Effective Exposure Control

The Centers for Disease Control and Prevention estimates more than 28,000 new cases of Hepatitis B occur in the United States every year.

WHAT is your company's agenda when an employee cuts himself while handling a knife (or any other incident that induces bleeding)? What happens if an employee contracts Hepatitis B (HBV) or the HIV virus while rendering first aid or CPR to a critically injured employee?

Will your company be prepared when a fact-finding OSHA inspector shows up at your company's doorstep to investigate a work-related injury or illness? Would you be left in a wooden pillory when the inspector asks for your written bloodborne pathogen prevention program and its binding documentation of compliance?

The Bloodborne Pathogen Standard
On March 6, 1992, OSHA initiated a Bloodborne Pathogens Standard (29 CFR 1910.1030) after nearly a year of comments during its obligatory run in the Federal Register. The standard's main objective was to inform both employers and employees which actions and precautions need to be taken to both prevent and protect one another from exposure to bloodborne pathogens and other harmful bodily fluids at the workplace. And though the standard was targeted originally toward the 5.6 million workers in the medical and dental sectors, it has ended up being applied to nearly all employers, despite the industry at hand.

Nationwide, with very few exceptions, all businesses are required by OSHA to have pre-assigned employees trained and certified to perform both CPR and first aid in case of workplace emergencies. The bloodborne pathogens standard is both an obligatory and a surreptitious daisy chain to first aid and CPR requirements, because there exists a viable chance an interchange of bodily fluids could transpire during first aid and/or CPR exercises.

Human bloodborne pathogens are disease- and infection-causing microorganisms carried by blood and other potentially infectious bodily fluids and materials (needles, bandages, etc.). Some of the more serious blood pathogens are the Human Immunodeficiency Virus (HIV); Hepatitis A, B, C, or D viruses; malaria; and syphilis. The most severe Hepatitis virus, Hepatitis B, infects the liver and can lead to serious and even fatal illnesses such as cirrhosis and liver cancer. In addition, the blood-tainted B virus can live up to 72 hours outside the body. The Centers for Disease Control and Prevention estimates more than 28,000 new cases of Hepatitis B occur in the United States every year.

OSHA regulations stipulate that employers must develop a written Exposure Control Plan as part of their overall bloodborne pathogen prevention (BPP) program and update it annually. It must include both protective and well documented, preventive procedures that are designed to eliminate or minimize employee exposures to bloodborne pathogens and other bodily fluids.

Existing plans should include the following elements:

  • Determine and clearly document exposure determinations, the specific job classification, and exact occupational exposure of each employee.
  • Engineering and work practice controls, such as appropriate medial devices and sharps disposal. (Contaminated sharps are defined as any contaminated object that can pierce the skin, including but not limited to needles, scalpels, broken glass, broken capillary tubes, and exposed ends of dental wires.)
  • Determine the correct personal protective equipment (PPE) that may be involved. Each employee must be trained (and documented with signatures and dates of both the exposed employee and the trainers involved) on how to properly use, maintain, and store assigned PPE.
  • Good housekeeping practices, including decontamination procedures and the safe and proper removal of regulated wastes. All applicable waste receptacles should have a red plastic liner accompanied with an exterior-attached, red-colored "Bio-Hazard" warning sticker.
  • Ongoing information and documented training of exposed employees, including training associated with the performance of newly assigned tasks and/or procedures.
  • Hepatitis B vaccination. This immunization process transpires over a course of nine months with one shot given every three months.
  • Post-exposure evaluations and well documented follow-ups.
  • Recordkeeping (including a sharps injury log).

Recent Revisions to 1910.1030
In 2001, responding to the Needlestick Safety and Prevention Act, OSHA revised the Bloodborne Pathogens Standard. The revised standard clarifies the need for employers to select safer needle devices and to involve employees in identifying and choosing those devices. The updated standard also requires employers to maintain a log of injuries from contaminated sharps.

On Oct. 15, 2003, OSHA issued a Safety and Health Information bulletin on the disposal of contaminated needles and blood tube holders. OSHA had determined that the best practice for prevention of needlestick injuries following phlebotomy procedures is the use of a sharp with engineered sharps injury protection attached to the blood tube holder and the immediate disposal of the entire unit after each patient's blood is drawn.

OSHA'S Definition of Blood
Today, 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 normal duties.

OSHA defines blood as human blood, human blood components, and products derived from human blood. OPIM is defined as the following human body fluids:

  • Saliva in dental procedures
  • Semen
  • Vaginal secretions
  • Cerebrospinal fluid
  • Synovial fluid
  • Pleural fluid
  • Pericardial fluid
  • Peritoneal and amniotic fluids
  • Body fluids visibly contaminated with blood
  • All body fluids in situations where it is difficult or impossible to differentiate between body fluids
  • Unfixed human tissues or organs
  • 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.

Smallpox Vaccination Plans
Employers who are engaged in smallpox immunization programs should already be complying with the standard. Their most current responsibility would be to update their exposure control plans so they specifically address in writing smallpox vaccination and that their employees who procure such immunizations are trained in vaccination procedure.

First Aid and CPR Trained Employees
If first aid/CPR response is a collateral duty of an employee's job responsibilities, regardless of whether the responsibility is in writing or is verbally understood, the employee's position should be listed in the Exposure Control Plan, as should the task(s) and procedures that place that worker at certain risk.

PPE such as protective gloves and face barriers would be required, with their proper usage, training, and storage. The written program on file also is required to include a voluntary, three-step inoculation to guard against Hepatitis B for all of the high-risk employees (first aid, CPR trained, etc.). Each affected employee, however, has the inherent right to decline the inoculation shots; therefore, it would be wise for employers to have the employee sign a Declination Form, with the employee entitled to have the vaccination shots at a later date if she or he so desires.

Precaution and Preparedness
In the meat and poultry industry, where 12-inch knives and circular band saws are everyday work tools, it would be wise to have in place an updated addendum procedure to your BBP on what the company's "preventive plan of action" would be whenever an employee cuts himself and blood is exposed on product contact surfaces, and possibly the raw meat itself.

If you're like many, you may think of commonly recognized bacterial organisms such as Salmonella, E coli, and Listeria as being the only hazards to our food supply. But viruses are estimated to be the leading cause of foodborne illness in the United States.

As previously mentioned, the Hepatitis B virus can survive, under the right conditions, up to 72 hours outside the body. Though the chances are rather small, the exposed meat could nevertheless become contaminated and affect the end consumer. Clear, concise, and verifiable company directives should be put in place where any possibly contaminated product is removed and rendered as inedible. In addition, the product contact area and the surrounding areas should be cleaned with hot water and soap and sanitized thereafter before production is allowed to resume.

Recent OSHA statistics clearly reveal the continuing ignorance of all industries to this standard. Between October 1998 and September 2002, non-compliance by companies nationwide to the bloodborne pathogens standard during normal OSHA audits has made the standard a member of the "Top 15" list as one of OSHA's most frequently cited standards. In addition, total dollar fines by OSHA for non-compliance to the standard have easily exceeded $1 million during that same time period.

This article originally appeared in the April 2004 issue of Occupational Health & Safety.

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