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.
Many workers in the health care industry and other fields are exposed to blood-borne pathogens - pathogenic microorganisms that are present in human blood. Exposure to blood-borne pathogens can infect and cause serious disease in humans. Among the more troublesome blood-borne 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 blood-borne 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 blood-borne 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 Blood-borne Pathogens Standard.
Excerpt from information from OSHA by H. Berrien Zettler, Deputy Director, Directorate of Compliance Programs:
OSHA does not have any evidence to support whether decontamination of plush carpets is possible; it is our opinion that carpeted surfaces cannot be decontaminated. However, under normal circumstances, carpeted surfaces are located in areas where there is minimal exposure from dermal contact, therefore, employers are expected to make a reasonable effort to clean and sanitize carpeting and soft plush surfaces with carpet detergent/cleaner products.
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