OSHA Inspection: CENTER FOR FOOT AND ANKLE EXCELLENCE, INC.

Issued

Jul 10, 2012

Abate by

Aug 7, 2012

Penalty

Initial $1,020 · Current $765 Reduced

Hazardous substances 8400

General-duty citation text

29 CFR 1910.1030(d)(2)(i):     Engineering and work practice controls shall be used to eliminate or minimize employee exposure. Where occupational exposure remains after institution of these controls, personal protective equipment shall also be used.    a. Examination Room  An employee used Exel International 3ml disposable syringes (26200) attached to Exel International 27G x 1 ? inch hypodermic needles (Reorder Number 26426) to administer a combination of medications (lidocaine hydrochloride NDC 63323-201-10, methylprednisolone acetate, and dexamethasone NDC 0641-0367-21) to two patients.  These needles were not equipped with built-in safety features designed either to eliminate or to minimize the risk of accidental percutaneous injuries from needles contaminated with bloodborne pathogens, such as, human immunodeficiency virus (HIV), hepatitis B (HBV), and hepatitis C (HCV).  Observed On or About May 18, 2012    b. Examination Room  An employee used a MooreBrand� Surgical Blade Carbon Steel (Reorder Number 37812) to remove a corn from a patient.  These blades were not equipped with built-in safety features (e.g. sterile disposable safety scalpels with retractable blades) designed either to eliminate or to minimize the risk of accidental percutaneous injuries from blades contaminated with bloodborne pathogens, such as, human immunodeficiency virus (HIV), hepatitis B (HBV), and hepatitis C (HCV).  Observed On or About May 18, 2012

Issued

Jul 10, 2012

Abate by

Jul 24, 2012

Penalty

Initial $0 · Current $0

Hazardous substances 8400

General-duty citation text

29 CFR 1910.1030(c)(1)(v):     An employer, who is required to establish an Exposure Control Plan shall solicit input from non-managerial employees responsible for direct patient care who are potentially exposed to injuries from contaminated sharps in the identification, evaluation, and selection of effective engineering and work practice controls and shall document the solicitation in the Exposure Control Plan.    a. Examination Room  The employer did not document the solicitation of input from non-managerial employees responsible for direct patient care who are potentially exposed to injuries from contaminated sharps in the identification, evaluation, and selection of effective engineering and work practice controls. Staff involvement in the device selection and evaluation process is an important element in the prevention of percutaneous injuries from needles or other sharps contaminated with bloodborne pathogens, such as, human immunodeficiency virus (HIV), hepatitis B (HBV), and hepatitis C (HCV).  Observed On or About May 18, 2012

Issued

Jul 10, 2012

Abate by

Jul 31, 2012

Penalty

Initial $1,020 · Current $765 Reduced

Hazardous substances 8400

General-duty citation text

29 CFR 1910.1030(d)(4)(ii):     All equipment and environmental and working surfaces shall be cleaned and decontaminated after contact with blood or other potentially infectious materials.    a. Examination Room  The employer did not use the appropriate or approve disinfectant to decontaminate all reusable medical instruments after contact with blood or other potentially infectious materials.  Benz-All, a 12.9% benzalkonium chloride chemical disinfectant, is not on the EPAs lists of registered antimicrobial products that are effective against blood borne pathogens - human HIV-1, Hepatitis B, and Hepatitis C viruses.  Also, the employer did not use steam sterilization to decontaminate the reusable medical instruments.  Appropriate disinfectants include fresh solutions of diluted bleach and EPA-registered antimicrobial products such as tuberculocides (List B), sterilants (List A), products registered effective against HIV/HBV (List E), and FDA cleared sterilants and high level disinfectants. Observed On or About May 18, 2012

Issued

Jul 10, 2012

Abate by

Jul 11, 2012

Penalty

Initial $0 · Current $0

Hazardous substances 8400

General-duty citation text

29 CFR 1910.1030(c)(2)(i)(A):     A list of all job classifications in which all employees in those job classifications have occupational exposure;    a. 2429 Brown Street, Philadelphia, PA 19130 - The employer did not identify and document those job classifications where employees have occupational exposure in their written Exposure Control Plan. For example, the job classifications of "Podiatrist" and "Medical Assistant" have occupational exposure.  The list of job classifications where employees have occupational exposure is a component of the exposure determination.  Observed On or About May 18, 2012