Workplace Bloodborne Pathogens

Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens Part 1

noreply@blogger.com (NSCsafety) — Tue, 22 May 2012 19:44:00 +0000

Directive Number: CPL 02-02-069 (formerly CPL 2-2.69)	Effective Date: November 27, 2001
Subject: Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens

ABSTRACT

Purpose:	This instruction establishes policies and provides clarification to ensure uniform inspection procedures are followed when conducting inspections to enforce the Occupational Exposure to Bloodborne Pathogens Standard.
Scope:	This instruction applies OSHA-wide.
References:	29 CFR 1910.1030, Occupational Exposure to Bloodborne Pathogens OSHA Instruction CPL 2.103, Field Inspection Reference Manual
Cancellations:	This instruction cancels CPL 2-2.44D
State Impact:	This instruction describes a Federal Program Change for which State adoption is not required (See Paragraph VI).
Action Offices:	National, Regional and Area Offices
Originating Office:	Directorate of Compliance Programs
Contact:	Office of Health Compliance Assistance (202)693-2190 200 Constitution Avenue, Room N3603 Washington, DC 20210

By and Under the Authority of
John L. Henshaw
Assistant Secretary

TABLE OF CONTENTS

Purpose
Scope.
Cancellation
References.
Action.
Federal Program Change.
Background.
Inspection Scheduling, and Scope.
General Inspection Procedures

Purpose. This instruction establishes policies and provides clarifications to ensure uniform inspection procedures are followed when conducting inspections to enforce the Occupational Exposure to Bloodborne Pathogens Standard.
Scope. This instruction applies OSHA-wide.
Cancellation. This instruction cancels OSHA Instruction CPL 2-2.44D, Nov. 5, 1999.
References.
1. OSHA Instruction, CPL 2.103, September 26, 1994, Field Inspection Reference Manual (FIRM).
2. OSHA Instruction CPL 2.111, November 27, 1995, Citation Policy for Paperwork and Written Program Violations.
3. OSHA Instruction, CPL 2-2.30, November 14, 1980, Authorization of Review of Medical Opinions.
4. OSHA Instruction, CPL 2-2.32, January 19, 1981, Authorization of Review of Specific Medical Information.
5. OSHA Instruction, CPL 2-2.33, February 8, 1982, Rules of Agency Practice and Procedure Concerning OSHA Access to Employee Medical Records-Procedures Governing Enforcement Activities.
6. OSHA Instruction, CPL 2-2.46, January 5, 1989, Authorization and Procedures for Reviewing Medical Records.
7. OSHA Instruction, PER 8-2.4, March 31, 1989, CSHO Pre-Employment Medical Examinations.
8. Centers for Disease Control Morbidity and Mortality Weekly Report: "Public Health Service Guidelines for the Management of Health-Care Worker Exposures to HIV and Recommendations for Postexposure Prophylaxis." May 15, 1998; Vol. 47, No. RR-7.
9. Centers for Disease Control Morbidity and Mortality Weekly Report: "Recommendations for Follow-Up of Health-Care Workers After Occupational Exposure to Hepatitis C Virus". July 4, 1997; Vol. 46, No. 26.
10. Record Summary of the Request for Information (RFI) on Occupational Exposure to Bloodborne Pathogens due to Percutaneous Injury. May 20, 1999.
11. Safer Needle Devices: Protecting Health Care Workers, Directorate of Technical Support, Office of Occupational Health Nursing, October 1997.
12. Needlestick Injuries Among Health Care Workers: A Literature Review, Directorate of Technical Support, Office of Occupational Health Nursing, July, 1998.
13. International HealthCare Worker Safety Center, #407, Health Sciences Center, University of Virginia, Charlottesville, VA 22908, EPINet, Exposure Prevention Information Network, E-mail: epinet@virginia.edu.
14. DHHS, Public Health Service, "FDA Safety Alert: Needlestick and Other Risks from Hypodermic Needles on Secondary IV Administration Sets - Piggyback and Intermittent IV", April 16, 1992.
15. Glass Capillary Tubes: Joint Safety Advisory About Potential Risks, OSHA/NIOSH/FDA, February, 1999 and Memorandum dated February 18, 1999, from Steve Witt to the Regional Administrators.
16. NIOSH, "Selecting, Evaluating, and Using Sharps Disposal Containers", DHHS (NIOSH) Publication No. 97-111, January 1998.
17. Centers for Disease Control, MMWR, October 16, 1998/Vol.47/No. RR-19 "Recommendations for Prevention and Control of Hepatitis C Virus (HCV) Infection and HCV-Related Chronic Disease."
18. Centers for Disease Control, American Journal of Infection Control, June 1998, Vol. 26, "Guideline for Infection Control in Health Care Personnel, 1998."
19. Centers for Disease Control, MMWR, December 26, 1997, Vol.46, No.RR-18, Immunization of Health-Care Workers: Recommendations
20. 29 CFR Part 1910.1030, Occupational Exposure to Bloodborne Pathogens; Final Rule, Federal Register/Vol.56, No.235/ December 6, 1991.
21. Training for Development of Innovative Control Technology Project, "Safety Feature Evaluation Forms".
22. 29 CFR Part 1910.1030, Occupational Exposure to Bloodborne Pathogens; Needlesticks and Other Sharps Injuries; Final Rule, Federal Register/Vol.66, No. 12/ January 18, 2001.
23. Centers for Disease Control, MMWR, June 29, 2001, Vol.50, No.RR-11, Updated U.S. Public Health Service Guidelines for the Management of Occupational Exposures to HBV, HCV, and HIV and Recommendations for Postexposure Prophylaxis.
Action. OSHA Regional Administrators and Area Directors should use the guidelines in this instruction to ensure uniform enforcement of the Bloodborne Pathogens Standard. The Directorate of Compliance Programs will provide support necessary to assist the Regional Administrators and Area Directors in enforcing the Bloodborne Pathogens Standard.
Federal Program Change. This instruction describes a federal program change for which State adoption is not required. On April 19, 2001, OSHA notified the state plan states of the requirement to adopt revisions to the Bloodborne Pathogens Standard by October 18, 2001. In order to effectively enforce safety and health standards, guidance to compliance staff is necessary. Therefore, although adoption of this instruction is not required, states are expected to have standards, enforcement policies and procedures which are at least as effective as those of Federal OSHA.
1. Preemption. A number of states have enacted state "needlestick" laws which apply to the public sector, the private sector or both. The issuance of OSHA's revised Bloodborne Pathogens Standard has raised questions as to the status of those State laws. Section 18 of the OSH Act expresses Congress' intent, as reaffirmed by the U.S. Supreme Court in Gade v. National Solid Wastes Management Assoc. [505 U.S. 19, 107 (1992)], to preempt state laws relating to issues in the private sector on which Federal OSHA has promulgated occupational safety and health standards, such as the Bloodborne Pathogens Standard, regardless of whether the requirements are more or less stringent. Preemption is a complex legal matter which can only be finally resolved by the courts when raised by an affected party. OSHA does not take any formal legal or other action with regard to preemption of state activities. However, in general, the following principles apply:
  1. State Plan States. All OSHA-approved state plans are required to incorporate "at least as effective" needlestick protection for private sector and public sector (state and local government) employment, either through a standard or a state needlestick prevention law administered under the plan. To avoid the preemptive effect of Section 18 of the OSHAct, state needlestick prevention laws applicable to the private sector must be administered under the state plan, and in accordance with the enforcement provisions of the state OSHAct.
  2. States Without State Plans. State "needlestick" laws and/or regulations in these states would not be affected by the preemptive effect of the federal Bloodborne Pathogens Standard to the extent to which they regulate the occupational safety and health conditions of public sector (state and local government) employment. (See: Section 3(5) of the OSH Act; 29 CFR Parts 1952 and 1956; 66 FR 5323.) However, state laws or programs which regulate private sector activities addressed by the federal Bloodborne Pathogens Standard, absent an OSHA-approved state plan, would be subject to challenge as preempted.
Background. In September 1986, OSHA was petitioned by various unions representing healthcare employees to develop an emergency temporary standard to protect employees from occupational exposure to bloodborne diseases. The agency decided to pursue the development of a Section 6(b) standard and published a proposed rule on May 30, 1989.
1. The agency also concluded that the risk of contracting the hepatitis B virus (HBV) and human immunodeficiency virus (HIV) among members of various occupations within the healthcare sector required an immediate response and therefore issued OSHA Instruction CPL 2-2.44, January 19, 1988. That instruction was superseded by CPL 2-2.44A, August 15, 1988; subsequently, CPL 2-2.44B was issued February 27, 1990.
2. On December 6, 1991, the agency issued its final regulation on occupational exposure to bloodborne pathogens (29 CFR 1910.1030). Based on a review of the information in the rulemaking record, OSHA determined that employees face a significant health risk as the result of occupational exposure to blood and other potentially infectious materials (OPIM) because they may contain bloodborne pathogens. These pathogens include but are not limited to HBV, which causes hepatitis B; HIV, which causes acquired immunodeficiency syndrome (AIDS); hepatitis C virus; human T-lymphotrophic virus Type 1; and pathogens causing malaria, syphilis, babesiosis, brucellosis, leptospirosis, arboviral infections, relapsing fever, Creutzfeldt-Jakob disease, and viral hemorrhagic fever. The agency further concludes that these hazards can be minimized or eliminated by using a combination of engineering and work practice controls, personal protective clothing and equipment, training, medical surveillance, hepatitis B vaccination, signs and labels, and other provisions. Both the standard and CPL 2-2.44C became effective on March 6, 1992.
3. On September 9, 1998 OSHA published a Request for Information (RFI) on engineering and work practice controls used to eliminate or minimize the risk of occupational exposure to bloodborne pathogens due to percutaneous injuries from contaminated sharps. The responses indicated that safer medical devices along with training are the most effective means of reducing injury rates. A Summary of the comments received on response to the RFI was published in March 1999. On November 5, 1999 CPL 2-2.44D was issued. It incorporated information from the RFI, past interpretations and several CDC guidelines on vaccination and post-exposure prophylaxis.
4. On November 6, 2000 the Needlestick Safety and Prevention Act was signed into law (Public Law 106-430). It directed OSHA to revise the Bloodborne Pathogens standard to include new examples in the definition of engineering controls; to require that exposure control plans reflect changes in technology that eliminate or reduce exposure to bloodborne pathogens; to require employers to document annually in the exposure control plans consideration and implementation of safer medical devices; to require employers to solicit input from non-managerial employees responsible for direct patient care in the identification, evaluation, and selection of engineering and work practice controls; to document this input in the exposure control plan; and to require certain employers to establish and maintain a log of percutaneous injuries from contaminated sharps. OSHA published these revisions on January 18, 2001 with an effective date of April 18, 2001.
Inspection Scheduling, and Scope.
1. Inspection scheduling should be conducted in accordance with the procedures outlined in the FIRM (CPL 2.103), Chapter II, Inspection Procedures.
2. All inspections, programmed or unprogrammed, should include, if appropriate, a review of the employer's exposure control plan and employee interviews to assess compliance with the Bloodborne Pathogens standard.
3. Expansion of an inspection to areas involving the hazard of occupational exposure to blood or other potentially infectious materials (including on site healthcare units and emergency response or first aid personnel) should be performed when:
  1. The exposure control plan or employee interviews indicate deficiencies in complying with OSHA requirements, as set forth in 29 CFR 1910.1030 or this instruction.
  2. Relevant formal employee complaints are received which are specifically related to occupational exposure to blood or OPIM.
  3. A fatality/catastrophe inspection is conducted as the result of occupational exposure to blood or OPIM.
General Inspection Procedures. The procedures given in the FIRM, Chapter II, should be followed except as modified in the following sections:
1. Where appropriate, the facility administrator, as well as the directors of infection control, employee (occupational) health, training and education, and environmental services (housekeeping) will be included in the opening conference or interviewed early in the inspection.
2. The facility's sharps injury log and any other file of "incident reports" that document the circumstances of exposure incidents in accordance with the provisions in the exposure control plan, and any first aid log of injuries, should be reviewed. The compliance officer should ask for any other additional records that track bloodborne incidents. The compliance officer should review the most recent Part 1904 - Recording and Reporting Occupational Injuries and Illnesses regulations prior to citing recordkeeping violations. See Paragraph X below.
3. Compliance officers should take necessary precautions to avoid direct contact with blood or OPIM and should not participate in activities that will require them to come into contact with blood or OPIM. The CSHO should avoid direct contact with needles or other sharp instruments potentially contaminated with blood or OPIM. To evaluate such activities, compliance officers normally should establish the existence of hazards and adequacy of work practices through employee interviews and should observe them at a safe distance.
4. On occasions when entry into potentially hazardous areas is judged necessary, the compliance officer should be properly equipped as required by the facility as well as by his/her own professional judgment, after consultation with the supervisor, who should refer to OSHA's exposure control plan for further guidance.
5. Compliance officers should use appropriate caution when entering patient care areas of the facility. When such visits are judged necessary for determining actual conditions in the facility, the privacy of patients must be respected. Photos or videos are normally not necessary and in no event should identifiable photos be taken without the patient's consent.

Retraining "at least annually"

noreply@blogger.com (NSCsafety) — Tue, 08 May 2012 12:24:00 +0000

Dear Mr. Skinner:

Thank you for your letter to the Occupational Safety and Health Administration's (OSHA's) Directorate of Enforcement Programs (DEP). This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question not delineated within your original correspondence. You requested clarification on OSHA's interpretation of acceptable time lapse for "annual" training.

Scenario: Various OSHA standards address frequency of employee training. Some standards are very explicit on frequency, stating "no later than 12 months from the date of the previous training," while others simply state that training must be performed "at least annually."

Question: Could you please clarify OSHA's interpretation of training requirements and what is expected when training must be conducted "at least annually"?

Reply: You are correct in stating that the language may vary in certain OSHA standards. However, wherever OSHA standards require that employee training be conducted "at least annually," OSHA interprets that to mean that employees must be provided re-training at least once every 12 months (i.e., within a time period not exceeding 365 days.) This annual training need not be performed on the exact anniversary date of the preceding training, but should be provided on a date reasonably close to the anniversary date taking into consideration the company's and the employees' convenience in scheduling. If the annual training cannot be completed by the anniversary date, the employer should maintain a record indicating why the training has been delayed and when the training will be provided.

Please keep in mind that the term "at least annually" is generally regarded as indicating that circumstances which warrant more frequent training may occur. It is extremely important that employees are trained to protect themselves from all known workplace hazards, including new hazards which may result from changes in workplace practices, procedures, or tasks. For example, OSHA's bloodborne pathogens standard at 29 CFR 1910.1030(g)(2)(v), provides for "additional training when changes such as modification of tasks or procedures or institution of new tasks or procedures affect the employee's occupation exposure." More frequent training may also be required when employee performance suggests that the prior training was incomplete or not fully understood.

Thank you for your interest in occupational safety and health. We hope this provides the clarification you were seeking and apologize for any confusion the earlier documents may have caused. OSHA requirements are set by statute, standards, and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you may consult OSHA's website at http://www.osha.gov. If you have any further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190.

Sincerely,

Richard E. Fairfax, Director
Directorate of Enforcement Programs

New National Emphasis Program for Nursing/Residential Care Facilities

noreply@blogger.com (NSCsafety) — Fri, 06 Apr 2012 18:32:00 +0000

US Labor Department's OSHA announces new National Emphasis
Program for Nursing and Residential Care Facilities

The U.S. Department of Labor's Occupational Safety and Health Administration today announced a new National Emphasis Program for Nursing and Residential Care Facilities to protect workers from serious safety and health hazards that are common in medical industries. OSHA develops national emphasis programs to focus outreach efforts and inspections on specific hazards in an industry for a three-year period. Through this NEP, OSHA will target nursing homes and residential care facilities in an effort to reduce occupational illnesses and injuries.

In 2010, according to the department's Bureau of Labor Statistics, nursing and residential care facilities experienced one of the highest rates of lost workdays due to injuries and illnesses of all major American industries. The incidence rate for cases involving days away from work in the nursing and residential care sector was 2.3 times higher than that of all private industry as a whole, despite the availability of feasible controls to address hazards. The data further indicate that an overwhelming proportion of the injuries within this sector were attributed to overexertion as well as to slips, trips and falls. Taken together, these two categories accounted for 62.5 percent of cases involving days away from work within this industry in 2010. For this NEP, OSHA will target facilities with a days-away-from-work rate of 10 or higher per 100 full-time workers.

"These are people who have dedicated their lives to caring for our loved ones when they are not well. It is not acceptable that they continue to get hurt at such high rates," said Dr. David Michaels, assistant secretary of labor for occupational safety and health. "Our new emphasis program for inspecting these facilities will strengthen protections for society's caretakers."

Health care workers face numerous serious safety and health hazards, and the NEP will provide guidance to OSHA compliance staff on the policies and procedures for targeting and conducting inspections specifically focused on the hazards associated with nursing and residential care. These hazards include exposure to blood and other potentially infectious material; exposure to other communicable diseases such as tuberculosis; ergonomic stressors related to lifting patients; workplace violence; and slips, trips and falls. Workers also may be exposed to hazardous chemicals and drugs.

The NEP directive can be viewed at http://www.osha.gov/OshDoc/Directive_pdf/CPL_03-00-016.pdf*. Information for employers and employees in nursing homes and residential care facilities, including guidance on ergonomics and workplace violence, is available at http://www.osha.gov/SLTC/nursinghome/index.html.

Is the CDC "Guideline for Hand Hygiene in Health-Care Settings" in compliance with OSHA BBP Standard?

noreply@blogger.com (NSCsafety) — Tue, 07 Feb 2012 14:00:00 +0000

March 31, 2003

Ms. Janice Zalen
Director of Special Programs
American Health Care Association
1201 L St., NW
Washington, DC 20005

Dear Ms. Zalen:

Thank you for your January 3, 2003 inquiry to the Occupational Safety and Health Administration (OSHA) regarding OSHA requirements for handwashing under the bloodborne pathogens standard [29 CFR 1910.1030]. Your question has been outlined below followed by OSHA's response.

The new Centers for Disease Control and Prevention (CDC) "Guideline for Hand Hygiene in Health-Care Settings" (Morbidity and Mortality Weekly Report, October25, 2002) supports the use of alcohol-based hand rubs as an effective means for decontaminating hands in healthcare settings. Is this consistent with the requirements for handwashing established in OSHA's bloodborne pathogens standard?

Many of CDC's hand hygiene guidelines are for infection control and patient safety, which OSHA standards do not specifically address. However, we feel that these guidelines which do address occupational exposures to blood or other potentially infectious materials (OPIM) are consistent with OSHA's bloodborne pathogens standard. In paragraph (d)(2) of OSHA's standard, the section that most appropriately addresses "handwashing" in the scenario that you describe, the following is stated:

(v) Employers shall ensure that employees wash their hands immediately or as soon as feasible after removal of gloves or other personal protective equipment. (vi) Employers shall ensure that employees wash hands and any other skin with soap and water, or flush mucous membranes with water immediately or as soon as feasible following contact of such body areas with blood or other potentially infectious materials.

OSHA interprets this to mean that when an employee is removing gloves and has had contact, meaning occupational exposure to blood or blood or other potentially infectious materials (OPIM), hands must be washed with an appropriate soap and running water. If a sink is not readily accessible (e.g., in the field) for instances where there has been occupational exposure, hands may be decontaminated with a hand cleanser or towelette, but must be washed with soap and running water as soon as feasible. If there has been no occupational exposure to blood or OPIM, antiseptic hand cleansers may be used as an appropriate "handwashing" practice.

Again, if there has been no occupational exposure to or contact with blood or OPIM (as defined in [29 CFR 1910.1030(b)]), the use of alcohol-based hand cleansers described in the CDC's October 2002 guidelines would be appropriate. The application of the standard and its specific elements must be put into place where there has been actual or reasonably anticipated exposure to blood or OPIM and does not apply if no occupational exposure exists.

OSHA has consistently relied on the findings and recommendations of the CDC in developing good work practices for those employees with occupational exposure to blood or OPIM and feels that the existing standard does not compromise or contradict the recommendations included in the CDC's most recent guidelines.

This is an official Letter of Interpretation from OSHA. You may find all the OSHA Letters of Interpretations online.

Removal of Contaminated Needles Prior to Disposal

noreply@blogger.com (NSCsafety) — Wed, 18 Jan 2012 17:53:00 +0000

December 19, 2011
MEMORANDUM FOR:	MARTHE B. KENT, REGIONAL ADMINISTRATOR
FROM:	THOMAS GALASSI, DIRECTOR DIRECTORATE OF ENFORCEMENT PROGRAMS
SUBJECT:	Removal of Contaminated Needles Prior to Disposal

This is in response to your Regional Office's request for clarification on the Agency's enforcement policy concerning the practice of uncapping used/contaminated needles prior to disposal. In the situation you presented, it was asked whether the Bloodborne Pathogens standard (29 CFR 1910.1030) permitted employers (e.g., medical and/or dental practitioners) to remove contaminated needles from caps/sheaths before disposing of the needles following medical or dental procedures.

As you are aware, the standard strictly prohibits bending, recapping, or removal of contaminated sharps unless the employer can demonstrate that no alternative is feasible or that such action is required by a specific medical or dental procedure. [29 CFR 1910.1030(d)(2)(vii)(A)] The scenario you described clearly does not meet either of these exceptions. In the case of the first exception (i.e., one in which there is no feasible alternative), the obvious alternative is that the needle with the cap attached can be placed directly into the sharps container. In the case of the second (i.e., one in which there is a medical or dental need for the removal of the needle), it is evident that at the point of disposal, the medical or dental procedure has already been completed and thus the prohibited activity is not medically necessary. This activity is one which requires additional manual manipulation, which unnecessarily exposed employees to a greater risk of injury and would NOT be permitted under this provision of the Bloodborne Pathogens standard.

Safer work practices in medical labs

noreply@blogger.com (NSCsafety) — Wed, 11 Jan 2012 17:22:00 +0000

The CDC has produced guidelines that reinforce a common-sense approach to biosafety in day-to-day laboratory activities.

“Guidelines for Safe Work Practices in Human and Animal Medical Diagnostic Laboratories” address safe work practices in human and animal diagnostic laboratory, including microbiology, chemistry, hematology, and pathology with autopsy and necropsy guidance. The following is an introduction to this publication:

This report offers guidance and recommends biosafety practices specifically for human and animal clinical diagnostic laboratories and is intended to supplement the 5th edition of Biosafety in Microbiological and Biomedical Laboratories (BMBL-5), developed by CDC and the National Institutes of Health (1). This document was written not to replace existing biosafety guidelines, but to 1) improve the safety of activities in clinical diagnostic laboratories, 2) encourage laboratory workers to think about safety issues they might not previously have considered or addressed, and 3) encourage laboratorians to create and foster a culture of safety in their laboratories. Should any of the guidelines provided herein conflict with federal, state, or local laws or regulatory requirements, the laboratorian should defer to the federal, state, or local requirements. This culture of safety is also supported by the Clinical and Laboratory Standards Institute (2). Work in a diagnostic laboratory entails safety considerations beyond the biological component; therefore, these guidelines also address a few of the more important day-to-day safety issues that affect laboratorians in settings where biological safety is a major focus.

The US Bureau of Labor Statistics estimates that there are approximately 500,000 human and animal diagnostic lab workers, and that “any of these workers who have chronic medical conditions or receive immunosuppressive therapy would be at increased risk for a laboratory-acquired infection (LAI) after a laboratory exposure.” But post exposure infection risks are unknown because of the difficulty in determining the source or mode of transmission and non national surveillance system is available.

Bacteria account for more than 40% of LAI, with more than 37 species “as etiologic agents,” says the report, but other microbes also present risks. For example, “Hepatitis B has been the most frequent laboratory-acquired viral infection, with a rate of 3.5–4.6 cases per 1000 workers, which is two to four times that of the general population,” according to the report. “Any laboratorian who collects or handles tubes of blood is vulnerable.”

Also, LAI surveys have found that laboratory staff “were three to nine times more likely than the general population to become infected with Mycobacterium tuberculosis.”

Acceptability of using a straight needle instead of a safety needle?

noreply@blogger.com (NSCsafety) — Mon, 02 Jan 2012 16:41:00 +0000

Thank you for your March 28, 2001 letter to the Occupational Safety and Health Administration (OSHA). Your letter was forwarded from OSHA's Milwaukee Area Office to the Directorate of Compliance Programs in Washington, DC for a response to your specific questions regarding the applicability of the Bloodborne Pathogens Standard (29 CFR 1910.1030) to the withdrawal of medications from a vial in a clinical setting. Your question is outlined below followed by OSHA's response. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any question not delineated within your original correspondence.

The pharmacy and nursing staff (of our facility) use large bore needles to withdraw medication from a vial and then remove that needle, placing a smaller gauge safety needle on the syringe to administer the medication to the patient.

Do we have to use a safety needle to withdraw the medication from the vial even though it will not have contact with the patient?

In the situation that you describe, the practices your facility uses are compliant with the Bloodborne Pathogens standard and no further controls would be required. The standard applies to all occupational exposure to blood or other potentially infectious materials (OPIM). Therefore, during a procedure where there is no exposure to blood or OPIM, such as withdrawing medication or pharmaceuticals from a vial, it would not be necessary to implement the use of engineering controls.

If, during this procedure, the same needle used to withdraw the medication is also used to administer it to a patient through injection, OSHA would require the use of an appropriate engineering control (e.g., safer medical device, sharp with engineered sharps injury protection). As you have stated, you use a straight needle to withdraw the medication from the vial and then switch to a "safety" needle for administration; this is acceptable.

Sincerely,

Richard E. Fairfax, Director
Directorate of Compliance Programs

Employer responsibilities for supplying contract employees

noreply@blogger.com (NSCsafety) — Thu, 15 Dec 2011 16:24:00 +0000

My company supplies contract employees to healthcare facilities. What are my responsibilities under the Bloodborne Pathogens standard?

OSHA considers personnel providers, who send their own employees to work at other facilities, to be employers whose employees may be exposed to hazards. Because your company maintains a continuing relationship with its employees, but another employer (your client) creates and controls the hazard, there is a shared responsibility for assuring that your employees are protected from workplace hazards. The client employer has the primary responsibility for such protection, but the "lessor employer" likewise has a responsibility under the Occupational Safety and Health Act. In the context of OSHA's standard on Bloodborne Pathogens, 29 CFR 1910.1030, your company would be required, for example, to provide the general bloodborne pathogens training outlined in the standard; ensure that employees are provided with the required vaccinations; and provide proper follow-up evaluations following an exposure incident. Your clients would be responsible, for example, for providing site-specific training and personal protective equipment, and would have the primary responsibility regarding the control of potential exposure conditions. The client, of course, may specify what qualifications are required for supplied personnel, including vaccination status. It is certainly in the interest of the lessor employer to ensure that all steps required under the standard have been taken by the client employer to ensure a safe and healthful workplace for the leased employees. Toward that end, your contracts with your clients should clearly describe the responsibilities of both parties in order to ensure that all requirements of the standard are met.

Hepatitis B Vaccinations continued!

noreply@blogger.com (NSCsafety) — Thu, 01 Dec 2011 17:34:00 +0000

Any workers who have reasonably anticipated contact with blood or Other Potentially Infectious Materials (OPIM) during performance of their jobs are considered to have occupational exposure and to be at risk of being infected. Workers infected with HBV face a risk for liver ailments which can be fatal, including cirrhosis of the liver and primary liver cancer. A small percentage of adults who get hepatitis B never fully recover and remain chronically infected. In addition, infected individuals can spread the virus to others through contact with their blood and other body fluids.

An employer must develop an exposure control plan and implement use of universal precautions and control measures, such as engineering controls, work practice controls, and personal protective equipment to protect all workers with occupational exposure. In addition, employers must make hepatitis B vaccination available to these workers. Hepatitis B vaccination is recognized as an effective defense against HBV infection.

What to do if an employee declines the vaccination.

Employers must ensure that workers who decline vaccination sign a declination form. The purpose of this is to encourage greater participation in the vaccination program by stating that a worker declining the vaccination remains at risk of acquiring hepatitis B. The form also states that if a worker initially declines to receive the vaccine, but at a later date decides to accept it, the employer is required to make it available, at no cost, provided the worker is still occupationally exposed.

Are employers required to provide an HBV vaccination?

noreply@blogger.com (NSCsafety) — Thu, 17 Nov 2011 21:00:00 +0000

HBV Vaccination

The standard requires employers to offer the vaccination series to all workers who have occupational exposure. Examples of workers who may have occupational exposure include, but are not limited to, healthcare workers, emergency responders, morticians, first-aid personnel, correctional officers and laundry workers in hospitals and commercial laundries that service healthcare or public safety institutions. The vaccine and vaccination must be offered at no cost to the worker and at a reasonable time and place. The hepatitis B vaccination is a non-infectious, vaccine prepared from recombinant yeast cultures, rather than human blood or plasma. There is no risk of contamination from other bloodborne pathogens nor is there any chance of developing
HBV from the vaccine.

The vaccine must be administered according to the recommendations of the U.S. Public Health Service (USPHS) current at the time the procedure takes place. To ensure immunity, it is important for individuals to complete the entire course of vaccination contained in the USPHS recommendations.

The great majority of those vaccinated will develop immunity to the hepatitis B virus. The vaccine causes no harm to those who are already immune or to those who may be HBV carriers. Although workers may desire to have their blood tested for antibodies to see if vaccination is needed, employers cannot make such screening a condition of receiving vaccination and employers are not required to provide prescreening.

Employers must ensure that all occupationally exposed workers are trained about the vaccine and vaccination, including efficacy, safety, method of administration, and the benefits of vaccination. They also must be informed that the vaccine and vaccination are offered at no cost to the worker. The vaccination must be offered after the worker is trained and within 10 days of initial assignment to a job where there is occupational exposure, unless the worker has previously received the vaccine series, antibody testing has revealed that the worker is immune, or the vaccine is contraindicated for medical reasons. The employer must obtain a written opinion from the icensed healthcare professional within 15 days of the completion of the evaluation for vaccination. This written opinion is limited to whether hepatitis B vaccination is indicated for the worker and if the worker has received the vaccination.

Are there exceptions for PPE use by healthcare workers?

noreply@blogger.com (NSCsafety) — Fri, 30 Sep 2011 19:40:00 +0000

One way the employer can protect workers against exposure to bloodborne pathogens, such as hepatitis B virus (HBV), hepatitis C virus (HCV), and human immunodeficiency virus (HIV), the virus that causes AIDS, is by providing and ensuring they use personal protective equipment, or PPE. Wearing appropriate PPE can significantly reduce risk, since it acts as a barrier against exposure. Employers are required to provide, clean, repair, and replace this equipment as needed, and at no cost to workers.

A worker may choose, temporarily and briefly, under rare and extraordinary circumstances, to forego use of personal protective equipment. It must be the worker’s professional judgment that using the personal protective equipment would prevent the delivery of health care or public safety services or would pose an increased hazard to the safety of the worker or coworker. When such a situation occurs, the employer is required to investigate and document the circumstances to determine if there is a way to avoid it from happening again in the future. Employers and workers should be aware that this is not a blanket exemption to the requirement to use PPE. OSHA expects that this will be an extremely rare occurrence.

Bloodborne Pathogens and Needlestick Prevention

noreply@blogger.com (NSCsafety) — Wed, 07 Sep 2011 17:10:00 +0000

Needlestick injuries and other sharps-related injuries which expose workers to bloodborne pathogens continues to be an important public health concern. Workers in many different occupations are at risk of exposure to bloodborne pathogens, including Hepatitis B, Hepatitis C, and HIV/AIDS. First aid team members, housekeeping personnel in some settings, nurses and other healthcare providers are examples of workers who may be at risk of exposure.

Bloodborne Pathogens is addressed in standards specifically for the general industry.

The Occupational Safety and Health Administration hereby promulgates a standard under section 6(b) of the Occupational Safety and Health Act of 1970 (the Act), 29 U.S.C. 655 to eliminate or minimize occupational exposure to Hepatitis B Virus (HBV), Human Immunodeficiency Virus (HIV) and other bloodborne pathogens. Based on a review of the information in the rulemaking record, OSHA has made a determination that employees face a significant health risk as the result of occupational exposure to blood and other potentially infectious materials because they may contain bloodborne pathogens, including hepatitis B virus which causes Hepatitis B, a serious liver disease, and human immunodeficiency virus, which causes Acquired Immunodeficiency Syndrome (AIDS). The Agency further concludes that this exposure can be minimized or eliminated using a combination of engineering and work practice controls, personal protective clothing and equipment, training, medical surveillance, Hepatitis B vaccination, signs and labels, and other provisions.

HIV Transmission in the Workplace

noreply@blogger.com (NSCsafety) — Sat, 12 Feb 2011 18:14:00 +0000

HIV can be detected in several fluids and tissue of a person living with HIV. It is important to understand however, that finding a small amount of HIV in a body fluid or tissue does not mean that HIV is transmitted by that body fluid or tissue. Only specific fluids (blood, semen, vaginal secretions, and breast milk) from an HIV-infected person can transmit HIV. These specific fluids must come in contact with a mucous membrane or damaged tissue or be directly injected into the blood-stream (from a needle or syringe) for transmission to possibly occur.

Some healthcare workers have become infected after being stuck with needles containing HIV-infected blood or, less frequently, when infected blood comes in contact with a worker's open cut or is splashed into a worker's eyes or inside their nose. There has been only one instance of patients being infected by an HIV-infected dentist.

These body fluids have been shown to contain high concentrations of HIV:

blood
semen
vaginal fluid
breast milk
other body fluids containing blood

The following are additional body fluids that may transmit the virus that health care workers may come into contact with:

fluid surrounding the brain and the spinal cord
fluid surrounding bone joints
fluid surrounding an unborn baby

Reporting Occupational Exposure to Bloodborne Pathogens

noreply@blogger.com (NSCsafety) — Sun, 06 Feb 2011 22:22:00 +0000

OSHA's bloodborne pathogens standard includes provisions for medical follow-up for workers who have an exposure incident. The most obvious exposure incident is a needlestick. But any specific eye, mouth, other mucous membrane, non-intact skin, or parenteral contact with blood or other potentially infectious materials is considered an exposure incident and should be reported to the employer. Exposure incidents can lead to infection from hepatitis B virus (HBV) or human immunodeficiency virus (HIV) which causes AIDS. Although few cases of AIDS are directly traceable to workplace exposure, every year about 8,700 health care workers contract hepatitis B from occupational exposures. Approximately 200 will die from this bloodborne infection. Some will become carriers, passing the infection on to others.

WHY REPORT?
Reporting an exposure incident right away permits immediate medical follow-up. Early action is crucial. Immediate intervention can forestall the development of hepatitis B or enable the affected worker to track potential HIV infection. Prompt reporting also can help the worker avoid spreading bloodborne infection to others. Further, it enables the employer to evaluate the circumstances surrounding the exposure incident to try to find ways to prevent such a situation from occurring again.
Reporting is also important because part of the follow-up includes testing the blood of the source individual to determine HBV and HIV infectivity if this is unknown and if permission for testing can be obtained. The exposed employee must be informed of the results of these tests. Employers must tell the employee what to do if an exposure incident occurs.

MEDICAL EVALUATION AND FOLLOW-UP
Employers must provide free medical evaluation and treatment to employees who experience an exposure incident. They are to refer exposed employees to a licensed health care provider who will counsel the individual about what happened and how to prevent fiuther spread of any potential infection. He or she will prescribe appropriate treatment in line with current U.S. Public Health Service recommendations. The licensed health care provider also will evaluate any reported illness to determine if the symptoms may be related to HIV or HBV development.
The first step is to test the blood of the exposed employee. Any employee who wants to participate in the medical evaluation program must agree to have blood drawn. However, the employee has the option to give the blood sample but refuse permission for HIV testing at that time. The employer must maintain the employee's blood sample for 90 days in case the employee changes his or her mind about testing--should symptoms develop that might relate to HIV or HBV infection.
The health care provider will counsel the employee based on the test results. If the source individual was HBV positive or in a high risk category, the exposed employee may be given hepatitis B immune globulin and vaccination, as necessary. If there is no information on the source individual or the test is negative, and the employee has not been vaccinated or does not have immunity based on his or her test, he or she may receive the vaccine. Further, the health care provider will discuss any other findings from the tests.
The standard requires that the employer make the hepatitis B vaccine available, at no cost to the employee, to all employees who have occupational exposure to blood and other potentially infectious materials. This requirement is in addition to post exposure testing and treatment responsibilities.

WRITTEN OPINION
In addition to counseling the employee, the health care provider will provide a written report to the employer. This report simply identifies whether hepatitis B vaccination was recommended for the exposed employee and whether or not the employee received vaccination. The health care provider also must note that the employee has been informed of the results of the evaluation and told of any medical conditions resulting from exposure to blood which require further evaluation or treatment. Any added findings must be kept confidential.

CONFIDENTIALITY
Medical records must remain confidential. They are not available to the employer. The employee must give specific written consent for anyone to see the records. Records must be maintained for the duration of employment plus 30 years in accordance with OSHA's standard on access to employee exposure and medical records.

National Safety Compliance has developed a Workplace Bloodborne Pathogens Training Program that is available for use by employers. Visit this link for more information:

OSHA Bloodborne Pathogens Safety Training

Bloodborne Pathogens Training Requirements

noreply@blogger.com (NSCsafety) — Wed, 26 Jan 2011 17:42:00 +0000

Question: Do the OSHA regulations require that the person conducting bloodborne pathogens training be a health care professional?

Response: No. The Bloodborne Pathogens Standard, 29 CFR 1910.1030, does not specify a particular job classification for qualified trainers. 29 CFR 1910.1030(g)(2)(viii) does however require that the trainer be: knowledgeable in the subject matter covered by the elements contained in the training program. . . In OSHA's bloodborne pathogens compliance directive (OSHA Instruction CPL 02-02-069), we state: possible trainers include a variety of healthcare professionals such as infection control practitioners, nurse practitioners, registered nurses, occupational health professionals, physician's assistants, and emergency medical technicians. Non-healthcare professionals, such as but not limited to, industrial hygienists, epidemiologists, or workplace trainers, may conduct the training provided they are knowledgeable in the subject matter covered by the elements contained in the training program as it relates to the workplace. One way, but not the only way, knowledge can be demonstrated is the fact that the person received specialized training.

National Safety Compliance has developed a blooborne pathogens training program that assists employers with OSHA compliance. For more information about this program, please click the following link: OSHA Bloodborne Pathogens Safety Training

Medical Dental Office Bloodborne Pathogens

noreply@blogger.com (NSCsafety) — Thu, 06 Jan 2011 17:34:00 +0000

Question 1: Do "universal precautions" apply to the activities of medical and dental facilities (e. g., the handling of masks, goggles, gloves, lab coats or other personal protective equipment (PPE))?

Reply 1: Yes. According to the Bloodborne Pathogens Standard, "Universal precautions" is an approach to infection control. According to the concept of Universal Precautions, all human blood and certain human body fluids are treated as if known to be infectious for HIV, HBV, and other bloodborne pathogens." OSHA Regulations 29 CFR 1910.1030(b). 29 CFR 1910.1030(d)(1) requires that universal precautions be observed to prevent contact with blood or other potentially infectious materials. This would include the handling of PPE that has become contaminated with blood or other potentially infectious materials (OPIM) in medical and/or dental facilities.

Question 2: Would it be a violation of the Bloodborne Pathogens Standard if medical or dental facilities failed to adhere to universal precautions for the handling of blood, OPIM, or items, such as laundry contaminated with blood or OPIM?

Reply 2: Yes. Medical and dental facilities failing to adhere to universal precautions would be in violation of section 29 CFR 1910.1030(d)(1) unless the facility is observing a more stringent set of guidelines. According to the Centers for Disease Control and Prevention's (CDC's) Guideline for Isolation Precautions: Preventing Transmission of Infectious Agents in Healthcare Settings 2007: "Standard precautions combine the major features of Universal Precautions and Body Substance Isolation and are based on the principle that all blood, body fluids, secretions, excretions except sweat, nonintact skin, and mucous membranes may contain transmissible infectious agents. Standard Precautions include a group of infection prevention practices that apply to all patients, regardless of suspected or confirmed infection status, in any setting in which healthcare is delivered. . ."¹ These include hand hygiene; use of gloves, gown, mask, eye protection, or face shield, depending on the anticipated exposure; and safe injection practices. Standard precautions are more stringent than universal precautions alone and would be acceptable.

Question 3: Would potential contact of textiles, such as linen or laundry, with unknown body fluids in medical or dental settings where universal precautions are practiced trigger coverage under OSHA's Bloodborne Pathogens Standard at that medical or dental facility? Also, would the contaminated textiles require special handling under the Bloodborne Pathogens Standard?

Reply 3: Pursuant to 29 CFR 1910.1030(a), the Bloodborne Pathogens standard is applicable to all occupational exposure to blood or other potentially infectious material (OPIM), as defined in 29 CFR 1910.1030(b). The definition of OPIM includes saliva in dental procedures, among other things. Occupational exposure is defined 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 determination of the duties, tasks, and scope of the employees' work must be done by the employer to assess whether employees have reasonably anticipated exposure to blood or OPIM [29 CFR 1910.1030(c)(2)]. Employers with employees who launder or otherwise handle linen contaminated with blood or OPIM (e.g., housekeeping staff in a healthcare setting; employees in a commercial laundry facility with a contract to launder contaminated linen from medical/dental settings) would be considered to have reasonably anticipated exposure and would be covered by the standard. Blood is often found on linen and laundry in medical facilities, and saliva is often found on such materials in dental offices. With respect to unknown fluids, 29 CFR 1910.1030(d)(1) provides in pertinent part: "Under circumstances in which differentiation between body fluid types is difficult or impossible, all body fluids shall be considered potentially infectious materials." The fact that the contaminated textiles are in a medical or dental facility where universal precautions are practiced would not preclude coverage under the Bloodborne Pathogens Standard.

With regard to the handling of contaminated laundry, 29 CFR 1910.1030(d)(4)(iv) sets forth the requirements for the handling and transport of laundry contaminated with blood or OPIM. For example, 1910.1030(d)(4)(iv)(A) and 1910.1030(d)(4)(iv)(A)(1) - 1910.1030(d)(4)(iv)(A)(3) cover the handling, containerization and transport of contaminated laundry, while sections 1910.1030(d)(4)(iv)(B) and 1910.1030(d)(4)(iv)(C) cover use of PPE while handling contaminated laundry and use of color-coded or labeled bags for transport to off-site facilities that do not use universal precautions in handling all laundry (e.g., transport to an off-site commercial laundry facility). Please refer to these sections of the standard for the specific requirements.

Question 4: Would an off-site facility (e.g., commercial laundry facility) which handles contaminated linen from healthcare settings be required to have a written exposure control plan?

Reply 4: Yes, as stated in the response to question #3, employers with employees who launder or otherwise handle linen contaminated with blood or OPIM (e.g., employees in a commercial laundry facility with a contract to launder contaminated linen from medical or dental settings) would be considered to have reasonably anticipated exposure to blood or OPIM and, thus, would be covered by the Bloodborne Pathogens Standard. Consequently, such employers are required to establish a written exposure control plan designed to eliminate or minimize employee exposure. 29 CFR 1910.1030(c)(1).

Question 5: Does an employer need to also ensure the proper laundering of contaminated linen?

Reply 5: The Bloodborne Pathogens Standard covers the handling and transport of contaminated laundry for the protection of employees; however, OSHA regulations do not have specific requirements for actual laundering procedures for assuring patient-specific infection control. OSHA's authority is limited to the protection of workers. As you noted in your inquiry, there are existing infection control guidelines set by the CDC. In the 2003 Guidelines for Environmental Infection Control in Health-Care Facilities, the CDC provides guidance for the handling, cleaning, and disinfection of contaminated laundry. The document can be found at http://www.osha.gov/pls/oshaweb/owaredirect.html?p_url=http:/www.cdc.gov/mmwr/preview/mmwrhtm/rr5210a1.htm.

Question 6: Is it permissible for employees to launder personal protective equipment like scrubs or other clothing worn next to the skin at home?

Reply 6: In your inquiry, you correctly note that it is unacceptable for contaminated PPE to be laundered at home by employees. However employees' uniforms or scrubs which are usually worn in a manner similar to street clothes are generally not intended to be PPE and are, therefore, not expected to be contaminated with blood or OPIM. These would not need to be handled in the same manner as contaminated laundry or contaminated PPE unless the uniforms or scrubs have not been properly protected and become contaminated.

Question 7: Is an employer in a dental office responsible for implementing an exposure control plan at the establishment if that employer launders the contaminated linen or PPE onsite?

Reply 7: Yes. Again, please see the response to question #3 above. Also, please be aware that dental offices would have other reasonably anticipated exposure scenarios other than the laundering of contaminated PPE that would make it necessary to develop and implement an exposure control plan. The exposure control plan should cover all job classifications and tasks in which employees have occupational exposure.

Question 8: Is that same employer responsible for following the CDC guidelines for laundering contaminated laundry?

Reply 8: The CDC guidelines are not mandatory. They are recommendations written with the intent of enhancing infection control measures in all healthcare facilities, including dental settings.

Question 9: How would OSHA regard an employer in a dental office who does not adhere to the requirements of the Bloodborne Pathogens Standard (e.g., use of universal precautions and establishment of an exposure control plan) and who does not use proper procedures for laundering contaminated laundry?

Reply 9: Again, please see the response to question #3 above. All employers having employees with occupational exposure must comply with the requirements of the Bloodborne Pathogens Standard and would be considered noncompliant for failing to do so. Please see the response to question #8 above with regard to the use of proper procedures for laundering contaminated linen.

National Safety Compliance has developed an employee training program that is specific to bloodborne pathogens. For more information about this program, please visit this link: OSHA Bloodborne Pathogens Safety Training Program

Exposure to Bloodborne Pathogens

noreply@blogger.com (NSCsafety) — Wed, 22 Apr 2009 00:55:00 +0000

Employees can be exposed to bloodborne pathogens at any time. OSHA has outlined these important steps that all employees should understand if they are involved in a bloodborne pathogens exposure incident.

If you are stuck by a needle or other sharp, or get blood or other potentially infectious materials in your eyes, nose, mouth, or on broken skin:

Immediately flood the exposed area with water and clean any wound with soap and water or a skin disinfectant if available.
Report this immediately to your employer.
Seek immediate medical attention.

Follow this link for OSHA bloodborne pathogens training videos.

Needlestick Safety

noreply@blogger.com (NSCsafety) — Fri, 06 Feb 2009 14:54:00 +0000

State legislative efforts to improve health care worker safety related to needlesticks began in 1998 in California. Twenty-one other states have enacted some type of legislation related to health care worker bloodborne pathogen exposures. These state laws typically require that state agencies, such as the department of health or labor, develop a set of administrative regulations to implement the laws.

These state laws are aimed at adding additional safeguards for health care workers at the state level. This includes adding provisions not in the federal OSHA Bloodborne Pathogen standard and/or coverage of public employees not regulated by OSHA.

Each of these state laws varies in terms of its coverage and scope. Common provisions include requirements for:

listing of safety devices as engineering controls;
development of a list of available safety devices by the state for use by employers;
development of a written exposure plan by employers and periodic review and updates;
development of protocols for safety device identification and selection by employers and involvement by frontline workers in the process;
development of a sharps injury log and reporting log information;
development of methods to increase use of vaccines and personal protective equipment;
waivers or exemptions from safety device use under certain circumstances (including patient and/or worker safety issues, use of alternative effective strategies, market unavailability, etc.);
placement of sharps containers in accessible positions, and
training for workers regarding safety device use.

Many of the state laws contain more unique requirements such as surveillance programs, cost-benefit analysis, strict requirements for safety device use and the use of statewide advisory boards. These unique features are noted in the state-by-state section. Each state law differs as to the time frame for development of its related regulations and the date the laws and regulations become effective.

State-by-State Provisions (In Chronological Order)

Select a state for specific details:

Alaska - Arkansas - California - Connecticut - Georgia - Iowa - Maine - Maryland - Massachusetts - Minnesota - Missouri - New Hampshire - New Jersey - New York - Ohio - Oklahoma - Pennsylvania - Rhode Island - Tennessee - Texas - West Virginia

What are Bloodborne Pathogens?

noreply@blogger.com (NSCsafety) — Mon, 26 Jan 2009 17:18:00 +0000

If you are searching the internet for "bloodborne pathogens" you may already know and understand what they are. However, many people may not.

A bloodborne pathogen is a disease producing bacteria or microorganism. OSHA defines a bloodborne pathogen as a pathogenic microorganism present in human blood that can lead to disease. There are many disease carrying pathogenic microorganisms that are covered by OSHA's Bloodborne Pathogen Standard (29 CFR 1910.1030); however, the most common and those of primary concern are Human Immunodeficiency Virus (HIV), Hepatitis B (HBV), and Hepatitis C (HCV).

I will give a brief description of each.

Human Immunodeficiency Virus (HIV):

HIV is the virus that leads to acquired immunodeficiency syndrome (AIDS). A person can carry HIV for many years and not have symptoms until it turns into full-blown AIDS.
AIDS attacks the person’s immune system, which makes it difficult for the body to fight off disease.
Scientists and medical authorities agree that HIV does not survive well outside the body. Drying of HIV-infected human blood or other body fluids reduces the risk of environmental transmission to essentially zero.
HIV is found in very low quantities in saliva and tears from some AIDS patients. HIV has not been found in the sweat of HIV-infected persons. Contact with saliva, tears, or sweat has never been shown to result in the transmission of HIV.

Hepatitis B Virus (HBV):

1 to 1 ¼ million Americans are chronically infected
Symptoms include: jaundice, fatigue, abdominal pain, loss of appetite, intermittent nausea, vomiting
May lead to chronic liver disease, liver cancer, and death
Vaccination available since 1982
HBV can survive for at least one week in
dried blood

Hepatitis C Virus (HCV):

An estimated 3.9 million Americans have been infected with HCV of whom 2.7 million are chronically infected.
Persons chronically infected with HCV may not be aware of it because they are not clinically ill. Sometimes it can take two decades before symptoms are recognized.
Chronic liver disease occurs in approximately 70 percent of infected persons.
There are some drugs that have been licensed for treatment of HCV; however, they are only effective in 10-40 percent of persons.
8,000-10,000 deaths occur each year as a result of the chronic liver disease.
There are some drugs that have been licensed for treatment of HCV; however, they are only effective in 10-40 percent of persons.

For more information about OSHA's Bloodborne Pathogens we recommend you visit the following link: Bloodborne Pathogens Safety Training

Bloodborne Pathogens - FAQ

noreply@blogger.com (NSCsafety) — Tue, 30 Dec 2008 19:01:00 +0000

Workers in many different occupations are at risk of exposure to bloodborne pathogens, including Hepatitis B, Hepatitis C, and HIV/AIDS. First aid team members, housekeeping personnel in some settings, nurses and other healthcare providers are examples of workers who may be at risk of exposure.

On December 6, 1991, the Occupational Safety and Health Administration (OSHA) promulgated the Occupational Exposure to Bloodborne Pathogens Standard. This standard is designed to protect approximately 5.6 million workers in the health care and related occupations from the risk of exposure to bloodborne pathogens, such as the Human Immunodeficiency Virus (HIV) and the Hepatitis B Virus (HBV).

As a result of the standard, numerous questions have been received on how to implement the provisions of the standard. On this blog we will provide answers to some of the more commonly asked questions related to the Bloodborne Pathogens Standard.

Q1. Who Is covered by the standard?

The standard applies to all employees who have occupational exposure to blood or other potentially infectious materials (OPIM).

Occupational exposure is defined as "reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or OPIM that may result from the performance of the employee's duties."

Blood is defined as human blood, human blood components, and products made from human blood.

OPIM is defined as the following human body fluids: saliva in dental procedures, semen, vaginal secretions, cerebrospinal, synovial, pleural, pericardial, peritoneal, and amniotic fluids; body fluids visibly contaminated with blood; along with all body fluids in situations where it is difficult or impossible to differentiate between body fluids; unfixed human tissues or organs (other than intact skin); HIV-containing cell or tissue cultures, organ cultures, and HIV- or HBV-containing culture media or other solutions; and blood, organs, or other tissues from experimental animals infected with HIV or HBV.

Q2. We have employees who are designated to render first aid. Are they covered by the standard?

Yes. If employees are trained and designated as responsible for rendering first aid or medical assistance as part of their job duties, they are covered by the protections of the standard.

Q3. Are employees such as housekeepers, maintenance workers, or janitors covered by the standard?

Housekeeping workers in health care facilities may have occupational exposure to bloodborne pathogens, as defined by the standard. Individuals who perform housekeeping duties, particularly in patient care and laboratory areas, may perform tasks, such as cleaning blood spills and handling regulated wastes, which constitute occupational exposure.

While OSHA does not generally consider maintenance personnel and janitorial staff employed in non-health care facilities to have occupational exposure, it is the employer's responsibility to determine which job classifications or specific tasks and procedures involve occupational exposure.

Q4. What is an exposure control plan?

The exposure control plan is the employer's written program that outlines the protective measures an employer will take to eliminate or minimize employee exposure to blood and OPIM.

The exposure control plan must contain at a minimum:

The exposure determination which identifies job classifications and, in some cases, tasks and procedures where there is occupational exposure to blood and OPIM;
The procedures for evaluating the circumstances surrounding an exposure incident; and
A schedule of how and when other provisions of the standard will be implemented, including methods of compliance, HIV and HBV research laboratories and production facilities requirements, hepatitis B vaccination and post-exposure follow-up, communication of hazards to employees, and recordkeeping.

A fill-in-the-blank exposure control plan may be obtained as part of the Bloodborne Pathogens Training Kit from National Safety Compliance.

Q5. What is meant by the term Universal Precautions?

Universal Precautions is OSHA's required method of control to protect employees from exposure to all human blood and OPIM. The term, "Universal Precautions," refers to a concept of bloodborne disease control which requires that all human blood and certain human body fluids are treated as if known to be infectious for HIV, HBV, and other bloodborne pathogens.

Q6. What type of personal protective equipment (PPE) should employees wear?

The standard requires that PPE be "appropriate." PPE will be considered "appropriate" only if it does not permit blood or OPIM to pass through to, or reach, the skin, employees' underlying garments, eyes, mouth, or other mucous membranes under normal conditions of use and for the duration of time that the PPE will be used. This allows the employer to select PPE based on the type of exposure and the quantity of blood or OPIM which can be reasonably anticipated to be encountered during performance of a task or procedure.

Q7. Who is responsible for providing PPE?

The financial responsibility for repairing, replacing, cleaning, and disposing of PPE rests with the employer. The employer is not obligated under the standard to provide general work clothes to employees, but is responsible for providing PPE. If laboratory jackets or uniforms are intended to protect the employee's body or clothing from contamination, they are to be provided by the employer. PPE kits and spill clean-up kits specific to bloodborne pathogens may be purchased from National Safety Compliance.

Q8. Who must be offered the hepatitis B vaccination?

The hepatitis B vaccination series must be made available to all employees who have occupational exposure. The employer does not have to make the hepatitis B vaccination available to employees who have previously received the vaccination series, who are already immune as their antibody tests reveal, or who are prohibited from receiving the vaccine for medical reasons.

Q9. Which employees must be trained regarding Bloodborne Pathogens?

All employees with occupational exposure must receive initial and annual bloodborne pathogens training. To assist trainers and employers, a bloodborne pathogens training video is available from National Safety Compliance.

For more information about the OSHA Bloodborne Pathogens regulations, please make a comment on this blog page or visit the following link: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=21010&p_text_version=FALSE