Blood Borne Pathogens
OSHA Standards
The OSHA Exposure to Bloodborne Pathogens Standard requires that employers in industries where exposure to bloodborne pathogens is reasonably foreseeable (i.e., health care) take steps to minimize or eliminate the risk of exposure. For example, regulated employers must establish a written Exposure Control Plan and are likely to be required to implement engineering and work practice controls; ensure that workers are provided (and use) appropriate personal protective equipment; and adopt certain housekeeping procedures that foster a clean and sanitary work environment.
It is estimated that approximately 5.6 workers in the health care industry and other fields are exposed to bloodborne pathogens – pathogenic microorganisms that are present in human blood. Exposure to bloodborne pathogens can infect and cause serious disease in humans. Among the more troublesome bloodborne pathogens are Hepatitis B Virus (HBV), which causes serious liver disease, and Human Immune Deficiency Virus (HIV), which causes AIDS.
Employers, therefore, need to be prepared to take proactive steps to minimize their workers’ foreseeable risk of exposure to blood and other potentially infectious material (OPIM).** Regulated employers are required to draft and adopt an Exposure Control Plan. Such plan should include a summary of possible exposure scenarios, a listing of methods that should be used to minimize the risk of exposure (i.e.: the use of personal protective equipment; the adoption of specific housekeeping procedures), and a procedure for the evaluation of the circumstances surrounding an exposure that does occur.
Of course, it is not enough to simply list various methods designed to minimize the risk of exposure. Employers are also required to implement such methods – including the institution of work practice controls and the establishment of policies that mandate the use of personal protective equipment. Of particular note in the cleaning and maintenance industry, housekeeping procedures should be adopted that ensure that the workplace is maintained in a clean and sanitary condition. Specifically, the housekeeping procedure should include a written cleaning and decontamination schedule, require that work surfaces that are contaminated be treated with an appropriate disinfectant, and provide for the effective handling and disposal of waste.
Employers should also establish a Hepatitis B vaccination program and make sure that all necessary hazard information is communicated to employees. Specifically, information concerning the hazards associated with bloodborne pathogens should be communicated through the use of warning labels, biohazard signs, and employee training.
** OSHA generally does not consider maintenance personnel and janitorial staff employed in non-health care facilities to have a foreseeable exposure to bloodborne pathogens. Regardless, it is the employer’s ultimate responsibility to determine which job classifications and specific tasks may involve potential exposure.
OSHA generally does NOT consider janitorial employees to be exposed to blood or OPIM when emptying waste containers that may contain discarded sanitary napkins or feminine hygiene products designed to absorb menstrual flow. Further, OSHA does not consider exposure to feces, nasal secretions, sputum, sweat, tears, urine, vomit, or saliva to be regulated under the Occupational Exposure to Bloodborne Pathogens Standard.
Additional Resources
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