For tattooists and body artists, accidental exposure to bloodborne pathogens is a constant risk. For this reason bloodborne pathogen training is a must.
Bloodborne pathogens are infectious microorganisms in the blood that can cause diseases like Hepatitis B (HBV), Hepatitis C (HCV) and HIV. Both employees and clients in a body art workplace or tattoo studio who become exposed to these pathogens are at risk.
If you are just starting out you may be wondering how do I get a tattoo license?
The Occupational Safety and Health Administration (OSHA) provides guidance through the Bloodborne Pathogens Standard.
Employers and body art studio owners can find the requirements in Title 29 of the Code of Federal Regulations at 29 CFR 1910.1030.
These requirements let employers know what they need to do to protect their workers who may be exposed to blood or other infectious materials (OPIM).
Now, let’s review the OSHA Bloodborne Pathogens Standard, and your responsibilities as an employer in the body art industry.
Employer Responsibilities Under the OSHA Bloodborne Pathogens Standard
The OSHA Bloodborne Pathogens Standard requires employers, and that includes body art and tattoo studio owners, to establish, update, and implement a plan to reduce occupational exposure. This is a requirement for all employers but there are some specifics to the body art workplace that you need to be aware of.
For more information on other occcupations and industries that require bloodborne pathogen training see this article.
Establish an Exposure Control Plan in a Body Art Studio
A crucial part of the OSHA Bloodborne Pathogens Standard is the bloodborne pathogens exposure control plan. The exposure control plan is always a written plan.
The purpose of the plan is to minimize or, hopefully completely eliminate occupational exposure. As a body art studio owner or manager, you must prepare this plan.
This plan must contain a list of your employees job classifications that have potential occupational exposure. In a body art workplace, this is likely to be all staff who are onsite. The list should also contain the procedures and other tasks performed by those workers that may result in their exposure
Annual Plan Update
As explained in the OSHA Bloodborne Pathogens Standard, you are required to update the bloodborne pathogens exposure control plan once per year.
By doing this, you reflect any changes in the procedures, tasks, and roles that relate to occupational exposure. You must also document any changes in equipment that either reduce or eliminate occupational exposure.
Have you consulted with your artists to identify, evaluate, and select effective work practices? If so, then document those as well.
Implement Universal Precautions
Following the OSHA Bloodborne Pathogens Standard, all employees should apply universal precautions while on the job. Universal precautions direct that all blood and human body fluids must be treated as if they are infectious.
Implementing universal precautions means doing the following:
Identifying and Using Engineering Controls
Engineering controls are devices for facilitating isolation and removal of bloodborne pathogens from a work environment.
Engineering controls include things like self retracting needles, needle guards, safe sharps disposal containers and self-sheathing needles.
They also include devices that relate to piercing and tattooing.
Identifying and Ensuring Use of Work Practice Controls
So, we know the importance of engineering controls, and that OSHA takes them pretty seriously. The Bloodborne Pathogens Standard also states that the correct use of work practice controls lower the chances of exposure by changing how employees perform the task.
This includes appropriate practices for handling and disposing of contaminated sharps. It also includes handling laundry, specimens, and contaminated surfaces and inks, pots and other tattoo equipment.
Providing Personal Protective Equipment (PPE) Suitable for a Body Art Workplace
The OSHA Bloodborne Pathogens Standard focusses heavily personal protective equipment or PPE. PPE most commonly needed in tattoo studios includes aprons, gloves, eye protection, and masks.
As the employer, you are responsible for the cleaning, repair, and replacement of required tattoo PPE as needed. You must replace PPE at no cost to your employees.
Making Hepatitis B Vaccinations Available
The OSHA Bloodborne Pathogens Standard dictates that employers must provide Hepatitis B vaccinations and these must be available to any and all employees who have occupational exposure risk.
This vaccination has to be offered after your employee receives the mandatory required bloodborne pathogens training.
Bloodborne pathogen training must take place within 10 days of the employee’s initial assignment to a position with occupational exposure. This is likely to mean any position in a body art studio as the workplace itself carries inherent exposure risk.
Making Post-Exposure Evaluation and Follow-Up Available
Even with precautions in place, exposure incidents do still occur. When this inevitably does happen, any occupationally-exposed worker who experiences an exposure incident must have a post-exposure evaluation.
An exposure incident is always deemed to be specific in nature. For this reason the OSHA Bloodborne Pathogens Standard defines an exposure incident and requires an evaluation with follow up.
An occupational exposure incident happens when parenteral contact is made with blood or OPIM. This contact can also be to the mouth, eyes, broken skin, or any mucous membrane.
The evaluation and follow-up must be free of cost to the employee and includes a requirement to document the route or routes of exposure. This includes the details of how the exposure incident occurred.
You must also identify and test the employee for HIV and HBV. You must also offer counseling, post-exposure prophylaxis treatment, and evaluation of any reported illnesses.
The treating healthcare professional will provide a written opinion regarding the OSHA bloodborne pathogens test to the employer. All diagnoses remain confidential.
Using Signage and Labels to Communicate Hazards
Proper labeling is a high priority under the OSHA Bloodborne Pathogens Standard. Employers must fix warning labels to containers that hold, reusable sharps, regulated waste and freezers and refrigerators and that contain blood or OPIM.
Warning labels also apply to containers used to store or transport blood or OPIM. Any contaminated equipment you are servicing or shipping such as tattoo guns, foot pedals or other equipment must also have labels. The same applies to bags of contaminated laundry.
Some facilities use red containers or red bags instead of labels.
Providing Information and Training
In addition to the initial training you provide new employees, you must also ensure that workers receive regular training on the OSHA Bloodborne Pathogens Standard. This includes information on bloodborne pathogens and diseases.
It also includes the methods used to control occupational exposure and administer the Hepatitis B vaccine.
Employees must receive regular bloodborne pathogen training so they stay familiar with medical evaluation and post-exposure follow-up procedures.
You must offer this training upon the employee’s initial assignment and annually thereafter. You must also offer training when the employee has new or modified tasks or procedures that relate to occupational exposure. An example of this in the in a tattoo studio could be when a cashier or intern becomes an apprentice artist, or when a tattoo artist also begins conducting body piercing procedures.
Employees should have the opportunity to ask the trainer any questions. Also, the training should be at the appropriate level and language for the attending employees. This is an important point that is often overlooked, particularly if medical trainers are engaged to deliver training.
OSHA Bloodborne Pathogens Training Tattoo & Body Art Specific Coverage
Some of the topics included in OSHA Bloodborne Pathogens Body Art Professional training should be the following:
- Introduction to bloodborne pathogens
- Identifying bloodborne diseases
- How pathogens are spread and transmitted
- OSHA requirements
- Exposure control plan
- Occupational exposure versus exposure incident
- Displaying warning signs and labels
- Proper use of PPE for Body Artists
- General Requirements in a body art workplace
- Cleaning, Disinfection and Sterilization
- Safe Disposal of Biohazard Waste in a Body Art Workplace
- HBV Vaccination program
- Emergency/Exposure control procedures
- What to do when an exposure incident occurs
- Post exposure requirements
Maintaining Medical and Training Records
Employees are required to maintain a sharps injury log, unless it falls under the exemption listed in Part 1904 –Recording and Reporting Occupational Injuries and Illnesses, in Title 29 of the Code of Federal Regulations.
As a note, one of the exemptions is for companies with fewer than ten employees, which may well apply to many body art establishments and tattoo studios, however please fully reviewthe relevant OSHA code to understand the defintions and application of this expemtion.
This article presented an overview of the OSHA Bloodborne Pathogen Standard specifically related to body art working environments. For more information on the standard, see the OSHA’s Bloodborne Pathogens Quick Reference Sheet.
As an employer, you are responsible for ensuring that the proper procedures, policies, and training are in place as required by the standard.
If you need OSHA’s Bloodborne Pathogen for Tattoo artist training for your staff please click on the Group Training link in the menu.
You can check this article more information on training requirements for microblading artists.