OSHA Inspection: NATIONAL HEALTH LABORATORIES

Issued

Dec 2, 1991

Abate by

Dec 5, 1991

Penalty

Initial $1,000 · Current $500 Reduced

Issued

Dec 2, 1991

Abate by

Jan 2, 1992

Penalty

Initial $2,500 · Current $1,000 Reduced

Issued

Dec 2, 1991

Abate by

Jan 4, 1992

Penalty

Initial $5,000 · Current $5,000

Issued

Dec 2, 1991

Abate by

Jan 4, 1992

Issued

Dec 2, 1991

Abate by

Jan 4, 1992

Issued

Dec 2, 1991

Abate by

Jan 2, 1992

Penalty

Initial $25,000 · Current $10,000 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 employee(s) were
exposed to the hazard of becoming infected with Hepatitis B Virus (HBV)
and/or Human Immunodeficiency Virus (HIV) through possible direct
contact with blood or other body fluids.
(a)  Laboratory Area; Not all employee(s) with the
job title of Laboratory Technicans received training
and education on Universal Precautions and Infection
Control as outlined in the 1988 CDC Guidelines.
Laboratory Technicans are exposed to blood or body
fluids while performing blood tests, such as,
but not limited to, tests for the Hepatitis Virus,
Antibody Screening, and Blood Typing; On or about
7/3/91.
(b)  Home Care Department; Not all employee(s) with the
job title of Phlebotomists who are exposed to blood
or body fluids while drawing patient's blood, received
training and education on Universal Precautions and
Infection Control as outlined in the 1988 CDC Guidelines;
On or about 7/3/91.
(c)  Laboratory Area;  The employer's written and
implemented Infection Control Plan did not
adequately incorporate all elements outlined by
the 1988 CDC Guidelines.  The Program was deficient
in providing accurate information on the Hepatitis
B Virus vaccination; labeling and containment
requirements for potentially infectious blood or
body fluids; the disposal of contaminated sharp
items; and the Follow-up Procedures after an
exposure incident that involved blood or other
body fluids;  On or about 7/3/91.
(d)  Home Care Department;  The employer's written
and implemented Infection Control Plan did not
adequately incorporate all elements outlined by
the 1988 CDC Guidelines.  The Program was deficient
in providing accurate information on the Hepatitis
B Virus vaccination; labeling and containment
requirements for potentially infectious blood or
body fluids; the disposal of contaminated sharp
items; and the Follow-up Procedures after an
exposure incident that involved blood or other
body fluids;  On or about 7/3/91.
(e)  Home Care Department;  Employee(s) with the
job titles of Phlebotomists, after exposure to
potentially infectious blood or body fluids, did
not receive appropriate Follow-up Procedures
after an exposure incident that involved blood or
other body fluids as outlined by the 1988 CDC
Guidelines; On or about 6/25/91.
(f)  Laboratory Area;  Employee(s) with the job
titles of Laboratory Technicians, after exposure
to potentially infectious blood or body fluids,
did not receive appropriate Follow-up Procedures
after an exposure incident that involved blood
or other body fluids as outlined by the 1988 CDC
Guidelines;  On or about 6/25/91.
The hazards of such exposure include, but are not
limited to, the onset of clinical symptoms of
acute Hepatitis B, anorexia, abdominal pain,
jaundice and the potential for becoming a chronic
carrier of the Hepatitis B and/or Human Immunod-
eficiency Virus.
ABATEMENT NOTES:
Among other methods, one feasible abatement method to reduce this
hazard, is to establish and enforce adequate procedures regarding
exposure to and handling of blood or other body fluids, such as those
stipulated by the Centers for Disease Control (CDC) Guidelines publish-
ed in Morbidity and Mortality Weekly Report, June 24, 1988, Volume 37,
Number 24.  Elements essential to an Infection Control Program include
at a minimum:
ENGINEERING, ADMINISTRATIVE, AND WORKPRACTICE CONTROLS
Sharp instruments and disposable items.  Needles shall not
be recapped, purposely bent or broken by hand, removed from
disposable syringes, or otherwise manipulateed by hand.
Resheathing instruments, self-sheathing needles, or forceps
shall be used to prevent recapping needles by hand.
Reusable Equipment.  Standard sterilization and disinfection
procedures currently recommended for Hepatitis B in a
variety of health care settings are adequate to sterilize or
disinfect instruments, devices, or other items contaminated
with blood or other body fluids.  A recommended source of
information is the CDC's Guidelines for Hospital Environmen-
tal Control: Cleaning, Disinfection, and Sterilization of
Hospital Equipment.
Bagging of Articles.  Objects that are contaminated with
blood or other body fluids shall be placed in a fluid
resistant bag.  If outside contamination of the bag is
likely, a second fluid resistant bag shall be added.
Handwashing.  After removing gloves, or other contaminated
personal protective equipment, hands or other skin surfaces
shall be washed thoroughly and immediately after contact
with blood or other body fluids.
TRAINING AND EDUCATION
Training and Education of employee(s) such as, but not
limited to, Phlebotomists, Laboratory and Blood Bank
Technicians.
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 vocabul-
ary to educational level, literacy, and language background
of the employees being trained.
The Training and Education Program shall contain, at 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 other
body fluids and other potentially infect-
ious materials;
(iv)   An explanation of the use and limitations
of work practices that will prevent or
reduce employee exposure, including approp-
riate 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 vaccinat-
ed;
(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, at a minimum, the
following:
(i)    A determination of the exposure potential
of all employees;
(ii)   The schedule and method of implementation
of the Infection Control Program.
(iii)  All the items related to the  identifica-
tion, evaluation, and control of bloodborne
pathogens and exposure to blood or other
body fluids contained in the employer's
Infection Control Training and Information
Program must be incorporated in the estab-
lishment's overall written Infection
Control Program.
The written Infection Control Program shall be made avail-
able to all employees during the training program and at
all other times.
HEPATITIS B VACCINATION
The facility's infection control policy regarding Hepatitis
B vaccinations shall address all circumstances warranting
such vaccinations and shall identify employees of substant-
ial risk of directly contacting blood or other 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 Laboratory Technician, Phlebotomists
has a percutaneous (needle-stick or cut) or
mucous membrane (splash to the  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 patient shall be informed of the
incident and tested for HIV and HBV in-
fections, after consent is obtained.
(ii)   If patient consent is refused or if the
source patient tests positive, the health
care 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
health care 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 patient.  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 (ii) or (iii) 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.
The National Health Laboratories was previously cited for a violation
of the General Duty Clause (5(a)(1)) which was contained in OSHA
Inspection Number 102270188, Citation Number 1, Item Number 1, issued
on November 9, 1989, by the OSHA Corpus Christi, Texas Area Office and
became a Final Order on December 6, 1989.

Issued

Dec 2, 1991

Abate by

Dec 17, 1991

Penalty

Initial $25,000 · Current $10,000 Reduced

Issued

Dec 2, 1991

Abate by

Jan 2, 1992

Penalty

Initial $10,000 · Current $5,000 Reduced

Issued

Dec 2, 1991

Abate by

Dec 5, 1991

Penalty

Initial $8,000 · Current $5,000 Reduced

Issued

Dec 2, 1991

Abate by

Jan 2, 1992

Penalty

Initial $8,000 · Current $5,000 Reduced

Issued

Dec 2, 1991

Abate by

Jan 2, 1992

Penalty

Initial $1,000 · Current $100 Reduced

Issued

Dec 2, 1991

Abate by

Jan 2, 1992

Penalty

Initial $1,000 · Current $100 Reduced