Handling BBP Requirements in Manufacturing and Service Industries

Your cleanup plan can be a checklist telling employees where to get the PPE, which solutions to make, and how to package the waste materials for disposal.

IT'S 2:30 in the afternoon and you are home in bed with a cold, sore throat, and runny nose, when the telephone rings. Your wife answers, then brings the phone to you. "It's your boss. There's a problem at work," she says.

"Hi, Boss," you say in a raspy voice, "what's going on?"

There was an accident, your boss explains: A contractor cut himself and left a bloody trail through the building and into a bathroom, leaving behind some bloody rags and a bloody glove. "What do we do?"

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

Who Must Be Trained
When we review the regulations, we find that 1030(g)(2) talks about who needs to be trained and "all employees with occupational exposure" are required to participate in a training program by their employer. These employees have a requirement to act. These employees can include health care workers, laboratory workers, and full-time emergency services employees (police, fire, or first aiders).

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

At OSHA's Bloodborne Pathogens Web site we find mention of first aid teams and housekeeping personnel, but nowhere is there a reference to the requirements for training if their exposures are not required (i.e., voluntary first aid team) or about manufacturing locations or service companies where blood or bodily fluids are not normally encountered.

Developing an Exposure Plan
Companies in health care settings or laboratories where blood or bodily fluids are used or researched already have exposure plans. Their employees have received training for several years now. Everybody else--those who work in the chemical field, paper converting, plastics manufacturing, textile industry, or other, similar types of companies, including retail and the services sector--probably haven't thought about what to do in the event an incident that leaves blood or bodily fluids to be cleaned up.

Here's what I recommend:

Although it is not required, develop your own Bloodborne Pathogens Program. As with any OSHA program, it needs to be in writing and to be communicated to those who need to know. Provide copies as necessary and conduct training. Modify the plan if you discover parts that do not fully address your company's needs and requirements.

Some sections that should be in your program are:

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

It should include universal precautions (putting an impervious barrier between you and the blood or fluid) and a quick 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 are to report all incidents to their supervisor (or other responsible official) as soon as possible.

2. Training program for maintenance and janitorial personnel. This would be employees who have to clean up floors or equipment that becomes contaminated. Give them 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 solutions are to be used? Have them do a table-top exercise or a practice session and observe to ensure they are doing everything correctly.

3. Cleanup plan. This part of the overall plan can be a checklist so that employees involved in performing a cleanup know where they get the PPE, which solutions they need to make, how to use those solutions, and how to package the waste materials for disposal.

4. Disposal plan. This section discusses what to do with the waste materials after the cleanup. If yours is a company with 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 the ambulance staff to take the medical wastes with them for proper disposal at the hospital. 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, however, takes time, and you would need to store the wastes on site until you received approval from your regulators.

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

5. Exposure plan. You have all of the other items under control but because of one thing or another, an employee is exposed to blood or bodily fluids. This section of the plan discusses how to decontaminate the employee and the medical surveillance procedures that must be followed to ensure the employee who was contaminated is tested and counseled so he or she understands what has happened and whether there's a risk of infection from any disease. This section needs to comply with the requirements of 29 CFR 1910.1030(c), Exposure Control, and (h), Recordkeeping.

We don't 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.

This article appeared in the April 2006 issue of Occupational Health & Safety.


First Aid Squads
Your company has a volunteer first aid squad. What must you do for it? Here, again, 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"--they are not covered under the 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 squad. It also should provide Hepatitis B vaccinations to these employees. In fact, 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.

This article originally appeared in the April 2006 issue of Occupational Health & Safety.

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