OSHA Inspection: SERVICE CORP. INT'L DBA RIVERSIDE-GORDON MEMORIAL

Issued

Apr 17, 1991

Abate by

May 19, 1991

Penalty

Initial $700 · Current $350 Reduced

General-duty citation text

The alleged violations below have been grouped because they involve
similar or related hazards that may increase the potential for illness.
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) On or about January 3, 1991, funeral service employees performing
embalming and removal of remains were exposed to the hazard of being
infected by Hepatitis B virus and/or human immunodeficiency virus
through possible direct contact with blood or other potentially
infectious materials.
Feasible abatement methods for reducing this hazard include:
1) Establishment of a Hepatitis B vaccination policy and program which
addresses all circumstances warranting such vaccinations and
identifies all employees at substantial risk of directly contacting
blood or other potentially infectious materials, and offers all such
employees Hepatitis B vaccinations in amounts and at times prescribed
by standard medical practice.
Reference: Center for Disease Control Immunization Practices Advisory
Committee: Recommendations for Protection Against Viral Hepatitis, MMWR
1990:39 (No. 5-2).
2) Establishment of a training policy and program for employees (as
above) which includes training about Hepatitis B vaccination program
and procedures to be followed and provided if they are exposed to a
needle stick or other direct contact with blood or other potentially
infectious material.
3) Implementation of engineering controls and workpractices as necessary
to reduce risk of contact with blood (e.g. splashes, aerosols, cuts)
such as;
a) Placement of embalming table drain tube and aspirator discharge
below water surface in the embalming sink.
b) Covering of embalming sink.
c) Maintenance of regulated areas to preclude access of unprotected
employees to areas of facility where fixtures, equipment, etc., may
be contaminated with blood or other potentially infectious material.

Issued

Apr 17, 1991

Abate by

May 19, 1991

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) On or about January 3, 1991, appropriate post-exposure for
embalmers and other employee(s) exposed to the hazard of being
infected with HBV and/or HIV through direct contact with blood
or other potentially infectious materials i.e., incidents of
percutaneous (needle stick or cut) exposure, or mucous membrane
(splash to eye, nasal mucosa, or mouth) exposure, or to cutaneous
exposure of chapped, abraded, or otherwise non-intact skin.
Review of policy documents, management and employee interviews indicated
deficiencies as follows:
1) Direct exposure incidents were not defined to include incidents other
than punctures (e.g., splashes to mucous membranes or non-intact
skin) and;
2) Policy documents and management statements did not specify, refer, or
include specific requirements of DCD protocols for HIV and/or HBV
(see references below) for post-exposure follow-up.
Feasible abatement methods for reducing this hazard include: A
Confidential medical examination and follow-up including the following:
1) Documentation of the HBV and HIV infection status of the source
patient (if known) and,
2) Follow-up of the exposed employee including antigen and/or antibody
testing (HBV/HIV), counseling, illness reporting, and safe and
effective post-exposure prophylaxis as indicated according to
standard recommendations for medical practice.
Reference: Centers for Disease Control. Recommendations for Prevention
of HIV Transmission in Health-Care Setting: MMWR 1987;36 (Suppl. 2s)
Reference: Centers for Disease Control, Immunization Practices Advisory
Committee, Recommendations for Protection Against Viral Hepatitis, MMWR
1990:39 (No. S.2).
NOTE: It is recommended that the facility develop policies for
documentation and tracking of post-exposure evaluation and follow-up
procedures (re: HBV/HIV) which address or specify requirements for:
1) Documentation of source patient identification and circumstances
underwhich exposure occurred.
2) Determination of source HIV status and/or testing (HIV) of source
patients where feasible and consent issues.
3) Documentation of seronegative source patients "risk-factors"
evaluation.
4) Development of a chronological tracking system to assure timely
administration of vaccines and procedures (e.g., HBV vaccine,
serial HIV testing) and notification to exposed employees of results
of tests and evaluations, and dates of future vaccinations/
innoculations, tests or procedures that may be required.