OSHA Inspection: NIAGARA FALLS MEMORIAL MEDICAL CENTER

Issued

Aug 17, 2021

Abate by

Sep 17, 2021

Penalty

Initial $7,802 · Current $300 Reduced

General-duty citation text

29 CFR  1910.134(c)(1): The respiratory protection program was not updated as necessary to reflect those changes in workplace conditions that affected respirator use:  a) On or about March 31, 2021 - Registered Nurses and NPS Practitioners are required to wear N95 filtering face piece respirators to perform tasks such as, but not limited to,  screening patients with suspect COVID-19, and assisting in surgical procedures.   Niagara Falls Memorial Medical Center Policy No. D-100, effective 2/15/05, latest review date 3/19, latest revision date 5/13 contains  Section 1 Respirator Selection.   Policy No. D-100 does not indicate that N-95 respirators are required for employee use when working with suspect or COVID-19 positive patients.  The respiratory protection program was not updated as necessary to reflect those changes in workplace conditions that affected respirator use.  b) On or about March 31, 2021 - Registered Nurses and NPS Practitioners are required to wear N95 filtering face piece respirators to perform tasks such as, but not limited to,  screening patients with suspect COVID-19, and assisting in surgical procedures.   Niagara Falls Memorial Medical Center Policy No. D-100, effective 2/15/05, latest review date 3/19, latest revision date 5/13 states "1. Respirator Selection  a...."When selecting respirators for M. tuberculosis one must consider whether the respirator will be used in sterile field, such as operating rooms, or in tuberculosis (TB) isolation rooms."  Policy No. D-100 does not list the respirators required for TB protection, the employee work areas, and the conditions of use.  The respiratory protection program was not updated as necessary to reflect those changes in workplace conditions that affected respirator use.  c) On or about March 31, 2021 - Registered Nurses and NPS Practitioners are required to wear N95 filtering face piece respirators to perform tasks such as, but not limited to,  screening patients with suspect COVID-19, and assisting in surgical procedures.   Niagara Falls Memorial Medical Center Policy No. D-100, effective 2/15/05, latest review date 3/19, latest revision date 5/13 contains  Section 4 B 2 Proper Respirator Use.  A separate document, Guidelines for Extended Use and Re-Use of N95 Respirators, updated 4/10/2020, describes N95 respirator use and reuse on the COVID Unit.  Policy No. D-100 does not indicate that N-95 respirators are required for employee use when working with suspect or COVID-19 positive patients.  The respiratory protection program was not updated as necessary to reflect those changes in workplace conditions that affected respirator use.  d)  On or about March 31, 2021 - Registered Nurses and NPS Practitioners are required to wear N95 filtering face piece respirators to perform tasks such as, but not limited to,  screening patients with suspect COVID-19, and assisting in surgical procedures.   Niagara Falls Memorial Medical Center Policy No. D-100, effective 2/15/05, latest review date 3/19, latest revision date 5/13 does not include fit testing procedures for tight-fitting respirators.  A separate document describes qualititative fit testing procedures using Bitrex.  The respiratory protection program was not updated as necessary to reflect those changes in workplace conditions that affected respirator use.  ABATEMENT CERTIFICATION REQUIRED

Issued

Aug 17, 2021

Abate by

Sep 17, 2021

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.134(c)(3): The employer did not designate a program administrator who was qualified by appropriate training or experience to administer or oversee the respiratory protection program and to conduct the required evaluations of program effectiveness:    1) On or about March 31, 2021 - Registered Nurses and NPS Practitioners are required to wear N95 filtering face piece respirators to perform tasks such as, but not limited to,  screening patients with suspect COVID-19, assist in surgical procedures.    The employer did not designate a program administrator who was qualified by appropriate training or experience to administer or oversee the respiratory protection program and to conduct the required evaluations of program effectiveness.    ABATEMENT CERTIFICATION REQUIRED

Issued

Aug 17, 2021

Abate by

Sep 17, 2021

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR  1910.134(k)(1): The employer did not provide effective training that covered the required elements in 1910.134(k)(1)(i) - (vii):  a) On or about March 31, 2021 - Registered Nurses and NPS Practitioners are required to wear N95 filtering face piece respirators to perform tasks such as, but not limited to,  screening patients with suspect COVID-19, assist in surgical procedures.  The employer did not provide effective training that covered the required elements in  1910.134(k)(1)(i) - (vii).  Employees were not trained in how to perform a user seal check.  ABATEMENT CERTIFICATION REQUIRED

Issued

Aug 17, 2021

Abate by

Sep 17, 2021

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.1200(e)(1) The employer did not develop, implement, and/or maintain at the workplace a written hazard communication program which describes how the criteria specified in 29 CFR 1910.1200(f), (g), and (h) will be met:  a)  On or about March 2021, the employer did not develop, implement, and/or maintain at the workplace a written hazard communication program.  Employees have exposure or potential exposure to chemicals such as, but not limited to,  Oxivir Five 16 Concentrate (US), which contains phosphoric acid (1-5% ), hydrogen peroxide (1-5%) and 2-Hydroxybenzoic acid (0.1-1.5%) and Virex II 256 which contains n-alkyl dimethyl benzyl ammonium chloride (8.190%) and didecyl dimethyl ammonium chloride (8.704%) disinfectants.     A written program should include descriptions of how the criteria for:       1.   Labeling and other forms of warning;       2.   Safety Data Sheets AND       3.   Employee information and training will be met. Additionally, a list of hazardous chemicals known to be present in the workplace must be compiled.  Methods used to inform employees of the hazards associated with non routine tasks and the informing of contractors of workplace hazard must also be addressed.  The written program must be made available upon request.  ABATEMENT CERTIFICATION REQUIRED