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OSHA and the Bloodborne Pathogen Standard

 OSHA's Bloodborne Pathogen Standard was created to protect workers occupationally exposed to blood or other potentially infectious materials (OPIM). This means any employee that might come into contact with infectious materials as a result of their job. Employers obligations are defined in the standard and the key components are highlighted in OSHA's Fact Sheet. We wanted to take this a step further and break down each bulleted point in more detail.

Establish an exposure control plan. This is a written plan to eliminate or minimize occupational exposures.The employer must prepare an exposure determination that contains a list of job classifications in which all workers have occupational exposure and a list of job classifications in which some workers have occupational exposure, along with a list of the tasks and procedures performed by those workers that result in their exposure.

 This is the meat and potatoes of your obligation under the standard. This policy identifies who has exposure, like a dentist(s), dental assistant(s) and dental hygienist(s) in a dental practice or physician(s), nurse(s), medical assistant(s), lab tech(s) or other specialty specific titles in a medical facility. Your exposure control plan lists the types of procedures you perform and the minimum PPE required. It contains required policies on Hepatitis B vaccinations and post-exposure prophylaxis. 

Employers must update the plan annually to reflect changes in tasks, procedures, and positions that affect occupational exposure, and also technological changes that eliminate or reduce occupational exposure. In addition, employers must annually document in the plan that they have considered and begun using appropriate, commercially-available effective safer medical devices designed to eliminate or minimize occupational exposure. Employers must also document that they have solicited input from frontline workers in identifying, evaluating, and selecting effective engineering and work practice controls.

Although this is pretty straight forward it has an important requirement. First the obvious, review your plan annually. Most of your site-specific details won't change from year to year. More than likely your still performing the same types of procedures and locations of items like an eye wash station, are unlikely to change. What can change is the actual OSHA regulations. Your policies have to be based on current regulations. OSHA doesn't change all the time, but 5 year old policies might not be adequate anymore. One very important element of your annual review is a safe needle or device evaluation. It's often overlooked, but the Bloodborne Pathogen Standard was amended to require annual evaluations of these safety equipped devices. These devices include retractable or self-sheathing needles and scalpels or any medical device that has the engineering control built-in. If you're not using them evaluations must be documented annually.

Implement the use of universal precautions - treating all human blood and OPIM as if known to be infectious for bloodborne pathogens.

OSHA defines OPIM to include semen, vaginal secretions, saliva in dental procedures, fluids found around the joints, brain and spine, amniotic fluid and any fluid visibly contaminated by blood.

One of the best ways to accomplish this concept is to treat all your patients the same. Many patients don't know if they are infectious or they might be reluctant to disclose it. Consider Hepatitis C infections alone; The CDC estimates 1 in 50 American adults are infected with Hep C and most don't know it. 

Identify and use engineering controls. These are devices that isolate or remove the bloodborne pathogens hazard from the workplace. They include sharps disposal containers, selfsheathing needles, and safer medical devices, such as sharps with engineered sharps-injury protection and needleless systems.

We already addressed a portion of this in the 'very important' part of the Employers must update the plan annually, but will expand on this a little bit further. 

Engineering controls include sharps containers and recapping devices, but consider the emphasis OSHA puts on built-in engineering controls.Try to incorporate or switch to safety needles. If you haven't, research or request samples. Some specialties are able to make the switch relatively easy, others have very limited options and might never incorporate them. This is our Safe Needle Evaluation Form that's included with our OSHA System. Use it to document any individual evaluations you've completed or need to complete. Evaluations should include non-managerial employees and can be conducted collectively. Individual product evaluations are summarized in the Safe Needle Administrative Log.

Keep in mind safety needles aren't always appropriate. If they aren't just make sure you have documentation showing why they weren't appropriate for your use. One final point if you aren't using safety needles is to not recap needles unless you have to. 

Identify and ensure the use of work practice controls. These are practices that reduce the possibility of exposure by changing the way a task is performed, such as appropriate practices for handling and disposing of contaminated sharps, handling specimens, handling laundry, and cleaning contaminated surfaces and items.

Unless you're using safety needles that have built-in safety features, don't recap needles unless you have to. Some specialties like dentistry, have no other option but to recap.This should be accomplished through a mechanical method like a recapping device or a single hand scoop method. Under no circumstances should needles ever be capped hand to hand. Point of origin disposal is another important work practice control. This is the concept of disposing of needles and biomedical waste in the area where it was  generated. 

Provide personal protective equipment (PPE), such as gloves, gowns, eye protection, and masks. Employers must clean, repair, and replace this equipment as needed. Provision, maintenance, repair and replacement are at no cost to the worker.

PPE should be available to all at-risk employees. It should be sized appropriately and if required, address any personal concerns like a latex allergy. Non-disposable items that are designed to be a barrier garment, like a lab coat or a jacket worn over scrubs during a procedure need to be laundered and maintained by the employer. Employees should not take these items home. These requirements are also addressed in your exposure control plan.

Make available hepatitis B vaccinations to all workers with occupational exposure. This vaccination must be offered after the worker has received the required bloodborne pathogens training and within 10 days of initial assignment to a job with occupational exposure.

Any employee that has the risk of occupational exposure to blood needs to be offered the vaccination series. This would include most clinical positions and in some small practices it could include non-clinical employees like a front desk employee that occasionally helps out with patient care or is asked to clean exam rooms or operatories. 

If you hire someone and they've been vaccinated already, your obligation has been fulfilled. Get them to bring documentation or have them sign the appropriate forms that acknowledge having been previously vaccinated. This is the first form at the back of our red OSHA manual. At-risk employees that haven't been vaccinated should be encourage to get vaccinated. OSHA enforces the current CDC recommendations for healthcare workers that requires a 3 dose series administered over 6 months. 1-2 months after completion the employee should have a titer test (blood test) to determine antibody conversion. The vaccination is 95% effective and considered lifelong immunity. Documentation of Hepatitis B vaccinations is really important. This should be done at the time of hire and reviewed periodically to make sure all clinical employees have  their record or acceptance/declination form signed.

Make available post-exposure evaluation and follow-up to any occupationally exposed worker who experiences an exposure incident. An exposure incident is a specific eye, mouth, other mucous membrane, non-intact skin, or parenteral contact with blood or OPIM. This evaluation and follow-up must be at no cost to the worker and includes documenting the route(s) of exposure and the circumstances under which the exposure incident occurred; identifying and testing the source individual for HBV and HIV infectivity, if the source individual consents or the law does not require consent; collecting and testing the exposed worker’s blood, if the worker consents; offering postexposure prophylaxis; offering counseling; and evaluating reported illnesses. The healthcare professional will provide a limited written opinion to the employer and all diagnoses must remain confidential.

If there's a needlestick or exposure incident the employee has the right to immediate medical attention. If known, the source patient should be asked to consent to a blood test. They have the right to refuse, but if you explain the situation and offer to pay in many cases they will consent. OSHA requires you ask the source patient. The Consent to Blood Testing form should be completed indicating their choice. If they consent, results should be provided confidentially. In most cases the results will be negative and that's the extent of testing and the employers responsibility. If the source patient is unknown or doesn't consent testing will normally include a baseline and a follow-up at 6 months at a minimum. Most bloodborne pathogens take 10-14 days to manifest so the baseline is usually just that. A full description of employers responsibilities should be included in your exposure control plan.

Use labels and signs to communicate hazards. Warning labels must be affixed to containers of regulated waste; containers of contaminated reusable sharps; refrigerators and freezers containing blood or OPIM; other containers used to store, transport, or ship blood or OPIM; contaminated equipment that is being shipped or serviced; and bags or containers of contaminated laundry, except as provided in the standard. Facilities may use red bags or red containers instead of labels. In HIV and HBV research laboratories and production facilities, signs must be posted at all access doors when OPIM or infected animals are present in the work area or containment module.

Typically if something contaminated with blood or infectious material it should be identified with the biohazard symbol. Any state approved sharps container or red bag would have the biohazard symbol and other warnings. Contaminated laundry or equipment should be identified.

Provide information and training to workers. Employers must ensure that their workers receive regular training that covers all elements of the standard including, but not limited to: information on bloodborne pathogens and diseases, methods used to control occupational exposure, hepatitis B vaccine, and medical evaluation and post-exposure follow-up procedures. Employers must offer this training on initial assignment, at least annually thereafter, and when new or modified tasks or procedures affect a worker’s occupational exposure. Also, HIV and HBV laboratory and production facility workers must receive specialized initial training, in addition to the training provided to all workers with occupational exposure. Workers must have the opportunity to ask the trainer questions. Also, training must be presented at an educational level and in a language that workers understand.

Clinical and other at-risk employees need to be trained annually on the fundamentals of the Bloodborne Pathogen Standard. Annual OSHA training is a good time to tackle state training requirements for biomedical waste management and disposal as well since many of the same concepts apply to one another. Training records need to be maintained for 3 years.

Maintain worker medical and training records. The employer also must maintain a sharps injury log, unless it is exempt under Part 1904 -- Recording and Reporting Occupational Injuries and Illnesses, in Title 29 of the Code of Federal Regulations.

This would include Hepatitis B Vaccinations, Sharps Injury Log and other injuries. These need to be kept for 30 years plus time of employment.

If you have any doubts about your compliance or obligations under OSHA's Bloodborne Pathogen Standard don't hesitate to call us. Our Deluxe OSHA System is our best seller and includes our 2020 OSHA Manual for Medical Offices or Dental Offices, OSHA Training Package, posters, updates, toll-free phone support and more for one low-price.

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