OSHA Bloodborne Pathogens Standard: A Guide For Employers
In December of 1991, The Occupational Safety and Health Administration (OSHA) announced the implementation of the Bloodborne Pathogens Standard with the mission to prevent injuries and protect the health of American workers. This standard imposes safety requirements on employers of workers who are exposed to blood or other potentially infectious materials.
Under OSHA’s Bloodborne Pathogens Standards, employers are required to protect workers against health hazards by adopting preventive measures such as occupational exposure control plans, hepatitis B vaccinations and annual training for all employees. Organizations that fail to comply with these requirements can face OSHA fines that go up to $70,000 depending on the gravity of the violation.
Let’s begin with the definition of bloodborne pathogens:
What are Bloodborne Pathogens?
Bloodborne pathogens are microorganisms in human blood that are infectious and can cause disease in humans. The most common pathogens are human immunodeficiency virus (HIV), hepatitis B (HBV), and hepatitis C (HCV). Bloodborne pathogens can be transmitted by having contact with infected human blood or other body fluids that are potentially infectious such as amniotic fluid, semen, vaginal secretions, saliva (in dental procedures) to name a few.
The most common ways of bloodborne pathogens exposure and transmission are:
Accidental punctures from a needlestick or other contaminated sharp materials.
The contact between mucous membranes, or damaged skin and infected body fluids.
The CDC (Centers for Disease Control and Prevention) determined that 5.6 million health care workers and other related occupations are at constant risk of exposure to bloodborne pathogens. For this reason, employers are required to comply with the OSHA Bloodborne Pathogens Standard as a preventive measure. Read more on the employer’s requirements:
How can employers comply with the OSHA Bloodborne Pathogens Standard
All of the requirements of the OSHA Bloodborne Pathogens Standard are found in Title 29 of the Code of Federal Regulations at 29 CFR 1910.1030.
In general, employers can comply with the standard by:
Establishing an Exposure Control Plan
The exposure control plan is a crucial part of the OSHA Bloodborne pathogens standard. It is a written plan where the employer has to prepare an exposure determination based on a list of job classifications. It should list the tasks and procedures performed by each of these job classifications and explain how they can result in their exposure to blood or other potentially infectious materials (OPIM).
Updating the Plan Annually:
By updating the exposure control plan once a year, employers must reflect technological changes aimed to reduce exposure. Also, address the changes made in procedures, tasks, and positions relating to occupational exposure. Documenting input from front-line workers is essential to identify, evaluate and select effective engineering as well as safer medical devices to reduce or eliminate the risk of exposure.
Implementing the Use of Universal Precautions:
Utilizing universal precautions refers to an approach to infection control where all human blood and OPIM are treated as if known to be infectious for bloodborne pathogens. These are the precautions to implement by all employees who have occupational exposure:
Employees should use engineering control devices at all times, so it is important that they can identify and use them correctly. Engineering controls are devices used to remove or isolate the danger of bloodborne pathogens in the workplace.
These include self-sheathing needles, disposal containers for sharp objects, needleless systems, and other safer medical devices with engineered sharps injury protection.
Work Practice Controls
Besides using engineering controls, the identification and proper usage of work practice controls help reduce the risk of exposure to bloodborne pathogens. These are aimed to change the way a task is performed, such as handling and disposing of contaminated sharps, cleaning contaminated surfaces or items, handling laundry and specimens.
Hepatitis B Vaccinations
OSHA's Bloodborne Pathogens Standard also states that hepatitis B vaccination must be available to all workers with occupational exposure and offered after the employee has completed the required training for bloodborne pathogens.
This must take place within the first 10 days after the employee was assigned to a job or position where they can reasonably be at risk of contact with blood or other potentially infectious materials.
Personal Protective Equipment (PPE)
Personal protective equipment is equipment that protects the user against any health or safety risks at work. Items such as gowns, gloves, masks, eye protection, safety footwear and high visibility clothing. This may also include respiratory protective equipment (RPE).
The provision of personal protective equipment as well as cleaning, repairing, and replacing PPE is entirely the employer’s responsibility and it is at no cost to the workers.
Post-Exposure Evaluation and Follow-up
Adopting all these precautionary measures will not completely eliminate the risk of an incident. In case of exposure, the employee must be assured a post-exposure evaluation and follow-up at no cost.
This must include the documentation of the route(s) of exposure as well as the circumstances under which the incident happened. Also, exposed workers should be tested for HIV and HBV and be provided with a written opinion by a healthcare professional, ensuring all diagnoses remain confidential.
Communicate the Hazard of Blood or Potentially Infectious Materials
Another priority under the OSHA Bloodborne Pathogens Standard is the proper labeling and signalization of any hazard. Warning labels must be put on containers of regulated waste such as contaminated reusable sharps or laundry.
Refrigerators, freezers, and other containers used to store or transport blood and OPIM should also be properly labeled. Some facilities may use red bags or containers instead of labeling. Also, door access to HIV and HBV research laboratories must have signs posted when infected animals or OPIM are present.
Providing Information and Training
Employees should receive training on a regular basis covering all elements of OSHA’s Bloodborne Pathogens Standard. Training should teach employees how to reduce occupational exposure by covering the following information:
Bloodborne pathogens and diseases
How pathogens can be transmitted
Hepatitis B and other vaccination programs
Overview of all labels and signs used to communicate hazard
The correct usage of personal protective equipment
Procedures to follow in case of accidental exposure
Medical evaluations and post-exposure follow-up procedures
This training has to be delivered upon initial assignment and be repeated at least once annually. If new or modified tasks or procedures will affect an employee’s occupational exposure, additional training should be given to cover the new information.
In addition to the training given to all workers, HIV and HBV laboratory and production facility workers should receive specialized initial training. Employees could also try our free workplace bloodborne pathogens quiz to learn more about them.
Maintaining Medical and Training Records
As a final measure, the employer should also keep a record of all work-related needlestick injuries or cuts from sharp objects that have been contaminated with blood or OPIM (sharps injury log). This is not intended to track employees having injuries but instead, it is used to track devices that are causing injuries and that should be replaced.
A properly documented sharps injury log will serve as a surveillance tool to identify procedures and/or departments where injuries are occurring.
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