OSHA Inspection: COMPREHENSIVE OPTIONS FOR DRUG ABUSERS INC

Issued

Jul 8, 1999

Abate by

Aug 8, 1999

Penalty

Initial $500 · Current $500

General-duty citation text

Oregon Safe Employment Act, ORS 654.010:  The employer did not furnish
employment and
a safe place of employment which were free from recognized hazards that
were causing or
likely to cause death or serious physical harm to employees exposed to the
hazard of being
infected with Mycobacterium tuberculosis through unprotected contact with
patients who
could be suspected of being infectious with tuberculosis in that:
Employees of the drug rehabilitation center were subject to contact with
patients classified by
the Center for Disease Control as high risk for M. tuberculosis.
Tuberculosis is a respiratory
disease readily transmittable by breathing the exhaled air of suspect or
confirmed carriers of
this bacterial agent.  Patients with drug abuse problems, many of whom
were homeless and
had medical symptoms like active tuberculosis, were allowed to come into
contact with an
assessment counselor, nurse practitioner, and doctor before a purified
protein derivative
(PPD) test or chest X-ray was conducted.
The following abatement methods were deficient:
a.  Risk Assessment:  An inadequate risk assessment had been conducted for
determining the
levels of risk to tuberculosis to which the employees were exposed.  This
assessment would
provide essential data needed by the facility to aid in the development
and implementation of
its TB Infection-Control Plan.
b.  TB Infection-Control Plan:  A TB Infection-Control Plan had not been
developed and
implemented for each area of the facility.  This plan would address areas
included, but not
limited to:
assignment of responsibility for the program,
completion of an initial TB risk assessment,
managing out-patients who have possible infectious tuberculosis,
identification and use of appropriate engineering controls and respiratory
protection, and
healthcare worker training and education, counseling and screening, and
evaluation of test conversions.
c.  Early Identification and Employee Training:  A protocol was not
devised for the early
identification of individuals with active tuberculosis, and subsequent
actions to take place.
Employees in the beginning of the patient admission process (e.g.,
reception, assessment
counselors) were not trained to report to a designated person any patients
with symptoms
suggestive of infectious tuberculosis, e.g., coughing, lethargy/weakness.,
etc.  It was
assumed the TB-like symptoms were due to flu, smoking, or drug withdrawal
and therefore,
no special procedures were taken to assure employee protection.  No masks
for patients nor
N-95 or better respirators for employees were provided and/or used.  In
addition, PPDs were
not conducted until a week after the patient met with the doctor to be
assessed for methadone
treatment and was accepted, the third step in the process.  Not all
patients who start the
process are accepted for treatment.  Some might not finish the assessment
process
through to
the PPD test.  Employees could be exposed to a patient with active
tuberculosis and not
know it, and would not be protected from that exposure.d.  Medical
Surveillance:  The two-step baseline PPD was not being conducted, per the
requirements for high-risk worksites from the Centers for Disease Control
Guidelines.  The
two-step method is used for employees who have an initially negative PPD
test result and
who have not had a documented negative TB skin test result during the
preceding 12 months.
This procedure is required so that a facility can determine if positive
PPDs are the result of
pre-job infection or recent conversion from exposure on the job.  Recent
conversions can
then be investigated.
e.  Engineering Controls:  Patients with symptoms of active tuberculosis
were not placed in
isolation rooms with negative pressure, nor in rooms with considerable
levels of fresh (not
recirculated) air.  They were allowed to go into any room where the
assessment process was
taking place.  Some rooms were very small with little air movement.
Depending on the
patient's level of infection and the duration of exposure, an employee
could be at risk of
infection.
f.  Management of Employees with Positive PPD Test Results:  The employer,
upon being
informed of the positive PPD result, did not provide an evaluation to the
employee who had
a positive PPD test result and did not immediately begin an
epidemiological investigation to
determine the source of possible transmission at the worksite.

Issued

Jul 8, 1999

Abate by

Apr 28, 1999

Issued

Jul 8, 1999

Abate by

Aug 8, 1999

Issued

Jul 8, 1999

Abate by

Mar 5, 1999