OSHA Inspection: LUTHERAN CENTER FOR THE AGING

Issued

Aug 26, 1991

Abate by

Sep 3, 1991

Penalty

Initial $5,000 · Current $1,300 Reduced

Issued

Aug 26, 1991

Abate by

Sep 9, 1991

Penalty

Initial $2,500 · Current $100 Reduced

Issued

Aug 26, 1991

Abate by

Jun 1, 1992

Penalty

Initial $35,000 · Current $7,400 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)  Lutheran Center for the Aging, Smithtown, NY - Employees
with the job titles of Nursing Staff, Laundry Workers and
Housekeeping Personnel who were subjected to potential
exposure incidents such as skin punctures from a sharp
contaminated with blood or other body fluids or splashes
of blood or other body fluids to the eyes and face,
were not provided with proper training and education
concerning the use of Universal Precautions and Infection
Control as outlined in the 1988 CDC Guidelines.  The
Employer's training program addresses only explanations
of work practices to prevent or reduce exposure to blood
or other body fluids and did not contain information on
the following topics:  Engineering Controls, Hepatitis B
Vaccination, HBV and HIV follow-up procedures after an
incident involving blood or other body fluid exposure,
and instructions on identifying biohazrd signs and
labels; on or about 3/19/91.
(b)  Lutheran Center for the Aging, Smithtown, NY - Employees
with job titles of Nursing Staff, Laundry Workers and
Housekeeping Personnel were subjected to potential
exposure incidents such as, skin punctures from a sharp
contaminated with blood or other body fluids or splashes
of blood or other body fluids to the eye and face were
not offered nor given the HBV vaccination at the time
it was requested; on or about 3/19/91.
(c)  Lutheran Center for the Aging, Smithtown, NY - Employees
with the job titles of Nursing Staff, Laundry Workers
and Housekeeping Personnel.  The employers' written
Infection Control Program did not encompass all de-
partments of the facility.  The Nursing Department
was the only division within the facility identified
as a location where the use of Universal Precautions
were requried.  The employer has an Infection Control
Program that focuses on Isolation Procedures rather
than Universal Precautions; on or about 3/19/91.
(d)  Lutheran Center for the Aging, Smithtown, NY - Employees
with the job titles of Nursing Staff and Housekeeping
Personnel were not required to bag soiled linen at the
site where it was generated, and where permitted to
transport unbagged soiled linen by hand outside the
patient area to the utility room; on or about 3/19/91.
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, Registered Nurses, Licensed Practical Nurses,
Nurses's Aid, Housekeeping Personnel and Laundry Workers.
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 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, 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 health care workers, Registered Nurses,
Licensed Practical Nurses, Laundry Workers
and Housekeeping Personnel have a percutane-
ous (needle-stick or cut) or mucous mem-
brane (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 infections,
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.
HANDLING OF LINEN
The Infection Control Program shall have identified all
laundry operations involving substantial risk of direct
exposure to blood or body fluids.  Linen soiled with blood
or body fluids shall be handled as little as possible and
with minimum agitation to prevent contamination of the
person handling the linen.
All soiled linen shall be bagged at the location where it
was used; it shall not be sorted or rinsed in patient-care
areas.  Soiled linen shall be placed and transported in bags
that prevent leakage.

Issued

Aug 26, 1991

Abate by

Sep 13, 1991

Issued

Aug 26, 1991

Abate by

Sep 13, 1991

Issued

Aug 26, 1991

Abate by

Sep 2, 1991

Issued

Aug 26, 1991

Abate by

Sep 30, 1991

Issued

Aug 26, 1991

Abate by

Sep 30, 1991

Penalty

Current $800

Issued

Aug 26, 1991

Abate by

Sep 30, 1991