 21, SEIU and leading hospitals in our Partnership for Quality Care will host an educational session in New York City for thousands of healthcare workers that will also be livestreamed to healthcare workers around the country. (You may view the archived footage here)

Other employers are simply dragging their feet. The working women and men of SEIU are calling on them now to do their part to ensure the safety and well-being of healthcare workers, potential patients and communities. We recognize the resources, new investments and extra staffing preparing for this moment requires, but there is no room for error and no time to lose.

SEIU healthcare workers are ready to work with our co-workers and hospital management teams to prevent the kind of events unfolding at Presbyterian Hospital from happening in our hospitals. Together, we can ensure the safety of healthcare workers and patients and stop the spread of Ebola.

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