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Comment Letter to NIOSH on Proposed National Surveys of Health Care Workers’ Safety and Employer Safety and Health Practices
Quality and Patient Safety (Workforce)
Last Updated: 7/1/2008
July 1, 2008
NIOSH Docket Office
NIOSH Mailstop C34
Robert A. Taft Laboratories
4676 Columbia Parkway
Cincinnati, OH 45226
RE: NIOSH Survey of Healthcare Workers’ Safety and Health and NIOSH Survey of Healthcare Employer Safety and Health Practices, Docket # NIOSH-135
Gentlemen:
The Hospital & Healthsystem Association of Pennsylvania (HAP), on behalf of its members, more than 250 acute and specialty hospitals and health systems, appreciates the opportunity to provide comments on the National Institute for Occupational Safety and Health’s (NIOSH) proposed national surveys of health care workers’ safety and employer safety and health practices.
HAP appreciates NIOSH’s efforts to collect information about facility-based health and safety resources as well as workers’ perceptions of safety and health practices, however, HAP has concerns about the surveys and the methodology proposed for the collection of the data.
Specifically, HAP questions the validity of the pilot-testing of the questionnaires. Pennsylvania is a very diverse state whose health care population is represented by various sizes and types of hospitals, including large health care systems, small rural hospitals, and community-based hospitals. NIOSH indicated that it used two large medical centers to validate the questionnaires, however, HAP does not believe that this validation truly represents Pennsylvania’s total health care community.
Furthermore, HAP is concerned about the methodology for conducting the surveys, particularly as it relates to the worker survey. HAP questions whether the use of various labor unions and professional associations will present a bias to the survey results. And because the worker survey is based on workers’ perceptions and opinions, HAP is concerned that this survey is too subjective and the data may be skewed as a result.
HAP fully supports the comments submitted by the American Hospital Association on June 26, 2008, and echoes the same concerns outlined in their detailed technical comments included as Attachments 1 and 2 of their comment letter.
HAP urges NIOSH to delay implementation of their survey tools until the content of the surveys and the methodology for the collection of the data can be appropriately revised to address the concerns and comments received during this public comment period.
If you have any questions about HAP’s comments, please feel free to contact me at (717) 561-5308 or by email at lgleighton@haponline.org or Mary Marshall at (717) 561-5312.
Sincerely,
Lynn G. Leighton
Vice President
Professional & Clinical Services
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