OSHA Inspection: WESTCHESTER GENERAL HOSPITAL, INC.

Issued

Aug 25, 1994

Abate by

Jan 11, 1995

Penalty

Initial $2,275 · Current $2,275

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:
%%
The employer did not furnish to employees 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:
On or about April 26, 1994, Nurses, Respiratory Therapists, Emergency Room
Techs, X-ray
Technicians and other employees were expsosed to the hazard of being
infected with tuberculosis
(TB) in the the performance of their job duties due to the repeated,
prolonged, indoor contact
with patients who were infectious, or suspected of being infectious, with
TB in that employees
had potential exposure to the exhaled air of individuals with suspected or
confirmed TB disease
and/or performed, or were exposed during performance of high-hazard
procedures (e.g.
aerosolized medication treatment, bronchoscopy, sputum induction,
endotracheal intub
ation, and suctioning procedures which have the potential to generate
potentially
infectious
airborne respiratory secretions or infectious airborne particles when
performed on individuals
with suspected or confirmed TB disease where;
(1) A protocol for early identification of individuals with active TB was
not developed
and implemented.
(2) Periodic employee medical evaluations and PPD tuberculin skin testing
was not
offered and made available to all employees exposed to TB.
(3) Worker education and training to ensure employee knowledge of hazards
of TB and
compliance with appropriate controls was not developed and implemented for
all
employees exposed to TB.
(4) Feasible engineering control measures were not fully implemented and
maintained for
employee protection from hazards of TB.
Feasible and useful abatement methods for reducing this hazard include,
but are not limited to
the following:
(1) Develop and implement a protocol for early identification of
individuals with active
TB.
(2) Provide medical screening for workers which includes the following:
(i) Periodic evaluations; provide initial and periodic employee medical
evaluations
which include PPD tuberculin skin testing every six (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 preventative therapy for
infection
are exempt unless they develop symptoms.NOTE: Evaluations must include
Mantoux skin test free of charge, conducted in
accordance with standard medical practice, and at a time and place
convenient
to
the employee.
(ii) 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.
(3) Provide case management which includes appropriate physical,
laboratory, and
radiographic evaluations of new converters 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.
(4) Provide medical removal when workers with infectious TB diseases are
detected by
medical evaluation. Remove infectious workers from duty until there is no
risk
of
transmission of TB. 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.
(5) Implement feasible engineering controls as follows on the basis of
qualitative risk
assessment and the ability of each method to provide employee protection:
(i) Place individuals with suspected or confirmed TB disease in AFB (acid
fact
bacilli) isolation/ holding/ interview rooms and perform "high risk"
procedures
such as sputum inductions, bronchoscopy, aerosol generating procedures, and
other treatments provided.
(ii) Keep AFB isolation rooms/procedures rooms under negative pressure to
induce airflow into the room from all surrounding areas (e.g. adjoining
hallways,
offices, processing areas. ceiling plenums, plumbing chases, etc.)
(iii) Monitor (demonstrate) direction of airflow frequently to assure
maintenance
of negative pressure, frequently, and after adjustment or maintenance is
performed on the systems.
(iv) Employ a combination of controls and workpractices to minimize
spillage of
contaminated air from AFB containment rooms/isolation rooms/procedures
rooms
when opening and closing doors and to assure door closure.
NOTE: Air flow exhausted from isolation rooms must be transported through
ducts and systems which are recognized as containing "biohazard air" and
which
are designed and operated to ensure maintenance of negative pressure during
normal operations and during interruptions (e.g. power failures and
required
maintenance).
(6) 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)  Workpractice controls, including personal hygiene protection
(vii) Personal protective equipment
References:
1. Centers for Disease Control and Prevention. Guidelines for preventing
transmission
of tuberculosis in health-care settings, with special focus on HIV related
issues. MMWR
1990; 39(No. RR-17):1-29.
2. American Society of Heating, Refrigeration, and Air Conditioning
Engineers. 1987
ASHRAE handbook: heating ventilating, and air-conditioning systems and
applications.
Atlanta, Georgia: American Society of Heating, Refrigeration, and Air
Conditioning
Engineers, Inc. 1987:23 1-23.12.
ABATEMENT NOTE:
MULTI-STEP ABATEMENT PLAN IS AS FOLLOWS;
Step 1:(a) Institutional policy shall be developed and implemented for
early identification
of individuals/patients with active TB.
(b) Employee medical monitoring program shall be established and include/
revised to include/ tuberculin (PPD) skin testing of appropriate frequency.
(c) Employee training shall be developed and implemented.
(d) A written detailed plan of abatement outlining a schedule for
theimplementation 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 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.
Abatement Plan Due (Step 1)  30 days
Step 2:Abatement Shall have been completed by the implementation of
engineering
controls and upon verification of their effectiveness.
NOTE: All proposed control measures shall be approved by a competent,
technically qualified person. Thirty (30) day progress reports are
required during
the abatement period.
Final Abatement Due (Step 2)  90 days

Issued

Aug 25, 1994

Abate by

Sep 14, 1994

Penalty

Initial $975 · Current $975

Issued

Aug 25, 1994

Abate by

Sep 21, 1994

Issued

Aug 25, 1994

Abate by

Sep 7, 1994

Penalty

Initial $975 · Current $975

Issued

Aug 25, 1994

Abate by

Sep 21, 1994

Penalty

Initial $1,300 · Current $1,300

Issued

Aug 25, 1994

Abate by

Oct 13, 1994

Penalty

Initial $1,300 · Current $1,300

Issued

Aug 25, 1994

Abate by

Sep 7, 1994

Penalty

Initial $4,500 · Current $4,500

Issued

Aug 25, 1994

Abate by

Sep 21, 1994

Penalty

Initial $2,275 · Current $2,275

Issued

Aug 25, 1994

Abate by

Sep 21, 1994

Issued

Aug 25, 1994

Abate by

Sep 21, 1994

Penalty

Initial $975 · Current $975

Issued

Aug 25, 1994

Abate by

Aug 31, 1994

Penalty

Initial $975 · Current $975

Issued

Aug 25, 1994

Abate by

Sep 21, 1994

Penalty

Initial $4,500 · Current $3,525 Reduced

Issued

Aug 25, 1994

Abate by

Sep 14, 1994

Penalty

Initial $975 · Current $975

Issued

Aug 25, 1994

Abate by

Sep 21, 1994

Penalty

Initial $1,300 · Current $1,300

Issued

Aug 25, 1994

Abate by

Sep 14, 1994

Penalty

Initial $1,300 · Current $1,300

Issued

Aug 25, 1994

Abate by

Sep 21, 1994

Issued

Aug 25, 1994

Abate by

Sep 7, 1994

Penalty

Initial $650 · Current $650

Issued

Aug 25, 1994

Abate by

Sep 7, 1994

Issued

Aug 24, 1994

Abate by

Sep 20, 1994