OSHA Inspection: GEORGETOWN UNIVERSITY SCHOOL OF MEDICINE

Issued

Jun 10, 2025

Abate by

Jun 18, 2025

Penalty

Initial $16,550 · Current $16,550

General-duty citation text

29 CFR  1910.1048(c)(1): Employees were exposed to an airborne concentration of formaldehyde which exceeded 0.75 parts per million, as an 8-hour time weighted average (TWA):   (a) Morgue - On or about  February 24, 2025, the Operations Manager of the Morgue  was exposed to an 8-hour TWA of  2.1 ppm of  formaldehyde during the embalming operation.   (b) Morgue - On or about February 25, 2025,  the Operations Manager of the Morgue  was  exposed to an 8-hour TWA of  1.7 ppm of  formaldehyde during of embalming operation.  In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the Certification of Corrective Action Worksheet), in addition, documentation demonstrating the abatement is complete must be included with your certification. This documentation may include but is not limited to evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

Issued

Jun 10, 2025

Abate by

Jun 23, 2025

Penalty

Initial $0 · Current $0

Hazardous substances 1290

General-duty citation text

29 CFR  1910.1048(c)(2): Employees were exposed to an airborne concentration of formaldehyde which exceeded two parts per million as a 15-minute short term exposure limit (STEL):  (a) Gross Anatomy Laboratory - On or about January 28, 2025, the Director of the Gross Anatomy Course was measured to be exposed to a 3.5 ppm of formaldehyde over a fifteen-minute period while instructing medical students on dissecting cadavers that were releasing formaldehyde vapors.  In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the Certification of Corrective Action Worksheet), in addition, documentation demonstrating the abatement is complete must be included with your certification. This documentation may include but is not limited to evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

Issued

Jun 10, 2025

Abate by

Oct 14, 2025

Penalty

Initial $0 · Current $0

Hazardous substances 1290

General-duty citation text

29 CFR  1910.1048(f)(1): Engineering controls and work practices were not instituted to reduce and maintain employee exposures to formaldehyde at or below the TWA and the STEL:  (a)  Gross Anatomy Laboratory - On or about January 23, 2025, the employer did not institute engineering and work practice controls to reduce and maintain employee exposures to airborne concentration of formaldehyde-in-air below two parts per million (PPM), 15-minute short term exposure limit (STEL) in that an employee was exposed to 3.5 ppm, 1.77 times the STEL of 2 ppm, of formaldehyde, while Instructors and TAS conducted dissection activities on cadavers.  (b) Morgue - On or about February 24, 2025, the employer did not institute engineering and work practice controls to reduce and maintain employee exposures to airborne concentration of formaldehyde-in-air below 8-hour time weighted average of 0.75 ppm permissible exposure limit (PEL) in that an employee was exposed to a TWA of 2.1 ppm, 2.83 times the PEL of .75 ppm, of formaldehyde, during the embalming operation being performed by the Morgue Operations Manager.   (c) Morgue - On or about February 25, 2025, the employer did not institute engineering and work practice controls to reduce and maintain employee exposures to airborne concentration of formaldehyde-in-air below an 8-hour time weighted average of 0.75 ppm permissible exposure limit (PEL) in that an employee was exposed to a TWA of 1.7 ppm, 2.25 times the PEL of 0.75 ppm, of formaldehyde, during the embalming operation being performed by the Morgue Operations Manager.  ABATEMENT STEPS ARE AS FOLLOW:  STEP 1 - As an interim measure, effective respiratory protection shall be provided to and used by exposed  employees until feasible and/or administrative controls can be implemented or whenever such controls fail to  reduce employee exposure to within permissible exposure limits.   STEP 2 - A written detailed plan of abatement shall be submitted to the Area Director outlining a schedule for  the implementation of engineering and/or administrative measures to control employee exposures to hazardous  substances as referenced in this citation. This plan shall include, at a minimum, target dates for the following  actions which must be consistent with the dates required by this citation by August 10, 2025:  1. Evaluation of engineering control options.  2. Selection of optimum control method and completion of design.  3. Procurement, installation and operation of selected control measures.  4. Testing and acceptance or modification/redesign of controls.  Note: All proposed control measures shall be approved for each particular use by a competent industrial  hygienist or other technically qualified person. Ninety- (90) day progress reports are required during the  abatement period.   (The 90-day requirement can be shortened or lengthened by the Area Director depending on the specific  circumstances.)  STEP 3 - Abatement shall have been completed by the implementation of feasible engineering and/or  administrative controls upon verification of their effectiveness in achieving compliance.  In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the Certification of Corrective Action Worksheet), in addition, documentation demonstrating the abatement is complete must be included with your certification. This documentation may include but is not limited to evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

Issued

Jun 10, 2025

Abate by

Jun 23, 2025

Penalty

Initial $0 · Current $0

Hazardous substances 1290

General-duty citation text

29 CFR 1910.1048(h): The employer did not comply with 29 CFR 1910.132 and 29 CFR 1910.133 by assuring that the protective devices provided at no cost were worn by the employees:  (a) Gross Anatomy Laboratory - On or about January 23, 2025, the employer did not ensure instructors and TAS were using the provided respirators, chemical goggles and or safety glasses while conducting dissections on cadavers where formaldehyde levels were monitored to be 3.5 ppm, 1.77 times the STEL of 2 ppm, of formaldehyde.  (b) Morgue - On or about February 24, 2025, the employer did not ensure Morgue Operations Manager was using the provided respirator during the embalming process where he was exposed to formaldehyde levels of  a TWA of 2.1 ppm, 2.83 times the PEL of .75 ppm.  (c) Morgue - On or about February 25, 2025, the employer did not  ensure Morgue Operations Manager was using the provided respirator during the embalming operation where he was exposed to formaldehyde levels of  a TWA of 1.7 ppm, 2.25 times the PEL of 0.75 ppm.  In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the Certification of Corrective Action Worksheet), in addition, documentation demonstrating the abatement is complete must be included with your certification. This documentation may include but is not limited to evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

Issued

Jun 10, 2025

Abate by

Jul 14, 2025

Penalty

Initial $0 · Current $0

Hazardous substances 1290

General-duty citation text

29 CFR 1910.1048(n)(1): The employer did not ensure that all employees who were assigned to workplaces where there was exposure to formaldehyde participated in a training program:  Gross Anatomy Laboratory - On or about January 23, 2025, the employer did not ensure instructors and TAs, who are dissecting cadavers, causing a release of formaldehyde, where there are exposures to airborne concentrations at or above 0.14  ppm, are required to participate in a training program that identifies the health hazards of overexposures to formaldehyde and how to protect themselves.  In accordance with 29 CFR 1903.19(d), abatement certification is required for this violation (using the Certification of Corrective Action Worksheet), in addition, documentation demonstrating the abatement is complete must be included with your certification. This documentation may include but is not limited to evidence of the purchase or repair of the equipment, photographic or video evidence of abatement, or other written records.

Issued

Jun 10, 2025

Penalty

Initial $0 · Current $0

General-duty citation text

29 CFR 1910.157(e)(3): Portable fire extinguishers were not subjected to an annual maintenance check:  (a)  Morgue - On or about February 24, 2025, the ABC fire extinguisher located on a wall, by the embalming table, had not had an annual maintenance inspection since September 2021 and had a gauge that showed as being discharged.  No Abatement Required

Issued

Jun 10, 2025

Penalty

Initial $0 · Current $0

Hazardous substances 1290

General-duty citation text

29 CFR  1910.1048(d)(6): Employees were not notified within 15 working days of receiving the results of formaldehyde exposure monitoring, in writing, either by distributing copies of the results to the employees or by posting the results:  (a) Gross Anatomy Laboratory - On or about January 27, 2025, a Gross Anatomy Teaching Assistant (TA) was working while the laboratory was being  sampled for formaldehyde exposure on January 16, 2025 and January 23, 2025, and did not receive sampling results until March 31, 2025.  No Abatement Required