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Bloodborne Pathogens Standard for Employers

May 5, 2021

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Bloodborne Pathogens Standard for Employers

Bloodborne Pathogens Standard for Employers. OSHA (Occupational Safety and Health Administration) has created a standard that employers must follow for the protection of their employees. The OSHA Bloodborne Pathogens standard (29 CFR 1910.1030) is a detailed list of responsibilities and actions and what they are required to provide to employees to ensure their safety against the transmission of bloodborne pathogens. The compliance and safety standard helps to protect against exposure in the workplace for such diseases as: HIV (human immunodeficiency virus), HBV (hepatitis B virus), HCV (hepatitis C virus), and a series of additional bloodborne pathogens.

This guideline has been developed by OSHA and employers are required to comply with each aspect. The goal of the design is to protect workers and the workplace environment from workplace incidents and accidents that could put them at risk for transmission of a potentially deadly bloodborne pathogen disease.

A general summary of what employers must supply and offer to their employees under the standard include:

Creating an exposure control plan: Bloodborne Pathogens

A written plan to minimize or eliminate occupational exposures. An employer is required to do an analysis and create an exposure determination that includes a job classifications list for all staff members/workers that have occupational exposure, as well as a list of the procedures and tasks that the workers perform that result in their exposure. The control plan will contain: the implementation schedule and methods for methods of compliance, HBV and HIV Research Laboratories and Production Facilities, Hepatitis B Vaccination and Post-Exposure Follow-up and evaluation, Hazards communications to employees, and recordkeeping, as well as the procedure set out for the circumstances evaluation surrounding incidents of exposure. Employers shall make sure that the Exposure Control Plan is accessible to all employees and be made available to the Assistant Secretary and Director upon request for copying and examination.

Annual Update of control plan: Bloodborne Pathogens

Employers are required to update their control plan on an annual basis so that it contains any alterations in procedures, positions, and tasks that affect the occupational exposure. In addition, they must include any changes in technology that reduce or eliminate these occupational exposures. The control plan must incorporate any considerations and/or institution of new/updated commercially available medical devices that are designed to minimize or eliminate occupational exposure and are considered to be safer devices. Employers are required to solicit the review/input from workers that are on the frontline and non-managerial in the evaluation, identification, and selection of effective engineering and controls and in the workplace.

Universal precautions implementation:

This is a general ideology that identifies and treats all human blood and OPIM (other potentially infectious materials) as if they are known to be infectious for bloodborne pathogens.

Identification and use of engineering controls:

This involves identifying and making use of all devices that are designed to remove or isolate workplace bloodborne pathogens hazards. They can include but are not limited to: FDA-cleared sharps disposal containers, self-sheathing needles, and safer medical devices such as sharps that have been engineered with sharps-injury protection and systems that are needleless. Additional devices will be added to the list as technology moves forward in designing safer methods to protect workers against bloodborne pathogens. Engineering controls shall be maintained, examined and replaced on a regular basis. Employers must supply facilities for employees to wash their hands with soap and running water and/or employer will provide antiseptic hand cleanser and clean paper towels/cloth or antiseptic towelettes. Employers must make sure employees wash their hands and any mucous membranes immediately or as soon as possible after the removal of personal protection equipment. Employers must make sure that employees flush all mucous membranes and wash with soap and water following any contact with blood or OPIM.

Work Practice Controls Identification and Ensuring Use:

This is the analysis of how a task is performed as a practice that can be changed to reduce potential exposure. An example might be altering the way that contaminated sharps are handled and stored, changing the methods of specimen handling, laundry changes, and sterilizing/cleaning surfaces and items that may be contaminated.

Providing PPE (personal protective equipment:

Employers are required to supply PPE to all workers that have potential exposure. PPE can include gloves, eye protection, gowns, resuscitation bags, respirators, mouth pieces, and masks and any other PPE deemed necessary. Employers are responsible for the repair, cleaning, and replacement of the PPE as needed. All maintenance, provision, replacement, and repair is to be supplied to the worker without cost to the worker. All PPE must be supplied to workers in sizes that fit workers and are readily accessible at the worksite. PPE is only considered to be “appropriate” only when it doesn’t allow OPIM or blood to pass through an reach the worker’s street clothes, work clothes, undergarments, mouth, skin, eyes, or other mucous membranes under normal use and conditions and for the duration of use of the protective equipment. The employer will be responsible for cleaning, laundering, repair, and replacement of all PPE. When PPE is removed employers will provide a designated container for storage.

Free hepatitis B vaccinations to all workers with potential occupational exposure:

This vaccination is to be supplied to a worker after they have received the bloodborne pathogens training that is required and within ten days of their initial assignment to a position that has potential workplace exposure. There should be no cost incurred by the worker.

Occupational incident post-exposure evaluation and follow-up for worker exposed:

An exposure incident is defined as a “specific eye, mouth, or other mucous membrane, non-intact skin, or parenteral contact with blood or OPIM (other potentially infectious materials).” There is to be a post-exposure evaluation at no cost to the worker and should include full documentation of the exposure route(s) and exposure incident circumstances; identification and testing the source individual for potential HBV and HIV infection, if the law does not require consent or the source individual consents; the collection and testing of the blood of the exposed worker, if the worker consents; making post-exposure prophylaxis available, making counseling available, and the evaluation of illnesses that are reported. A healthcare professional will offer limited written opinion to the employer and all diagnosis and private health information will be confidential.

Posted Signs and Labels for hazard communication:

Using OSHA state and federal labeling guidelines, warning labels must be affixed to regulated waste containers, contaminated reusable sharps containers, any freezers or refrigerators that contain blood or OPIM (other potentially infectious materials), any other containers that may be used for storage, transporting, or shipping of blood or OPIM; equipment that has been contaminated that is being serviced or shipped; and containers or bags of contaminated laundry (except as provided in the standard.)  The use of text that is large enough to be seen from a distance as well as the universal hazard label should be used. Employers must ensure that all signs and labels are instituted. Facilities may make use of red containers or red bags instead of labels however they should have the universal biohazard logo affixed. In research laboratories and production facilities that have HBV and HIV, signs are required to be posted at all access doors when infected animals or OPIM are present within the containment module(s) or work area(s).

Provide FDA-cleared containers for hazardous waste:

Employer must provide FDA-cleared containers that are labeled and identified for specific waste types and that are easily accessible at the point of use. The containers must be sturdy, leak-proof, puncture-resistant and be able to be completely sealed for storage and transport. Sharps containers must be identified and have a top opening that only allows the sharps to be dropped in but not access for workers to place their hands inside. Sharps containers must be filled only to the 2/3 mark.

General Housekeeping:

Employers are responsible for making sure that all work areas and surfaces are maintained in a clean and sanitary condition. The employer will decide and implement the appropriate written schedule detailing the cleaning, decontamination method based on location within the facility, surface type to be cleaned, soil type present, and the procedure tasks that are performed in that area. All working surfaces, equipment and environmental shall be decontaminated and cleaned after any contact with OPIM or blood. Employer shall ensure that work surfaces are decontaminated with the appropriate disinfectant after procedures are complete or as soon as possible when any surfaces might be overtly contaminated with blood or OPIM when a work shift ends if the surface could have been contaminated between that time and the last cleaning. Any protective coverings such as paper, aluminum foil, or plastic wrap shall be removed and then replaces as soon as possible when they become overtly contaminated or at the completion of a work shift if they may have been contaminated during the work shift. Any/all cans, bins, pails, or similar containers intended for reuse which may have the likelihood of having been contaminated with blood or OPIM is required to be inspected and contaminated on a regular basis and cleaned/decontaminated immediately or as soon as possible when there is visible contamination. 

HBV and HIV research laboratories and facilities: Bloodborne Pathogens

These labs and facilities are those engaged in HBV and HIV production, concentration, culture, manipulation, and experimentation. The rules do not apply to diagnostic or clinical laboratories that are only involved in blood, tissue, or organ analysis. All HBV and HIV laboratory doors will be closed when work is being done involving HIV and HBV. All regulated waste will be destroyed using incineration and/or a decontamination method such as autoclaving to ensure the destruction of bloodborne pathogens. Employers must ensure that only authorized personnel have access to the work area. There will be written procedures and policies in place that establish the individuals who have been advised of a potential biohazard, who meet the requirements for entry, comply with all procedures for entry and exit and only those people can have work area and animal room access.  All access doors shall have the universal biohazard symbol where there is potentially infectious animals or materials. It’s required that each lab/research facility have double doors for access and exit. Laboratory PPE, including uniforms, smocks, gowns, coats and any other protective clothing shall be used in the animal rooms and work areas. PPE clothing shall not be worn outside of the work area and must be contaminated prior to laundering.  Vaccum lines must be protected using liquid disinfectant traps and HEPA (high-efficiency particulate air filters or filters that offer the equivalent efficiency. The filters must be checked, maintained, and replaced routinely. All laboratories and research facilities must have hand washing and eye washing areas.

Provide training and information to workers: Bloodborne Pathogens

Employers must require and ensure that all workers receive regular OSHA-approved training that encompasses all of the elements of the standard including but not limited to: bloodborne pathogens and disease information, methods used for occupational exposure control, hepatitis B vaccine, and procedures for medical evaluation and post-exposure follow-up.  Employers are required to offer the training as soon as an initial assignment is confirmed and a minimum of an annual training after the first training is successfully completely. Additionally, training updates must be offered when modified tasks or new positions will affect the occupational exposure of a worker. Specialized initial training must be offered and completed for HBV and HIV laboratory and production facility workers as well as training to all workers that have potential occupational exposure. The training must be presented in a language that is understood by the workers, at an educational level understood by the workers, and must allow workers to ask the trainer questions.

Maintain worker training and medical records: An employer is required to maintain a sharps injury log, unless they are exempt under Part 1904 – Recording and Reporting Occupational Injuries and Illnesses, in Title 29 of the Code of Federal Regulations. This portion of the standard has specific limitations that include but are not limited to: partial exemptions for certain industries, for those with 10 employees or less, and regarding maintaining records for multiple agencies.

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