HospitalInspections.org

Based on review of facility documents, personnel files (PF) and staff interview (EMP), it was determined the facility failed to develop comprehensive policies to ensure proper disposal of dry ice (solid carbon dioxide) in a safe manner in accordance with the Material Safety Data Sheet (MSDS) and OSHA recommendations.

Findings include:

A review of facility policies on January 3 and 4, 2018 revealed there were no facility policies for the proper disposal of dry ice, a solid carbon dioxide.

A review of the MSDS sheet provided by the facility on January 3, 2018 at 2:00 PM for dry ice contained information as follows: "1. Chemical Product and Company Identification Product Name: Dry Ice ... 2. Hazards Identification Emergency Overview Caution! Frozen carbon dioxide - extremely cold solid. Can cause severe frostbite. Vaporizes at normal temperatures without forming a liquid. Vapor can cause rapid suffocation. Vapor can increase respiration and heart rate. Vapor may cause nervous system damage. Vapor may cause dizziness and drowsiness. Self-contained breathing apparatus may be required by rescue workers. ... 7. Handling and Storage, Precautions To Be Taken In Handling: Avoid materials incompatible with cryogenic use; some materials such as carbon steel may fracture esily (sic) at low temperature. Vapour (sic) can cause rapid suffication (sic) due to oxygen deficiency. Never allow any unprotected part of your body to touch solid carbon dioxide or to touch uninsulated pipes or vessels containing solid or liquid carbon dioxide or cold carbon dioxide gas. Not only can you suffer frostbite, you (sic) skin may stick fast to the cold surfaces. Use tongs or insulated gloves when handling solid carbon dioxide or objects in contact with cold carbon dioxide in any form. Wear protective clothing and equipment as prescribed in Section 8. ... 8. Exposure Controls/Personal Protection: Ingredients: carbon dioxide ... Exposure limits 5000 ppm (parts per million). Ventilation/Engineering Controls: Local Exhaust: Use a local exhaust system, if necessary, to maintain the concentration of carbon dioxide below the TLV (threshold limit value) in the worker's breathing zone. Mechanical (General): Under certain conditions, general exhaust ventilation may be acceptable to keep carbon dioxide below the exposure limit ... Personal Protection: Respiratory Protection: Use respirable fume respirator or air supplied respirator when working in confined space or where local exhaust or ventilation does not keep exposure below TLV ... Skin Protection: Loose-fitting cryogenic gloves. Eye Protection: Wear safety glasses when handling cylinders ... Other Protective Equipment: Protective clothing where needed ... 13. Disposal Considerations: Waste Disposal Method: Do not attempt to dispose of residual or unused quantities. Return cylinder to supplier... "

Review on January 4, 2018, of the Occupational Safety and Health Administration (OSHA) website revealed the following "Cryogens and Dry Ice Quick Facts Laboratory Safety Cryogens and Dry Ice," OSHA 3408 Rev. October 2011, "Cryogens, as well as dry ice, can be hazardous to workers if not handled properly. General Precautions When Working with Dry Ice or LN2 [liquid nitrogen] Avoid eye or skin contact with these substances. Never handle dry ice or LN2 with bare hands. Use cryogenic gloves, which are designed specifically for working in freezers below -80 [degrees]C and for handling containers or vials stored in these freezers. Cryogenic gloves need to be loose-fitting so that they can be readily removed if LN2 splashes into them or a piece of dry ice falls into them. Always use appropriate eye protection. Do not use or store dry ice or LN2 in confined areas, walk-in refrigerators, environmental chambers or rooms without ventilation. A leak in such an area could cause an oxygen-deficient atmosphere. ... "

A review on January 3, 2018 at 2:50 PM of PF1 and PF8 revealed the facility was notified on December 4, 2017 that EMP2 disposed of dry ice in a surgical scrub sink. EMP2 and took a picture of themselves and the vapors from the dry ice in front of the surgical scrub sink.

Interview with EMP3 on January 3, 2018 at 10:30 AM confirmed the facility investigated this incident as a confidentiality issue. The incident was not investigated as a safety issue for the disposal of the dry ice in the OR scrub sink. On January 3, 2018 at 2:40 PM EMP3 confirmed the facility did not have a policy regarding the storage, handling, or disposal of dry ice and PPE (personal protective equipment) use.

Interview with EMP2 on January 3, 2018 at approximately 3:15 PM confirmed that EMP2 disposed of the dry ice in the surgical scrub sink by pouring water over it "to make it melt faster." EMP2 stated they wore medical gloves when disposing of the dry ice in the scrub sink.