Preparedness is on everyone's mind these days. Aside from the daily possibility of routine medical emergencies such as heart attack or workplace injury, there is additional urgency to be ready due to the current political state of the world. The constant threat of terrorism creates a great need to anticipate and prepare for the possibility of a medical emergency or injury in the workplace.
The question that vexes the average safety director is, "What is prepared?" What can a company do to be at optimum readiness? Are there any regulations, guidelines or suggestions to structure a company program? Like any other safety program, these types of projects can range from a short session aimed solely at minimum compliance to a sophisticated program with initial training, refresher sessions and drills, and a true emergency team. Program lengths can range from short, 2-3 hour workshops to full- or multiple-day programs, and are generally easy to implement, provided one can analyze the needs of the workplace and make an informed decision.
In this article, we will discuss the relevant regulations, program types and specific workplace needs so that you, the safety manager, can make a deliberate and informed decision on the subject.
Regulations
There are remarkably few regulations affecting CPR and first aid programs in the workplace. The main OSHA standard regarding this topic is 29 CFR 1910.151 the "Access to Medical Care" standard. Aside from outlining the need for "adequate first aid supplies" (not very specific, although the ANSI standard for first aid kits is a good place to start), it does clearly create some employer requirements for training. Basically, it states that employers must guarantee employees access to medical care. After a request for interpretation, OSHA explains that if the workplace has a potential for severe life-threatening hazard (suffocation, electrocution, etc.), an employee must have medical care within 3-4 minutes. Where no such hazard exists, such as an office location, the standard is 15 minutes. Where a municipal emergency service is not available within the specified timeframe (in locations with severe hazards, the municipal EMS will likely not guarantee a 3-4 minute response time), employers must provide employees training in CPR and first aid.
Another relevant OSHA standard is 29 CFR 1910.1030 the Bloodborne Pathogens standard. This creates an obligation for additional training for employees who have anticipated contact with blood or bodily fluid as a result of a workplace activity or function. This means if you've assigned your employees to first aid duties (not simply trained them, but created an expectation of service) , there are some additional compliance needs. Most of these are very simple training burdens, but there may be a need for Hepatitis B vaccination in some cases. A good consultant is helpful in providing interpretation on this standard, as there are some interesting circumstances in which an employer will not be penalized for non-vaccination. This can save a company a lot of money and sometimes allow a previously squeamish employer to implement an emergency response team where the cost of vaccination is viewed as prohibitive.
Automated External Defibrillator (AED) laws vary from state to state, and are also an important regulatory component if your program includes that type of device. Although each state has its own act for allowing Public Access Defibrillation (PAD), the standard template includes liability immunity for the AED's owner and users provided CPR and AED training is provided, device maintenance is conducted as per the manufacturer's specifications, and other requirements are followed.
Although there are not too many laws that force a general workplace to have an AED, it is an important life-saving therapy for victims of sudden cardiac arrest. The support for such devices from third-party experts is also very strong OSHA has a letter of endorsement for the devices, as does the American Heart Association and the American Safety & Health Institute.
Emergency oxygen is another helpful tool in emergency care, although workplaces occasionally shy away from it. Interestingly, we've worked with companies that readily embrace defibrillation, but feel that oxygen is "too medical" for their program. The reality of emergency oxygen is that it is a harmless, inexpensive therapy that will be used dozens of times more than an AED and requires none of the prescription and much less training to operate. The FDA has some text in their Compliance Policy Guide 7124.10 Chapter 24 "Devices," that addresses the use of medical oxygen as a non-prescription item when the delivery system meets some very basic design features.
Program Choices
The skills sets that need to be learned, the devices on which training is required, and the regulations that must be complied with generally dictate the scope and length of a training program. I have outlined some of the more common program elements we set up for clients.
CPR training: Some workplaces simply want to be able to assist employees if they have a sudden collapse (such as from a heart attack). For these clients, a CPR training session lasting 2-4 hours, depending on whether the site is interested in pediatric CPR skills, is the most common session we run. These programs are often perks given to employees by the company rather than formal emergency team building since the OSHA standard for first aid specifies first aid training.
CPR/AED training: Other workplaces have committed to the idea of providing some basic emergency care to employees who have sudden cardiac arrest by purchasing an AED. These sites will run combined CPR/AED training a program running about 3-4 hours. This creates functional AED operators capable of using the device during an emergency.
CPR/First Aid training: A more common program is CPR/First Aid training. This program runs between 4 and 6 hours, and can include AED training for sites with that type of equipment. This affords the company OSHA compliance with 29 CFR 1910.151 by combining both CPR and first aid.
MERT training: The flagship emergency team training we run at our agency is the Medical Emergency Response Team or "MERT" program. It is an 8-hour program that encompasses adult CPR, AED, Bloodborne Pathogens, first aid and emergency oxygen training, and is designed as a one-day workshop to acclimate trainees to occupational emergency care. It is often implemented as part of a training and equipment purchase and includes the necessary elements to create a response team including documentation, forms, policy and procedure, and other systemic elements. This program is intended for organizations with dedicated emergency response teams who are looking for a premium training program.
Other Workplace-Specific Needs
Like any other health and safety compliance, it is important to consider workplace-specific needs before building an emergency response program. For example, if your operation requires confined space entries, you may have a need to conduct CPR and first aid training for other reasons than those outlined above. The confined space standard, 29 CFR 1910.146, provides some insight on that particular type of operation.
You should incorporate training on any emergency equipment your company may own into your first aid program. I often will go to a workplace to conduct a program, only to find out at the end of the program that the company owns an oxygen system that was not incorporated into the CPR/first aid training. This is a terrible loss, as emergency skills are largely psychomotor activities that are learned through repeated performance. A group that does not train with the oxygen unit during practice is unlikely to use it during a real event because they have not developed the necessary "muscle memory" to reach for the device during an emergency. Bringing the tools to the classroom is an important part of proper training.
Standard industry practices are also important. Your industry may have some specific emergency care needs created by a successful legal precedent, a recommendation by an accrediting body or a licensing group. The airline industry has had AEDs for years as a result of a significant legal settlement against Lufthansa in the late 1990s for not having a device. Theme parks were also quick to adopt AEDs after a settlement by Busch Gardens involving a visitor collapsing in their park. These precedents create a situation where a broader emergency care program might be a prudent and reasonable endeavor. Look to safety colleagues in your industry to see what type of efforts they are making in this area.
In summary, building a medical emergency response program is a not a daunting task if you approach the task with the right information. Using the data and the templates above, you can begin building your program with the right safety and compliance needs in mind. Some other resources you might find helpful are listed on page 46 happy team building!
John Mateus is the programs director for Less Stress Instructional Services, a firm that provides emergency care training, products, and consulting to workplaces around the country. You can reach him at [email protected] or at the company's Web site at http://www.LessStress.comwww.LessStress.com.
Sidebar: Resources
OSHA Links:
29 CFR 1910.151 the Access to Medical Care Standard:
www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9806
29 CFR 1910.1030 the Bloodborne Pathogens Standard:
www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10051
OSHA's Support for Workplace AED's:
www.osha.gov/Publications/osha3185.pdf
FDA Links:
Text on medical oxygen during emergencies (from a vendor site): www.lifecorporation.com/fda-gif.html
Other Industry Expert Recommendations:
Endorsements for medical oxygen by American Heart Association and Journal of the American Medical Association
(from a vendor site): www.lifecorporation.com/oxyadmin2.html