For EMS and other healthcare professionals, accidental exposure to bloodborne pathogens is a constant risk. Bloodborne pathogens are infectious microorganisms in the blood. They can cause diseases like hepatitis B virus (HBV) and hepatitis C virus (HCV). Employees who become exposed to these pathogens are at risk.
The Occupational Safety and Health Administration (OSHA) provides protection through the guidance contained in its OSHA Bloodborne Pathogens Standard. Employers can find the requirements in Title 29 of the Code of Federal Regulations at 29 CFR 1910.1030. These requirements let employers know what they must do to protect their workers. These workers are those exposed to blood or other infectious materials (OPIM).
Next, is an overview of the OSHA Bloodborne Pathogens Standard and your responsibilities as an employer.
Employer Responsibilities Under the OSHA Bloodborne Pathogens Standard
OSHA Bloodborne Pathogens Standard requires employers to establish, update, and implement a plan to reduce occupational exposure.
Establishing an Exposure Control Plan
A crucial part of the OSHA Bloodborne Pathogens Standard is the bloodborne pathogen exposure control plan, which is a written plan. The purpose is to minimize or eliminate occupational exposure. As an employer, you must prepare this plan. This plan must contain a list of your employees’ job classifications who have potential occupational exposure. Further, the list should contain the procedures and other tasks performed by those workers that may result in their exposure.
Updating the Plan Once a Year
Per the OSHA Bloodborne Pathogens Standard, you must update the bloodborne pathogen exposure control plan once a year. In doing so, you reflect any changes in the procedures, tasks, and positions that relate to occupational exposure. Also, document any changes in technology that either reduce or eliminate occupational exposure.
Another addition you must also document any commercially-available medical devices that you have implemented. These devices are ones designed to minimize occupational exposure. Have you consulted with front line workers to identify, evaluate, and select effective work practices? If so, then document those as well.
Implementing Universal Precautions
Following the OSHA Bloodborne Pathogens Standard, personnel should apply universal precautions while on the job. Universal precautions direct personnel to treat all blood as if it is infectious for bloodborne pathogens. Implementing universal precautions means doing the following:
Identifying and Using Engineering Controls
Engineering controls are devices used to isolate and remove bloodborne pathogens from the workplace. They include sharps disposal containers and self-sheathing needles. They also include devices like needleless systems and sharps with engineered sharps injury protection. Employees should use all these engineering control devices at all times.
Identifying and Ensuring Use of Work Practice Controls
In addition to using engineering controls, the OSHA Bloodborne Pathogens Standard asserts that work practice controls lower the possibility of exposure by changing how personnel performs the task. This includes appropriate practices for handling and disposing of contaminated sharps. It also includes handling laundry, specimens, and contaminated surfaces.
Providing Personal Protective Equipment (PPE)
The OSHA Bloodborne Pathogens Standard emphasizes personal protective equipment or PPE. PPE includes gowns, gloves, eye protection, and masks. As the employer, you are responsible for cleaning, repairing, and replacing PPE as needed. And you must do so at no cost to your employees.
Making Hepatitis B Vaccinations Available
As directed by the OSHA Bloodborne Pathogens Standard, employers must ensure that the hepatitis B vaccine is available to all employees who have occupational exposure. You must offer this vaccination after your employee receives the mandatory bloodborne pathogen training. This training must occur within 10 days of the employee’s initial assignment to a position with occupational exposure.
Making Available Post-Exposure Evaluation and Follow-Up
Even with all of these precautions in place, exposure incidents do occur. Any occupationally-exposed worker who experiences an exposure incident must have a post-exposure evaluation. An exposure incident is specific, which is why the OSHA Bloodborne Pathogens Standard defines an exposure incident and requires an evaluation with follow up. An occupational exposure incident occurs to the mouth, eye, non-intact skin, any mucous membrane, or parenteral contact with blood or OPIM.
The evaluation and subsequent follow-up need to be free to the employee. It also includes a requirement to document the route or routes of exposure. Included are circumstances the exposure incident occurred under.
You must also identify and test the employee for HIV and HBV. You must also offer post-exposure prophylaxis treatment, counseling, and evaluation of any reported illnesses. The treating healthcare professional will provide a written opinion regarding the OSHA bloodborne pathogens test to the employer. All diagnoses remain confidential.
Using Labels and Signs to Communicate Hazards
Proper labeling is also a priority under the OSHA Bloodborne Pathogens Standard. Employers must fix warning labels to containers that hold regulated waste, reusable sharps, and refrigerators and freezers that contain blood or OPIM. Warning labels also apply to containers used to store or transport blood or OPIM. Likewise, any contaminated equipment you are servicing or shipping must also have labels. The same applies to bags of contaminated laundry.
Some facilities use red containers or red bags instead of labels. In HIV and HBV research laboratories, posted signs should appear at all access doors when OPIM or infected animals are present.
Providing Information and Training
Beyond the initial training, you provide new employees, you must also ensure that your workers receive regular training regarding the OSHA Bloodborne Pathogens Standard. This includes information on bloodborne pathogens and diseases. It also includes the methods one uses to control occupational exposure and administer the hepatitis B vaccine.
Employees must receive regular bloodborne pathogen training so that they remain familiar with medical evaluation and post-exposure follow-up procedures. You must offer this training upon the employee’s initial assignment and annually after that. You must also offer training when the employee has new or modified tasks or procedures that relate to occupational exposure. Employees should have the opportunity to ask the trainer any questions. Also, the training should be at the appropriate level and language for those employees in attendance.
What’s Included in OSHA Bloodborne Pathogens Standard Training
Some of the topics included in OSHA Bloodborne Pathogens Standard training should be the following:
• Identify bloodborne diseases
• How pathogens are transmitted
• Summary of OSHA’s requirements
• Exposure control plan
• Occupational exposure vs. exposure incident
• Exposure control procedures
• Displaying warning signs and labels
• Proper use of PPE
• Vaccination program
• Emergency procedures
• When an exposure incident occurs
HIV and HBV Laboratories
If yours is an HIV and HBV laboratory and production facility, your employees require special initial training in addition to the general OSHA Bloodborne Pathogens Standard training provided to all workers with occupational exposure.
Maintaining Medical and Training Records
A final note: Employees must maintain a sharps injury log, unless it falls under the exemption listed in Part 1904 –Recording and Reporting Occupational Injuries and Illnesses, in Title 29 of the Code of Federal Regulations.
Get More Information
In conclusion, this article presented an overview of the OSHA Bloodborne Pathogen Standard. For more information on the standard, see the OSHA’s Bloodborne Pathogens Fact Sheet. As an employer, it’s your responsibility to ensure that the proper procedures, policies, and training are in place as required by the standard. Please contact us if you have any questions about OSHA’s Bloodborne Pathogen Standard training for your staff.