OSHA Inspection: MEDI-WASTE LTD.

Issued

Jan 12, 1990

Abate by

Mar 30, 1990

Penalty

Initial $1,000 · Current $500 Reduced

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The
employer did not furnish employment and a place of employment which were
free from recognized hazards that were causing or likely to cause death
or serious physical harm to employees in that employees were exposed to:
a) The hazards to employees working with blood and body fluids thus
causing or likely to cause employees exposure to and contraction of
Hepatitis B Virus (HBV) and/or Human Immunodeficiency Virus (HIV).
Employees exposed include laborers and personnel who maintain the
incinerator facility on or about 7/31/89.
Feasible abatement methods for reducing this hazard, include but are
not limited to:
TRAINING AND EDUCATION
Training and Education of employees such as but not limited to laborers
and personnel who maintain the incinerator facility. Such training and
education shall be at the time of initial employment and at least
annually thereafter. The training materials used shall be appropriate
in content and vocabulary to education level, literacy, and language
background of the employees being trained.
The training and Education Program shall contain as a minimum the
following elements:
I) A general explanation of the modes of transmission of bloodborne
pathogens;
II) An explanation of the employer's infection Control Program;
III) An explanation of the appropriate methods for recognizing tasks
and other activities that may involve exposure to blood or body
fluids and other potentially infectious materials;
IV) An explanation of the use of work practices that will prevent or
reduce employee exposure, including appropriate engineering
controls, work practices and personal protective equipment;
V) An explanation of the basis for selection of personal protective
equipment;
vi) Information on the Hepatitis B vaccination, including information
on its efficacy, safety and the benefits of being vaccinated;
VII) Information on the appropriate actions to be taken and the person
to contact in an emergency;
VIII) An explanation of the procedure to follow if an exposure incident
occurs, including the method of reporting the incident and the
medical follow-up that will be made available;
IX) An explanation of the signs and labels and/or color coding used in
the workplace; and
X) A copy of the Center for Disease Control (CDC) Guidelines.
WRITTEN INFECTION CONTROL PROGRAM
The employer shall design and implement a written Infection Control
Program to minimize or eliminate employee exposure. This Infection
Control Program shall be reviewed and updated as necessary to reflect
significant changes in tasks or procedures. This program shall contain
as a minimum the following:
I) A determination of the exposure potential of all employees; and
II) The schedule and method of implementation of the Infection Control
Program.
The written Infection Control Program shall be made available to all
employees during the training program.
HEPATITIS B VACCINATION
The facility's infection control policy regarding Hepatitis B
vaccinations shall address all circumstances warranting such
vaccinations and shall identify employees at substantial risk of
directly contacting body fluids.
All such employees shall be offered Hepatitis B vaccinations in amounts
and at times prescribed by standard medical practice.
FOLLOW-UP PROCEDURES AFTER POSSIBLE EXPOSURE TO HIV/HBV:
I) If a worker has a percutaneous (needlestick or cut) or mucous
membrane (splash to eye, nasal mucosa, or mouth) exposure to blood
or body fluids or has a cutaneous exposure to blood or body fluids
when the worker's skin is chapped, abraded, or otherwise nonintact,
the source shall be informed of the incident and tested for HIV
and HBV infections, after consent is obtained.
II) The worker shall be evaluated clinically by HIV antibody testing as
soon as possible and advised to report and seek medical evaluation
of any acute febrile illness that occurs within 12 weeks after
exposure. HIV seronegative workers shall be retested 6 weeks post-
exposure and on a periodic basis thereafter (12 weeks and 6 months
after exposure).
III) Follow-up procedures shall be taken for workers exposed or
potentially exposed to HBV. The type of procedures depends on the
immunization status of the worker (i.e., whether HBV vaccination
has been received and antibody response is adequate) and the HBV
serologic status of the source.
The CDC Immunization Practices Advisory Committee has published
its recommendations regarding HBV post-exposure prophylaxis in
table format in the June 5, 1985, Morbidity and Mortality Weekly
Report.
IV) If an employee refuses to submit to the procedures in (b) or (c)
above, when such procedures are medically indicated, no adverse
action can be taken on that ground alone since the procedures are
designed for the benefit of the exposed employee.

Issued

Jan 12, 1990

Abate by

Apr 16, 1990

Penalty

Initial $1,000 · Current $500 Reduced

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970: The
employer did not furnish employment and a place of employment which were
free from recognized hazards that were causing or likely to cause death
or serious physical harm to employees in that employees were exposed to:
a) The hazard of excessive heat stress. Employees performing
incineration activities in the incinerator area on 7/28/89.
Employees were removing cardboard boxes of medical waste from trucks
and placing them in one of two active furnaces. The furnaces were
stocked periodically. This operation involved employees wearing
cotton overalls, shoes, cotton-leather gloves and helmets. A time
weighted average wet bulb globe temperature index reading taken on
7/28/89 in the incinerator area revealed 400 degress centigrade.
Such conditions of exposure, use of personal protective equipment
and the type of work being performed can lead to the development of
serious heat induced illnesses: Heat stroke, heat exhaustion, cramps
and behavioral disorders.
Among other methods some feasible and acceptable abatement methods to
correct this hazard include but are not limited to:
1) WBGT index readings taken periodically during each shift where there
is a potential for a heat stress hazard. NIOSH Publication No. 36-113
Occupational Exposure to Hot Environments and the 1988-1989 threshold
limit values and biological exposure indices by the American
Conference of Governmental Industrial Hygienists provide useful
information to assess the potential for a heat stress hazard.
2) Work rest regiments should be estalished based on American Conference
of Governmental Industrial Hygienists permissable heat exposure
threshold limit values or other state of the art technology.
3) Implement a comprehensive heat stress training program for all high
risk employees. The program shall address at a minimum the following:
a) Source of heat transfer, i.e. metabolism, radiation, convection.
b) Physiological responses to heat and first aid measures to take to
alleviate symptoms.
c) Physical indications that a worker should remove himself/herself from
the job.
d) Administrative and work practice controls in use such as diet, salt
intake, acclimation...
e) Medical and social conditions that effect heat tolerance; i.e., acute
or chronic illnesses, alcohol intake, drugs...
f) Description of Medi-Waste Ltd's, heat stress program and
responsibilities of enforcment.
Heat stress training should be reviewed prior to initial exposure to a
heat stress condition and yearly thereafter.
4) Screen employees at the beginning of each shift for physical
conditions that would affect the employees tolerance to heat stress.
Conditions such as fluid intake, appropriate rest, meals, use of
medications and previous illness can affect an employee's tolerance
to heat stress.
5) Develop and implement a comprehensive medical program. Screening must
be selective so that workers who are incapable of heat acclimation or
have precluding medical conditions are identified.
6) Establish an acclimation program similar to the one described in
NIOSH Publication No. 86-113, Occupational Exposure to Hot
Environments.
7) Where engineering and administrative controls do not provide
sufficient protection, personal cooling devices should be used.
Such devices include circulating air systems, ice chests, liquid
cooling systems and reflective clothing.
8) Establish administrative lines of authority and responsibility for
developement, implementation and control of a heat stress management
program.
9) Automate the incineration process.