OSHA Inspection: UNIVERSITY HOSPITALS OF CLEVELAND

Issued

May 22, 1996

Abate by

Oct 1, 1996

Penalty

Initial $4,500 · Current $2,250 Reduced

General-duty citation text

Section 5(a)(1) of the Occupational Safety and Health Act of 1970:  The
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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:
Morticians and residents were exposed to the hazard of being infected with
TB through
unprotected contact with tuberculosis-containing droplet nuclei during
autopsies of individuals
suspected or confirmed to have been infectious with TB, in that, since
September 1995, three
autopsies have been performed on individuals with suspected or confirmed
TB.
A. On September 27,1995 a contagious autopsy was performed on specimen
#A95-282.
B. On January 8, 1996 a contagious autopsy was performed on specimen
#A96-10AN.
C. On February 14, 1996 a contagious autopsy was performed on specimen
#A96-56N.
Feasible and useful abatement methods for reducing this hazard, as
recommended by the CDC,
include, but are not limited to:
(1)    Engineering Controls:
a)  Autopsies of individuals, who were suspected or confirmed of having TB
disease, must be
placed in a respiratory acid fast-bacilli (AFB) isolation room. High risk
procedures on
individuals with suspected or confirmed TB disease must be performed in
AFB isolation rooms.
(b)  Isolation room in use to prevent exposure to TB-containing droplet
nuclei shall be kept
under negative pressure to induce airflow into the room from all
surrounding areas (e.g.
corridors, ceiling plenums, plumbing chases, etc.).
Note: Direction of airflow into isolation rooms must be demonstrated at
least
monthly. At a
minimum, the employer must use smoke trails or some other indicator to
demonstrate that
direction of airflow is from the corridor into the isolation room with the
door closed.  If an
anteroom exists, direction of airflow must be demonstrated at the inner
door between the
isolation room and the anteroom.
Note:  The CDC guidelines, dated 10/28/94, recommend daily negative
pressure checks for the
following circumstances:
1) if the room is undergoing changes to ventilation, and
2) during the time it is being used for TB isolation.
(c)  Air exhausted from AFB isolation or treatment rooms must be exhausted
directly outside
and not recirculated into the general ventilation system.  In such
circumstances where
recirculation is unavoidable, HEPA filters must be installed in the duct
system from the room
to the general ventilation system.(d) In order to avoid leakage,
potentially contaminated air which is ducked through the facility
must be kept under negative pressure until it is discharged safely outside
(i.e., away from
occupied areas and air intakes) or decontaminated by a recognized process
(e.g., high efficiency
filtration) before being recirculated back to the isolation room.
Note: The opening and closing of doors in an isolation room which is not
equipped with an
anteroom compromises the ability to maintain negative pressure in the
room.  For these rooms,
the employer must utilize a combination of controls and practices to
minimize spillage of
contaminated air into the corridor. Recognized controls and practices
include, but are not limited
to: minimizing entry to the room; ensuring that the main autopsy room fans
are not operated
while the contagious autopsy room is in use; adjusting the hydraulic
closer to slow the door
movement and reduce displacement effects; adjusting doors to swing into
the room where fire
codes permit; avoiding placement of room exhaust intake near the door ,
etc.
(e) If high-risk procedures are performed within AFB isolation rooms
without benefit of source
control ventilation or local exhaust (e.g., hood, booth, tent, etc.), and
droplets are released into
the environment (e.g., during cutting of the chest) then a purge time
interval must be imposed
during which non-essential personnel must be restricted from entering the
room.

Issued

May 22, 1996

Abate by

Jun 24, 1996

Penalty

Initial $2,250 · Current $1,125 Reduced

Hazardous substances 1290

Issued

May 22, 1996

Abate by

Jun 24, 1996

Penalty

Initial $2,250 · Current $1,125 Reduced

Hazardous substances 1290

Issued

May 22, 1996

Abate by

Jun 24, 1996

Hazardous substances 1290

Issued

May 22, 1996

Abate by

Jun 24, 1996

Issued

May 22, 1996

Abate by

Jul 1, 1996

Issued

May 22, 1996

Abate by

Jun 24, 1996

Hazardous substances 1290