Introduction

On December 6, 1991, the Bloodborne Pathogens standard was finalized and published in the Federal Register. The OSHA standard is designed to protect workers who may have occupational exposures to Hepatitis B Virus (HBV), Human Immunodeficiency Virus (HIV) and other bloodborne pathogens, and potentially infectious materials. While health services represent a majority of the establishments covered by this standard, research labs, funeral services, linen services, medical equipment repair, law enforcement, fire aid rescue, correctional facilities, and waste removal are considered to have personnel at risk to bloodborne pathogens.

Summary

The standard requires employers to eliminate or minimize exposure to personnel by developing and implementing an Exposure Control Plan (ECP). The ECP is described to contain the following elements:

• Determination of exposure
• Schedule and method of implementation of ECP
• Method(s) of compliance
• Hepatitis B vaccination and Post-Exposure Evaluation and Follow-Up
• Communication of hazards to employees
• Recordkeeping

Similar to other OSHA programs, the ECP must be in written form and accessible to all employees. The following information will detail the major parts and impacts of the ECP.

Exposure Determination

The standard calls for the employer to list all job classifications that have full time or occasional occupational exposure (which it defines as "reasonably anticipated skin eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee's duties"). A job analysis or a list of tasks and procedures in which occupational exposures occur is to be included.

Schedule and Method of Implementation of the ECP

In addition to exposure determination, the plan must include an explanation of when and how the employer will implement the provisions of the standard that are specific to the employer's workplace.

Methods of Compliance

Universal precautions are to be observed to prevent contact with contaminated blood or materials. If the circumstance in which differentiation between body fluids is difficult or impossible, all body fluids shall be considered potential, infectious materials (e.g. saliva in dental practice). Other methods of compliance include Engineering and work practice controls. Hand washing facilities or appropriate antiseptic hand towelettes must be provided. Contaminated needles and other sharps cannot be bent, recapped, removed unless there is no alternative or it is necessary for a specific medical procedure. The shearing or breaks of contaminated needles is prohibited. All contaminated sharps must be placed in containers that are puncture resistant, properly labeled or color-coded and leakproof on the sides and bottom.

Warning information regarding equipment that may become contaminated is to be conveyed to employees or the servicing representative or manufacture so that precautions will be taken (e.g. artificial kidney).

Personal protective equipment (PPE) is to be provided to the employee at no cost. PPE includes at a minimum gloves, gowns, laboratory coats, face shields or masks, eye protection, mouthpieces, resuscitation bags, pocket masks or other ventilation devices. It is up to the employer to enforce the use of PPE. If an employee decides to decline to use PPE (because PPE use would have prevented the delivery, of health care, public safety service, or posed an increased hazard to the user) the circumstances should be investigated and documented to assess if changes should be instituted to prevent future occurrences. The PPE must be available in appropriate sizes and if an employee is allergic to certain glove types, hypoallergenic gloves, glove liners, powderless gloves or similar alternatives must be provided.

PPE is to be cleaned, laundered, repaired or replaced, and disposed of at no cost to the employee.

The employer must determine and implement an appropriate written schedule for cleaning and method at decontamination based upon the location within the facility, type of surface to be cleared type of soil present, and procedures being performed in the area.

Regulated Wastes

Must be in containers which are closeable constructed to prevent leakage of fluids and properly labeled or color coded.

Disposal of all regulated waste must be in accordance with State or Local regulations. (In California the Medical Wastes Management Act, Health and Safety code Division 20, Chapter 6.1.)

All the above procedures are to be reviewed and updated on a regular schedule to ensure their effectiveness.

Hepatitis B Vaccination & Post-Exposure Evaluation and Follow-up

Hepatitis B vaccination are to be made available at no cost to employees who have occupational exposure. Employees that decline to accept the hepatitis B vaccination must sign the statement in appendix A.

If an employee should experience an exposure incident (e.g. needle stick, splash), the exposed employee is to have a confidential medical evaluation and follow-up which include:

• Documentation of the route(s) of exposure and circumstances under which the exposure incident occurred.
• Identification and documentation of the source individual unless the employer can establish identification is infeasible or prohibited by law.
• Employee blood sample for HBV and HIV serological status to be collected as soon as feasible and tested after consent is obtained.

The Health care professional providing an exposure evaluation must be provided the following information:

• Copy of the bloodborne pathogen standard
• Description of exposed employees duties as they relate to the incident.
• Documentation of route(s) of exposure & circumstances under which exposure occurred.
• Results of source individual's blood tests, if available.
• All medical records relevant to appropriate treatment including vaccination status.

The Healthcare professional's written opinion must be made available to the employee within 15 days of the evaluation.

Communication of Hazards to Employees

Labels – Should be fluorescent orange or orange red. Red bags and/or red containers may be substituted. The biohazard logo is also acceptable.

Training – Annual training must be provided to employees with occupational exposures during working hours and at no cost to the employee. A training program is to include at a minimum the following items:

• An explanation of the modes of transmission of bloodborne pathogens
• An explanation of the employer's exposure control plan and the means by which the employee can obtain a written copy of the plan
• An explanation of the appropriate methods for recognizing tasks and other potentially infectious materials
• An explanation of the use and limitations of methods that will prevent or reduce exposure including engineering controls, work practices and PPE
• Information on the types, proper use, location, removal, handling, decontamination and disposal of PPE
• An explanation for the basis for selection of PPE
• Information on the Hepatitis B vaccine, including information on its efficacy, safety, method of administration, the benefits of being vaccinated and that the vaccine and vaccination will be offered free of charge
• Information on the appropriate actions to take and persons to contact in an emergency involving blood or other potentially infectious materials
• An explanation of the procedure to follow if an exposure incident occurs, including the method of reporting the incident and the medical follow-up that will be made available
• Information on the post-exposure evaluation and follow-up and that the employer is required to provide for the employee following an exposure incident
• An explanation of the signs and labels and/or color coding
• An opportunity for interactive questions and answers with the person conducting the training session

Recordkeeping

Records for each employee with occupational exposure should be kept for at least the duration of employment plus 30 years. Records should included: Name and social security number of the employee, a copy of HBV vaccination and all relevant medical records.

A copy of exams, medical testing, employer's copy of the Healthcare Professional's written opinion, and a copy of the information provided to the healthcare professionals should be included in the records.

APPENDIX A

I understand that due to my occupational exposure to blood or other potentially infectious materials I may be at risk of acquiring hepatitis B virus (HBV) infection. I have been given the opportunity to be vaccinated with hepatitis B vaccine, at no charge to myself. However, I decline hepatitis B vaccination at this time. I understand that by declining this vaccine, I continue to be at risk of acquiring hepatitis B, a serious disease. If in the future I continue to have occupational exposure to blood or other potentially infectious materials and I want to be vaccinated with hepatitis B vaccine, I can receive the vaccination series at no charge to me.