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Bloodborne Pathogen Requirements in Manufacturing and Service Industries

Bloodborne Pathogen Danger at Work

It’s 3:30PM and you are at home in bed with the sniffles, a sore throat, and runny nose. Suddenly your cellphone rings. It’s your boss. There’s a problem at work. Your heart sinks.

Hi,” you say in a raspy voice, “what’s happening?”

Your boss explains that there was an accident. A contractor cut himself trailing blood through the building and into a restroom, leaving behind some bloody rags and a bloody glove. “What do we need to do?”

Your first thought is, Why is he bothering me? But then your inner safety professional kicks in and you answer yourself: because there is nobody else who has any training under the OSHA 29 CFR 1910.1030 Bloodborne Pathogens Standard. Hmm, what to do?

Who Needs Bloodborne Pathogens Training?

When we review the regulations, we find that 1030(g)(2) discusses who needs to be trained and “all employees with occupational exposure” are required to participate in a training program by financed by their employer and receive annual Bloodborne Pathogens Certification.

These employees have a requirement to act. These employees can include healthcare workers, laboratory workers, and full-time emergency services employees like police, first responders or fire.

The standard does not discuss employees who may have incidental or accidental exposures to blood or human bodily fluids.

OSHA’s Bloodborne Pathogens information site mentions first aid teams and housekeeping personnel, but nowhere is there a reference to the obligations for training if their exposures are not required, for example a voluntary first aid team; or about manufacturing locations or service companies where blood or body fluids are rarely encountered.

Blood Spill

Developing an Exposure Plan

Companies in health care settings or laboratories where blood or bodily fluids are used or stored already have exposure plans. Their employees have received training for many years now. Everybody else – those who work in the chemical field, paper converting, plastics, the textile industry, retail and the services sector – probably haven’t considered what to do in the event an incident that leaves blood or bodily fluids to be cleaned up.

Recommendation:

Although it is not required, you should develop your own Bloodborne Pathogens Program. Like any OSHA program, it needs to be in writing and to be communicated to those who need to know.

Make copied available at key locations and conduct training. Modify the plan if you discover parts that do not fully address your organization’s needs and requirements.

Some sections that should be in your program include:

  1. Awareness training program. This program could be short, ideally less than an hour. It tells all employees that, if someone has an accident and is bleeding, here’s what you need to do to help them and to protect yourself.

It should include universal precautions (putting an impervious barrier between you and the blood or fluid) and a brief introduction to first aid. Also, it should state which employees should be notified if there is an incident. This is also a good time to remind employees they must report all incidents to their supervisor or other responsible official immediately.

  1. Training program for maintenance and janitorial personnel. Employees who have to clean up floors or equipment that becomes contaminated require Bloodborne Pathogens training. Provide instructions on what to do in the event of a blood-related incident. What type of protective clothing or gowning do they need, and which cleanup solutions are to be used? Have them do a table-top exercise or a practice session to ensure they are performing correctly.
  2. Cleanup plan. This part of the plan can be a checklist so that employees involved in performing a cleanup know where they get PPE, which solutions they need to make, how to use those solutions, and how to package the waste materials for disposal.
  3. Disposal plan. This section discusses what to do with the waste materials after the cleanup. If yours is a company whose employees who have “occupational exposures,” then you are probably a registered generator of medical wastes. If that is the case, then disposal of this type of cleanup material is placed into your medical waste disposal stream.

Other companies are probably not registered medical waste generators. For these companies there are a couple of options, depending on what your state regulations allow. For example, ask ambulance staff to take the medical wastes with them for proper disposal. Another option is to request a one-time exemption (depending on your state) to have wastes picked up by a licensed medical waste transporter. This option doe stake time and you would need to store the wastes on site until you received approval from regulators.

Regardless of the option selected, you should develop these plans and work on receiving approvals and letters of understanding before an incident occurs.

  1. Exposure plan.You have all of the other items under control, but an employee is exposed to blood or bodily fluids. This section of the plan discusses how to decontaminate that employee and the medical surveillance procedures that must be followed to ensure the employee who was contaminated is tested and counseled so they understand what has happened and the risk of infection from any disease. This section must comply with the requirements of 29 CFR 1910.1030(c), Exposure Control, and (h), Recordkeeping.

We never expect accidents of this type to happen in our workplaces. But with pre-planning and training, we will be prepared to handle the situation correctly and safely.

First Aid Teams

Your company has a volunteer first aid team. What must you do for it? The standard does not address the issue. But an OSHA Compliance document (CPL 2-2.69) and a Letter of Interpretation (3/23/01) do.

If employees are assisting on a voluntary basis i.e., they do not have an occupational requirement to act, but rather are acting as “Good Samaritans” then they are not covered under the bloodborne pathogen standard, but “employers are encouraged to provide coverage to them,” according to the letter of interpretation.

The company needs to develop an exposure control plan that includes the first aid team. It also should provide Hepatitis B vaccinations to these employees. The OSHA compliance document states, “An employee who routinely provides first aid to fellow employees with the knowledge of the employer may also fall, de facto, under this designation even if the employer has not officially designated this employee as a first aid provider.” (XIII A.4.c.)

References

  1. 29 CFR 1910.1030 Bloodborne Pathogens
  2. CPL 2-2.69 – Enforcement Procedures for Occupational Exposure to Bloodborne Pathogens
  3. Standard Interpretation – Coverage of the BBP standard for Good Samaritan acts and personal medical conditions, March 23, 2001.
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