OSHA Inspection: UNIVERSITY OF MIAMI SCHOOL OF MEDICINE

Issued

Apr 7, 1994

Abate by

Sep 30, 1994

Penalty

Initial $3,150 · Current $1,260 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 of
likely to cause death or serious physical harm to employees in that:
(a) On or about January 28  February 7, 1994, the Medical Examiner,
Associate Medical examiners and
other Pathologists, Morgue Curators, and other employees were exposed to
hazards of tuberculosis (TB)
infection or disease in the morgue during autopsy procedures which may
aerosolize infectious particles
e.g. sawing, irrigating!, and in adjacent and contiguous areas of the
building not physically separated
from and potentially contaminated by air recirculated from the morgue,
where:
(1) Periodic employee medical evaluations and PPD tuberculin skin testing
were not offered and
made available for all exposed employees.
(2) Worker education and training was not developed and implemented for
all exposed
employees.
(3) Feasible engineering control measures were not fully implemented and
maintained for
employee protection.
Feasible and useful abatement methods for reducing this hazard include,
but are not limited to the
following:
(1) Provide free medical screening for workers which includes the
following:
(i) Preplacement exams; provide new employees in the covered workplace
preplacement
health assessment including history and a PPD tuberculin skin test.
(ii) Administration and interpretation of skin tests; offer all employees
in the covered
workplace the Mantoux skin test free of charge, conducted in accordance
with standard
medical practice, and at a time and place convenient to the employee.
(iii) Periodic evaluations; provide periodic employee medical evaluations
which include
PPD tuberculin skin testing every (6) months for workers with frequent
exposure to
individuals with TB. Provide all other workers in the covered workplace
testing annually.
Note; workers with a documented positive TB skin test who have received
documented
adequate treatment for disease or preventive therapy for infection are
exempt unless they
develop symptoms.
(iv) Reassessment following exposure or change of health; additionally,
provide any
employee experiencing an unprotected occupational exposure to a person
with infectious
tuberculosis disease a revaluation and repeat PPD testing in accordance
with current CDC
guidelines.
(2) Provide case management of infected employees which include the
following:
(i) Protocol for new converters; provide appropriate physical, laboratory
and radiographic
evaluation to determine whether the employee has TB disease as soon as
possible,
normally     within 72 hours, following detection of a PPD conversion.
Provide
prophylactic therapy in accordance with current CDC guidelines.
(ii) Medical removal of infectious employees; When workers with
infectious TB disease
are detected by medical evaluation, remove infectious workers from duty
until there is
no risk of transmission of TB.
(iii) Return to work; return workers on medical removal to work when
adequate
treatment for TB disease is instituted, cough has resolved, and a health
care professional
certifies that the employee is no longer infectious.
(3) Provide worker education and training prior to initial assignment,
and at least annually, which
includes at least the following elements;
(i) Nature and transmissibility of TB
(ii) Risk factors for disease development
(iii) Signs, symptoms, diagnosis, and treatment of TB disease
(iv) Institutional protocols
(v) Engineering controls
(vi) Workplace controls, including personal hygiene protection
(vii) Personal protective equipment
(4) Implement feasible engineering controls as follows on the basis of
qualitative risk assessment
and the ability of each method to provide employee protection:
(i) Perform autopsies on individuals with suspected or confirmed TB
disease in
appropriately isolated autopsy rooms.
(ii) Keep autopsy rooms under negative pressure to induce airflow into
the
rooms from
all surroundings areas (e.g. corridors, ceiling plenums, plumbing chases,
etc.)
(iii) Ventilation control methods should include the following;
(a) Direction of airflow into autopsy rooms must be monitored
(demonstrated) at
least monthly to assure maintenance of negative pressure.
(b) Air flow exhausted from containment rooms must be transported through
ducts dedicated to "biohazard air" and these ducts may communicate only
with
other contaminated air into adjacent areas.
(c) The opening and closing of doors in containment rooms which are not
equipped with an anteroom must employ a combination of controls and
practices
to minimize spillage of contaminated air into adjacent areas.
ABATEMENT NOTE:
ASHRAE recommends that autopsy rooms have ventilation that provides at
least
12 totalair changes per hour. In addition these rooms should have good
distribution of air flow
in the room, negative pressure with respect to adjacent areas, and room
air exhausted
directly to the outside of the building.
(iv) In laboratories, conduct all aerosolgenerating manipulations of
clinical specimens
of (or containing, or that may potentially contain) Mycobacterium
tuberculosis in
appropriate Class I, II, or III biological safety cabinets (BSC).
(a) Recertify BSC annually, at a minimum, and whenever the HEPA filters
are
replaced, the BSC is moved, or maintenance is performed on the BSC.
(b) Determine appropriate biosafety levels for laboratory operations from
the
advisory guidelines in Biosafety in Microbiological and Biomedical
Facilities
(CDC).
References:
1. Centers for Disease Control and Prevention. Guidelines for preventing
transmission of
tuberculosis in healthcare settings, with special focus on HIVrelated
issues. MMWR 1990;
39(No. RR17):129.
2. Centers for Disease Control and Prevention/NIH. Biosafety in
Microbiological and Biomedical
Facilities. 3rd ed., May 1993 (HHS Pub.#CDC! 938395).
3. American Society of Heating, Refrigeration, and Air Conditioning
Engineers. 1987 ASHRAE
handbook: heating, ventilating, and airconditioning systems and
applications. Atlanta, Georgia:
American Society of Heating, Refrigeration, and Air Conditioning
Engineers, Inc. 1987:23 123.12.
ABATEMENT NOTE:
MULTISTEP ABATEMENT PLAN IS AS FOLLOWS;
Step 1:
(a) Employee medical monitoring program shall be tuberculin (PPD) skin
testing of appropriate
frequency.
(b) Employee training shall be developed and implemented.
(c) A written detailed plan of abatement outlining a schedule for the
implementation of
engineering measures to control or reduce employee exposure to TB as
referenced in this citation
shall be submitted to the Area Director. This plan shall include, at a
minimum, target dates for
the following actions which must be consistent with the abatement dates
required by this citation.
(1) Evaluation of engineering control options;
(2) Selection of optimum control methods;
(3) Procurement, installation, and operation of selected control
measures; and
(4) Testing or acceptance or modification/redesign of controls.
NOTE: All proposed control measures shall be approved by a competent,
technically
qualified person. Forty five(45) day progress reports are required during
the abatement
period.
Step 2:
Abatement shall have been completed by the implementation of engineering
controls and upon
verification of their effectiveness.

Issued

Apr 7, 1994

Abate by

Apr 26, 1994

Penalty

Initial $3,150 · Current $1,260 Reduced

Issued

Apr 7, 1994

Abate by

Apr 26, 1994

Penalty

Initial $3,150 · Current $1,260 Reduced

Issued

Apr 7, 1994

Abate by

Apr 26, 1994

Issued

Apr 7, 1994

Abate by

Apr 26, 1994

Issued

Apr 7, 1994

Abate by

Apr 11, 1994

Penalty

Initial $1,800 · Current $900 Reduced

Issued

Apr 7, 1994

Abate by

Apr 11, 1994

Issued

Apr 7, 1994

Abate by

Apr 26, 1994

Penalty

Initial $3,150 · Current $1,260 Reduced

Issued

Apr 7, 1994

Abate by

Apr 26, 1994

Penalty

Initial $3,150 · Current $1,260 Reduced

Issued

Apr 1, 1994

Abate by

Apr 20, 1994