U.S.

Department of Labor

Occupational Safety and Ilealth Administration

Nashville Area Office
51 Century Boulevard
Suite 340
Nashville, TN 37214
Telephone: (615) 232-3803 Facsimile: (615) 232'3827

www.osha.qov

l{AY 6

I g0,E

Sean Higgins
U.S. Department of VeteranAffairs
1030 JeffersonAve
Memphis, TN 38104

RE: OSHA ComplaintNo. 1075736

Dear Mr. Higgins:

In Response to your complaint concerning safety'health hazards at the U.S. Department of Veteran
Affairs worksite located at 1030 Jefferson Ave, Memphis, TN, the Occupational Safety and Health
Administration (OSHA) conducted an inspection there. That inspection began on3l29l20l6.
The results of our investigation of your complaint items are as follows:

l:

Employees working at the Department of Veteran Affairs Medical Center in

to bio-hazardous waste f.o- u stopped-up sink drain in the 3'd floor
""por"d
CW302-1.
closet,
surgical unit housekeeping

COMPLAINT ITEM
Memphis, TN were

FINDINGS: On March 29,2016, a work place inspection of the 3'd Floor OR area was conducted.
The OR Manager, and Housekeeping Supervisor, indicated they were conducting area rounds when
they noticed an odor coming from HAC CW302-1. They accessed the room and saw that the floor sink
was clogged up and full of brown water. An Engineering Pipe-fitter, indicated he responded to room
CW302-1 on 3-15-2016 to unclog the floor sink. The Pipe-fitter indicated the floor sink was full of
brown water. The Pipe-fitter indicated he used a snake to clear the drain and as he was using it some
material started floating to the top. He collected it in a white bucket and thought it to be body tissue.
The pipe-fitter indicated he took the bucket to Building l0 and placed it outside the building in the
back and notified the Safety Office. The IFVGems Coordinator, went to Building 10 and saw the
bucket and indicated she thought the contents was body tissue of some kind and emailed EMS to pick
up. The ItVGems Coordinator said the bucket did not have a biohazard label on it and she did not put
a label on the bucket. The Medical Center has a written Blood Borne Pathogen Exposure Control Plan,
Memorandum 00-124. Service Chiefs are responsible for maintaining a list of job descriptions and
corresponding exposure risk determination. Attachment B indicates the exposure determination to be
high, some, or no risk. Attachment C lists job titles and their exposure category. Engineering Pipefitters are not listed in Attachment C. The Pipefitter had not been provided the Hepatitis B vaccine and
had not been trained on bloodborne pathogens. Notices of violation were issued regarding these issues.
See the enclosed citation for additional information.
Enclosed for your information is a copy of the Citation and Notification of Penalty which was sent to
the employer, and should have been posted at the workplace for at least three days after receipt.