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Compliance

Bloodborne Pathogens

PURPOSE

The bloodborne pathogens standard protects workers who come in contact with blood or potentially infectious material in the course of their job duties.

HISTORY

In 1991, OSHA created a bloodborne pathogens standard, or a standard concerning disease-causing microorganisms present in human blood, to decrease the risk of occupational exposure to dangerous viruses and diseases. OSHA updated the standard in 2001 in response to the Needlestick Safety and Prevention Act. The standard has undergone subsequent revisions to refine definitions, correct typographical errors, and renumber sections.

APPLICABILITY TO BYU–HAWAII

The bloodborne pathogens standard (BPS) applies to all BYU–Hawaii employees, including student employees, who have potential occupational exposure to human blood or other potentially infectious materials.7 BYU–Hawaii’s Health Center provides information and checklists for complying with the BPS.

REQUIREMENTS

Under federal law, an employer is required to provide employees with a workspace that is free from recognized hazards and to follow occupational safety and health standards (i.e., BPS). Federal regulations attempt to reduce the likelihood of an employee’s occupational exposure to these pathogens through the institution of controls.10 The regulations broadly define occupational exposure as “reasonably anticipated . . . contact with blood or other potentially infectious materials that may result from the performance of an employee’s duties.”

Exposure Control Plan

The BPS requires employers to establish an exposure control plan, which is a written plan to eliminate or minimize occupational exposure. The control plan must be reviewed and updated at least annually to reflect new tasks or procedures and new employee positions. In addition, the employer must annually document any consideration and implementation of commercially safer medical devices that may eliminate or reduce exposure to bloodborne pathogens. In preparing the plan, employers must also solicit and document opinions from non-managerial employees who are responsible for direct patient care and could potentially be exposed to injuries from contaminated sharps.

As part of the plan, the employer must prepare an exposure determination. This document should include a list of job classifications in which employees have occupational exposure or reasonably anticipated contact with a bloodborne pathogen. The employer should also list all tasks and procedures in which occupational exposure occurs. All exposure determinations should be made without regard to the use of personal protective equipment.

A copy of the exposure control plan must be made available to employees. If an employee requests access, the employer must provide the plan “in a reasonable time, place, and manner.” If access cannot be given within fifteen days, the employer must explain the reason for the delay. In addition, the exposure control plan must be made available to the OSHA assistant secretary of labor and the director of National Institute for Occupational Health and Safety upon request.

Safety Precautions

Universal safety precautions should be observed, and any undefined body fluid types should be considered potentially infectious material. Work practices should be established and used to minimize employee exposure to fluids, and these controls must be examined and maintained or replaced on a regular basis. Required controls include the following:

Hand Washing Facilities

An employer shall provide readily accessible hand washing facilities until it is not feasible, in which case the employer must provide either an antiseptic hand cleanser / clean cloth combination or provide antiseptic towelettes. The employer must ensure that employees wash their hands or affected skin immediately after removing personal protective equipment or after contacting a potentially infectious material.

Sharps

Sharps are defined as objects that can penetrate the skin and include needles, scalpels, broken glass, or exposed ends of dental wires. Contaminated sharps should never be bent, recapped, removed, sheared, or broken, unless no other alternative is feasible and it is done with the use of a mechanical device or a one-handed technique. If a contaminated sharp is reusable, it should be placed immediately in an appropriate container until properly reprocessed. The container must be puncture resistant, labeled or color-coded, leak proof on the sides and bottoms, and stored to prevent employees having to reach in a container by hand.

Prohibited Activities and Procedures

Procedures involving blood or potentially infectious materials should minimize splashing, spraying, spattering, and the generation of droplets. Mouth pipetting or suctioning of such materials is prohibited.

Employees should never eat, drink, smoke, apply cosmetics or lip balm, or handle contact lenses within designated work areas. Food and drink should not be kept in the same refrigerator, freezer, shelf, or cabinet, or on the same countertop or bench top as potentially infectious materials.

Storage and Transportation

Specimens of blood or other potentially infectious material must be placed in containers that prevent leakage, specifically during collection, handling, processing, storing, transporting, and shipping. The containers must be labeled or color-coded and placed within a second container if leakage occurs or is probable. Equipment that is contaminated prior to shipping must be decontaminated as much as possible and have an observable label. The employer must convey this information to appropriate persons prior to handling, servicing, or shipping.

Personal Protective Equipment

If occupational exposure is still possible when all available controls are in place, employees must be provided with personal protective equipment that does not permit potentially infectious material to pass through to the employee. Personal protective equipment may include gloves, gowns, laboratory coats, face shields, masks, eye protection, mouthpieces, resuscitation bags, pocket masks, or other ventilation devices. The employer must ensure the equipment is used properly and that appropriate sizes are readily accessible to employees. The employer must provide, clean, dispose, repair, and replace protective equipment at no cost to the employee.

The employee should remove all equipment before leaving the work area49 and place it in an appropriately designated area for storage, washing, decontamination, or disposal. If blood or another potentially infectious material penetrates a garment, the employee should remove the garment as soon as possible.

Gloves

Employees should be provided with gloves as part of their personal protective equipment and wear the gloves whenever they anticipate contact with blood or other potentially infectious material. Alternative glove types (e.g., hypoallergenic gloves, glove lines, powderless gloves) should be accessible to employees with allergies. Disposable gloves should be used only once and should be replaced as soon as possible if compromised (e.g., torn, punctured). Utility gloves may be decontaminated and reused if the integrity is not compromised.

Masks, Eye Protection, Face Shields

Masks must be used with eye protection devices (e.g., goggles) if there is the possibility of splash, spray, or spatter of blood or other materials and it may reach an employee’s eye, nose, or mouth.

Protective Body Clothing

Gowns, aprons, or other outer garments must be worn depending on the task and degree of exposure anticipated. Surgical caps or hoods and shoe covers or boots must be worn in instances of gross contamination.

Housekeeping

The employer must maintain a clean and sanitary workplace by implementing a written schedule for cleaning and decontaminating the facility. All equipment and work surfaces must be decontaminated after contact with blood or other potentially infectious material. Protective coverings must also be replaced when contaminated. Bins, pails, cans, or other receptacles must be regularly inspected for contamination, and if found, cleaned or replaced immediately. Broken glassware should be picked up by mechanical means—never directly with hands.

Regulated waste must be placed in closable containers that prevent leakage, are labeled or color-coded, and are closed prior to removal.

Contaminated laundry should be handled as little as possible and should be placed in leak-proof bags or containers and labeled or color-coded.

Vaccinations and Follow-up Procedures

An employer subject to the BPS must make the hepatitis B vaccination series available to any employee at no personal cost and within ten working days of initial assignment, unless the employee has previously received the vaccination. A prescreening program cannot be required before the vaccination is offered, and the vaccination must continue to be made available even if the employee declines it initially. If the employee does decline the vaccination, he or she must sign a waiver.

Any employee who is exposed to blood or another potentially infectious material must be able to immediately have a confidential medical evaluation and follow-up. This examination must come at no personal cost to the employee. Evaluation must include documentation of the routes of exposure and circumstances of the incident, identification of the source individual, and blood testing. Results of the source individual’s testing, if received through consent, shall be provided to the exposed employee. The evaluation must include prophylaxis, or additional measures designed to preserve health and prevent the spread of disease, as recommended by the U.S. Public Health Service. Counseling must also be made available to the employee.

The employer must provide the healthcare professional responsible for the vaccine or evaluation a copy of the federal bloodborne pathogens regulation. The evaluating professional must also be provided a description of the employee’s duties, documentation of the route of exposure, and relevant medical records. The employer must provide the employee with the healthcare professional’s written opinion within fifteen days of the evaluation. All other components of the examination outside the written report are confidential.

Training

The employer must train all employees with occupational exposure on the bloodborne pathogen standards at the time of initial assignment to the task and annually thereafter. Training must be free and provided during work hours. Additional training must be given when there are changes made to procedures and tasks. Training material must be commensurate with the education level and language skills of the employees83 and should contain the following elements:

  • A copy and explanation of the regulatory text;
  • An explanation of epidemiology and the symptoms of bloodborne diseases;
  • An explanation of the modes of transmission of bloodborne diseases;
  • An explanation of the employer’s exposure control plan and the means for obtaining a copy;
  • An explanation of the methods used to prevent or reduce exposure;
  • An explanation of engineering controls, work practices, and personal protective equipment;
  • Information on the types, proper use, location, removal, handling, decontamination, and disposal of personal protective equipment;
  • An explanation on selecting personal protective equipment;
  • Information on the hepatitis B vaccine;
  • Information on appropriate actions and people to contact in an emergency involving blood or potentially infectious material;
  • An explanation of the procedure to follow if exposure occurs, including reporting and medical follow-up;
  • Information on post-exposure evaluation and follow-up;
  • An explanation of the signs and labels and / or color-coding system; and
  • An opportunity for interactive questions with the person conducting the training.

If an employee performs work in a human immunodeficiency virus (HIV) or hepatitis B virus (HBV) laboratory, then additional training requirements apply:

  • The employer must assure the employee’s proficiency in standard microbiological practices and techniques;
  • The employee must assure the employee’s experience in handling human pathogens or tissue cultures;
  • If the employee has no prior experience, the employer will train him or her and provide needed experience.

HIV and HBV Labs

Additional requirements exist for research laboratories and production facilities engaged in the culture, production, concentration, experimentation, and manipulation of HIV and HBV. All regulated waste from these facilities must be either incinerated or decontaminated by a method known to destroy bloodborne pathogens (i.e., autoclaving). Laboratory doors must be kept closed while work with HIV or HBV is in progress, and the area must be limited to authorized persons. There must be a hazard warning sign on the door when infectious material or infected animals are present. Activities cannot be performed on an open bench, but must be conducted inside biological safety cabinets or other physical containment devices. Vacuum lines must be protected with liquid disinfectant traps and HEPA air filters, and all spills must be immediately cleaned up and reported to the laboratory director, if exposure occurs. A biosafety manual must be prepared and reviewed at least annually, and personnel must be advised of potential hazards and required to read instructions on procedures. Certified biological safety cabinets should be used for all activities with potentially infectious materials that pose a threat of exposure. Biological safety cabinets should be certified when installed, when moved, and at least annually.

Records

The employer must maintain accurate medical records for every employee with occupational exposure. This includes the employee’s name; social security number; hepatitis B vaccination status; and any examination results, written opinions, and information provided to a healthcare professional. Employee medical records must be kept confidential.

Employers must also keep training records that include the dates of training sessions, contents and summaries of the sessions, names and qualifications of the people conducting the session, and the names and job titles of people attending the sessions. Training records must be maintained for three years.

The employer must maintain a sharps injury log that records injuries from contaminated objects that can penetrate the skin; the log should reflect the type and brand of device involved, the department or work area where the exposure incident occurred, and an explanation of how the incident occurred. The sharps injury log must be maintained for five years.

COMPLIANCE CALENDAR

10 Days

An employer must make the hepatitis B vaccination series available to new employees within ten days of the employee’s initial assignment, unless the vaccination has already been received.

15 Days

If requested, an employer has fifteen days to provide an employee with the exposure control plan or explain the delay in providing it. Employers also must provide an employee who undergoes a medical evaluation for exposure with a written opinion from the doctor within fifteen days of the evaluation.

Annually

The exposure control plan must be reviewed and updated every year,
and employers must document their consideration and implementation of commercially safer medical devices to reduce exposure. Additionally, employees must be trained on the bloodborne pathogens standard upon initial assignment and at least annually thereafter. An employer with HIV and HBV labs must also certify biological safety cabinets and review its biosafety manual annually.