1. Complying with OSHA’s Bloodborne Pathogen Final Rule
Module B
Complying with OSHA’s Bloodborne Pathogen Final Rule
Welcome to Module B, Complying with the Occupational Safety and Health Administration’s Bloodborne Pathogen Final Rule.
Almost there!

2. Objectives
Provide an overview of the Bloodborne Pathogen (BBP) Standard
Highlight OSHA’s requirements regarding bloodborne pathogens, including needlestick safety provisions
There are two main objectives for this module:
To provide and overview of the bloodborne pathogen standard and to highlight OSHA’s requirements regarding bloodborne pathogens, including needlestick safety.

3. OSHA and OSHA-NC
General Duty Clause Occupational Safety and Health Act (OSHA) - “requires that employers provide every provider with a safe and healthful workplace” Occupational Safety and Health Act of North Carolina (OSHANC) -1973
The Occupational Safety and Health Administration ( or OSHA) has used the Federal mandated General Duty Clause approved in 1970 under the OSHA Rules which requires that employers provide every worker with a safe and healthful workplace.
North Carolina has its own, state-administered OSHA program that must enforce compliance through inspection with all Federal rules.
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4. OSHA’s Mandate OSHA’s mission is to protect the healthcare provider
OSHA Rule is required compliance under Federal Law
There is sometimes confusion about what OSHA responsibilities are in healthcare settings. OSHA’s mission is to protect providers and in this case those providers are healthcare providers. Unlike The Joint Commission or the NC Division of Health Service Regulation (DHSR), OSHA does not have any mandate over patient care, how it is delivered or the patient outcomes. The OSHA mandate is to have employers comply with OSHA Rules, under the authority of Federal Law.
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5. Occupational Exposure to Bloodborne Pathogen Standard, 1991
In 1991, OSHA issued the first Rule covering biologic agents for BBPs, HIV, and HBV. In 2001, OSHA issued a Compliance Update to the Final BBP Prevention Rule. We will address these most recent requirements in this module, with the exception of medical waste management already covered in Module A.
Revised CPL Enforcement Document
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6. BBP Standard Scope and Application
Applies to all employees with occupational exposure to blood or other potentially infectious materials (OPIM) and includes:
All private sector employees
All public sector employees
Students receiving compensation (teaching/graduate assistants, internships)
Does not include:
Self-employed persons
Includes sole practitioners and partners
Students not receiving compensation
Other employees covers by other federal statutes
The bloodborne pathogen standard has a broad scope that covers many different types of occupational settings including those in healthcare facilities, non-healthcare facilities (like employment agencies and personnel services), and temporary worksites (like mobile blood banks and trama scenes). It is also broad in its scope as far as what is considered an employee. This includes all private and public sector employees as well as any students receiving compensation for duties being performed (such as during an internship). Employees not covered under the standard include self employed persons, students not receiving compensation, and any employee covered under other federal standards (like construction and agricultural workers)

7. Employees Potentially At Risk
Physicians and surgeons
Nurses
Phlebotomists
Medical examiners
Dentists and dental workers
Clinical/diagnostic laboratory workers
Medical technologists
Nursing home personnel
Dialysis personnel
Laundry and housekeeping employees
As part of compliance, you must identify all workers at risk for exposure to blood and other potentially infectious materials. These are just an example of employees who may be at risk at your facility.

8. Types of Occupational Exposures to Bloodborne Pathogens
Percutaneous injury (PI)
Mucous membrane
Non-intact skin
Healthcare providers work in a high risk environment, with many sharp instruments used in the delivery of patient care. Healthcare providers have the potential for injury from these sharps and exposure to a variety of potentially infectious body fluids that can harbor bloodborne pathogens.
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9. Body Fluids Linked to Transmission of HBV, HCV and/or HIV
blood cerebrospinal fluid
bloody body fluids synovial fluid
semen pleural fluid
vaginal secretions peritoneal fluid
amniotic fluid pericardial fluid
saliva in dental settings
The body fluids recognized by the CDC that are linked to transmission of hepatitis B virus, hepatitis C virus and HIV are blood, bloody body fluids, semen (not a typical occupational exposure), vaginal secretions, amniotic fluid, cerebrospinal, synovial, pleural, peritoneal, and pericardial fluids. Saliva in dental settings is included because any type of dental procedure is so frequently associated with some amount of blood being present.
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10. Bloodborne Pathogens
(b)
Pathogenic organisms that are present in human blood, and
Can cause disease in humans
Includes but not limited to:
Hepatitis B virus (HBV)
Hepatitis C virus (HCV)
Human immunodeficiency virus (HIV)
Bloodborne pathogens are considered any pathogenic organisms that are present in human blood or body fluids that can cause disease in humans. The three pathogens of most concern for bloodborne transmission are HIV, Hepatitis B virus and Hepatitis C virus.

11. Other Bloodborne Pathogens
Malaria
Syphilis
Babesiosis
Brucellosis
Leptospirosis
Staphylococcus aureus
Arboviral infections
Relapsing fever
Creutzfeld-Jakob Disease
Human T-Lymphotrophic Virus Type 1 and 2
Viral hemorrhagic fevers
That being said, there are a number of other pathogens that have been linked to blood exposures.

12. Final Rule Requirements
Written exposure control plan (reviewed yearly)
Protocols to mandate healthcare provider compliance
Program to provide PPE
Hepatitis B vaccination program
Post-exposure evaluation and follow-up program
Comprehensive hazard communication program
Accessible record keeping system - training, medical records
The OSHA BBP Rule has 10 major components that must be included in a written Exposure Control Plan that every healthcare facility is required to have. Each of these components will be discussed in this lecture. A frequently cited OSHA violation is not having protocols in place that can demonstrate what the employer is doing to mandate healthcare provider compliance. Simply providing the personal protective equipment (PPE), along with education is not enough. A more active program must be in place for those who do not comply with the facilities BBP policies. Also included in the Exposure Control Plan are the personal protective equipment (PPE) program, hepatitis B (or HBV) vaccination and post-exposure program, a hazard communication program (tags, labels, and bags) for equipment and environment, and an accessible record keeping system for training, and medical records. You can expect that OSHA inspectors will request these records if they come to your facility.
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13. OSHA Enforcement Revisions - provider Services
Shared responsibility between the contract provider and the host employer to ensure compliance with OSHA standards.
Contract provider is responsible for providing:
General bloodborne pathogen training
Appropriate vaccinations
Follow-up evaluations to exposure incidents
Host employer is responsible for providing:
Site-specific training
Personal protective equipment (PPE)
Control of potential hazards and exposure conditions
There is sometimes confusion over contract employees and who is responsible in the event of an inspection violation. OSHA considers contract providers, who send their own employees to work at other facilities, to be employers whose employees may be exposed to hazards. Because the contract provider maintains a continuing relationship with its employees, but another employer (the host employer) creates and controls the hazard, there is a shared responsibility for assuring the employees are protected from workplace hazards. The host employer has the primary responsibility for such protection, but the agency employer likewise has a responsibility under the Occupational Safety and Health Act.
In the context of OSHA's standard on Bloodborne Pathogens, the contract provider would be required, for example, to provide the general training outlined in the standard; ensure that employees are provided with the required vaccinations; and provide proper follow-up evaluations following an exposure incident. The host employer 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.
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14. OSHA Enforcement Revision – “Occupational Exposure”
Includes
“Reasonably anticipated contact” includes potential or actual contact with contaminated needles, medical waste, plumbing
Human bites that break the skin
Does not include
“Good Samaritan” acts, encourages voluntarily providing follow-up
Dietary provider, chaplains, social provider
The OSHA enforcement revision includes clarification to include those healthcare providers whose duties involve “reasonably anticipated contact” (that is, potential or actual contact) with contaminated needles, medical waste, or plumbing. Also included are exposures that can occur from human bites that break the skin of a healthcare provider. For example, a human bite could potentially happen to someone working in a psychiatric practice with mentally handicapped individuals.
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15. OSHA Enforcement Revision – Exposure Control Plan
Reviewed and updated annually* (new or modified tasks, procedures, equipment)
Procedure to evaluate circumstances surrounding exposure incidents
Use of Body Substance Isolation or Standard Precautions is acceptable as long as all provisions of standard are adhered to.
One of the most frequently cited OSHA violations is failure to review and revise the Exposure Control Plan on a yearly schedule. Each component of the plan should be evaluated to determine if any changes in practice or equipment have occurred since the last policy review.
There must also be evidence that each exposure incident reported was aggregated and that there is a procedure to evaluate the circumstances surrounding the exposure incidents. There are forms on the OSHA website that can be used for completing the process. The goal of the evaluation is to determine if anything could be done to reduce further exposures through changes in work practices, engineering controls, PPE availability, or education.
Although the OSHA BBP Final Rule has used the outdated term Universal Precautions, in the 2001 revision it states that the use of CDC Standard Precautions is acceptable as long as all provisions of the BBP standard are adhered to.
* Annual = 365 days from last review
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16. OSHA Injury Prevention Strategies
OSHA Categories
Engineering controls
Work practice controls
Personal protective equipment
Administrative controls
OSHA followed their previous industry strategies for injury prevention and maintaining employee safety in the workplace.
These include, whenever possible, use of engineering controls to improve safety. If engineering controls are not available, then the next category, work practice controls, should be used. If exposure cannot be prevented by engineering or work practice, OSHA expects the next category of prevention, personal protective equipment, to be used.
The placement of administrative controls in the hierarchy of control measures can vary by the problem or disease being addressed.
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17. Engineering Controls Remove the hazard from the provider
Should be used in preference to other control methods
Must be examined and maintained or replaced on a regularly scheduled basis to ensure their effectiveness
Engineering controls refer to the use of available devices and technology to isolate or remove the hazards from the healthcare provider. Once installed, engineering controls protect the provider permanently and do not rely on provider adherence to policy in order to be effective. It is important to understand that OSHA expects that engineering controls be used as the first line of defense to eliminate or minimize provider exposure to blood or other potentially infectious materials.
Also OSHA requires that engineering controls be examined and maintained or replaced on a regularly scheduled basis to ensure their effectiveness
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18. OSHA Enforcement Revision – Evaluation of Devices
The employer must:
Review and evaluate available and new engineering control devices on an annual basis
Train employees on safe use and disposal
Implement use of appropriate engineering controls and devices
Document evaluation and implementation in the exposure control plan (ECP)
All engineering control devices currently in use in a facility and new devices available must be reviewed and evaluated on an annual basis to ensure that the safest devices are currently in use.
Once devices have been reviewed and evaluated, employees must be trained on the safe use and disposal of any devices newly or currently in use.
Also OSHA expects documentation of appropriate evaluation and training for new safety devices when implemented.
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19. Needlestick Safety and Prevention Act November 2002
Directs OSHA to revise BBP standard to clarify requirement for employers to evaluate safer needles and involve employees in identifying and choosing devices
Requires documentation of frontline provider participation in the evaluation of safety devices and decision making in product purchasing.
In 2002, OSHA was directed to enforce the new Needlestick Safety and Prevention Act. Because the original 1991 BBP rule did not include the terminology “safety devices” many healthcare facilities were limiting use of these available products, often because of increased costs associated with safety device products. The US Congress directed OSHA to revise the BBP standard to clarify the requirement for employers to evaluate safety devices and to involve employees in identifying and choosing these devices.
This rule requires documentation of frontline provider participation in the evaluation of safety devices and decision making in product purchasing. A facility’s exposure control plan must include effective procedures for identifying and selecting safety devices, and progress made in this effort. Healthcare facilities are required to document in writing any difficulties in implementing safety devices, such as lack of market availability or interference with medical procedures.
If a safety device is not currently in the market, then you must use work practice controls to reduce risk.
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20. Examples of Engineering Controls
Needleless IV systems
Lasers, staples
One way cardiopulmonary resuscitation (CPR) airway-mask
Handwashing facilities placement
Sharps containers
Self-sheathing needles
Blunted sutures/sutureless
Safety scalpel
OSHA expects a comprehensive program of needleless devices, including needless IV systems, lasers in place of scalpels, staples in place of sutures, one way CPR airway-masks, adequate hand washing facilities in locations with BBP exposure, sharps containers placed where sharps are used so healthcare providers do not have to walk for disposal, use of self-sheathing needles if available, blunted sutures or sutureless products when medically appropriate, and use of safety scalpels that are disposable to prevent reprocessing injuries.
These products when available on the market must be evaluated by healthcare facilities to replace non-safety devices. OSHA states patient safety as the only acceptable reason for not choosing a safety device over a non safety device. For example, blunt safety needles cannot be used safely on surgery of all tissue types.
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21. OSHA Enforcement Revision - Action List
Collect data on device-related injuries including how exposure occurred . . .
type and brand of device
circumstances of injury
job category
Use information on injuries to guide the selection and implementation of safety devices
In the 2001 OSHA Enforcement Revision, healthcare facilities had to begin to collect data on device-related injuries including how exposure occurred, the type and brand of device, the circumstances involved with the injury ( i.e. what time of day it was and the location where the injury occurred), type of sharp injury (i.e. puncture versus cut), the procedure or activity when injury occurred, and the job category of the injured healthcare provider.
The purpose of this practice is to use information on injuries to guide the selection and implementation of safety devices for your facility.
If a device is associated with injury then it should be carefully evaluated and possibly replaced.
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22. NEVER Recapped by Hand Removed from disposable syringes
Bent, cut, or broken by hand
Prior to the OSHA BBP Standards taking effect in 1991, needles and syringes were generally recapped by hand, needles were removed from disposable syringes, or needles were bent, cut, or broken by hand. Some nurses have been observed to continue twisting needles off of syringes for disposal when they have a very small sized sharps container so the container does not fill so quickly. Old habits are hard to break. Implementing a change in how a task is performed is difficult because work practices are behavior-based.
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23. Control Measures Work Practice Controls
Alterations in the manner in which a task is performed to reduce likelihood of exposure
Perform hand hygiene as soon as possible after glove removal or contact with body fluids
All PPE removed as soon as possible after leaving work area and placed in designated container for storage, decontamination, or disposal
Used needles and sharps shall not be sheared, bent, broken, recapped or resheathed by hand.
If there are no engineering controls commercially available to eliminate the risk of a blood exposure, then organizations must evaluate if alterations in the manner in which a task is performed can reduce the likelihood of BBP exposure.
Some examples of work practices include
performing hand hygiene as soon as possible after glove removal or contact with body fluids,
removing all PPE as soon as possible after leaving work area and placing in a designated container for storage, decontamination, or disposal,
removing devices that may allow used needles and sharps to be sheared, bent, broken, recapped or re-sheathed by hand.
It is always a good idea to check with staff and observe equipment that has been purchased or brought into an organization that could be a risk, such as needle collection devices that have the capability of allowing needles to be bent or twisted off rather than disposed of with needle and syringe intact.
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24. Control Measures Work Practice Controls
Considerations (cont.):
All procedures performed to minimize splashing and spraying that could result in exposure to blood and body fluids
Prohibit eating, drinking, smoking, applying cosmetics or lip balm in work areas where reasonable chance of exposure
Prohibit storage and/or consumption of food and drink where blood or other potentially infectious materials (OPIM) are present
The idea of work practice control measures is to evaluate all patient care procedures performed to make modifications that will minimize splashing and spraying that could result in mucous membrane or intact skin exposure to blood and body fluids. A policy statement must be included for healthcare providers when in direct patient care areas to prohibit eating, drinking, smoking, applying cosmetics or lip balm in work areas where there is a reasonable chance of BBP exposure. Also, organizations must, by policy, prohibit storage and/or consumption of food and drink where blood or other potentially infectious materials are present. For example, healthcare provider lunches and drinks cannot share the same refrigerator as lab specimens that have been collected from patients.
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25. Personal Protective Equipment (PPE)
Gloves, masks, protective eyewear
Puncture-resistant gloves and thimbles
Double gloves
When exposure risks cannot be mitigated by engineering controls with safety devices or reduced by work practice changes and the risk of exposure to BBP remains possible, then the use of personal protective equipment (PPE) is the last in the hierarchy of control measure categories. PPE is specialized clothing or equipment used by healthcare providers to protect themselves from direct exposure to blood or other potentially infectious material. Employers must first provide and also assure that the employee uses the appropriate PPE such as gloves, gowns, laboratory coats, fluid resistant aprons, face shields or masks, eye protection and mouthpieces, resuscitation bags, pocket masks or other ventilation devices.
By assure, OSHA means that if a healthcare provider is observed or reported not to be using PPE when appropriate, a policy must be in place and be implemented to discipline the employee. OSHA has given examples of such a disciplinary policy: for a first offense, a warning; second offense, require attending a re-education class; third offense, affecting merit raise; and fourth offense, termination.
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26. Protective Clothing
Wear gowns, lab coats, or uniforms that cover skin and personal clothing likely to become soiled with blood, saliva, or infectious material
Change if visibly soiled
Remove all barriers before leaving the work area
Healthcare providers should wear long-sleeved disposable or reusable gowns, lab coats, or uniforms that cover skin and personal clothing likely to become soiled with blood, saliva, or infectious material (for example, when spatter and spray of blood, saliva, or other potentially infectious material to the forearms might occur).
Healthcare providers should change protective clothing when it becomes visibly soiled or as soon as possible if penetrated by blood or other potentially infectious fluids. All protective clothing should be removed before leaving patient care or laboratory areas.
Photo credit: Lt. Col. Jennifer Harte, U.S.A.F. Dental Investigation Service, Great Lakes, IL.
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27. Recommendations for Gloving
Remove gloves that
are torn, cut or punctured
Gloves are worn for three reasons:
To minimize the risk of healthcare providers acquiring infections from patients.
To prevent pathogenic organisms from being transmitted from healthcare provider to patients.
To reduce contamination of healthcare provider's hands by organisms that can be transmitted from one patient to another
If the integrity of a glove is compromised by tears, cuts, or punctures, it should be changed as soon as possible. Surgical or examination gloves should not be washed before use, nor should they be washed, disinfected, or sterilized for reuse. Washing of gloves can cause a condition known as “wicking,” or penetration of liquids through undetected holes in the gloves. These circumstances may increase the risk of wound contamination and exposure of healthcare provider hands to microorganisms from patients. Disinfecting agents, oils, certain oil-based lotions, and heat treatments such as autoclaving may result in deterioration of gloves.
Photo credit: Lt. Col. Jennifer Harte, U.S.A.F. Dental Investigation Service, Great Lakes, IL.
Do not wash, disinfect
or sterilize gloves for reuse
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28. Protective Face Masks, Surgical Masks, and Eye Guards
Required when contamination of mucous membranes with body fluids may occur through splashes or aerosolization of these fluids.
Prescription glasses may be used as protective eyewear as long as they are equipped with solid side shields.
If protective eyewear is chosen over the use of a face shield, the eyewear must be worn in combination with a mask to protect the nose and mouth.
For occupational exposure, healthcare provider must have PPE that prevents mucous membrane exposure of the eyes, nose, and mouth that may occur through splashes or aerosolization of these fluids. OSHA allows prescription glasses to be used as protective eyewear as long as they are equipped with side shields. Of course, if protective eyewear is chosen over the use of a face shield, then the eyewear must be worn in combination with a mask to protect the nose and mouth.
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29. Personal Protective Clothing Summary
Must be provided by the employer at no cost, in appropriate sizes and housed in accessible locations for the employee.
Mechanism must be in place for cleaning, laundering or disposing of employees’ protective clothing.
Mechanism must be in place for replacement or washing of an employee-owned uniform or clothing if it becomes contaminated.
(OSHA required)
Another frequent citation by OSHA is not having PPE available in a variety of sizes and readily accessible to where the healthcare provider needs to use it. For gloves this means small, medium, and large sizes must be available. Employers must also provide for the cleaning and laundering of PPE. The employer cannot expect or even allow the healthcare provider to take PPE home for cleaning and laundering. This is to reduce to migration of contaminants in the community and home environment. Another option is that the PPE be disposable such as disposable gowns instead of cloth lab coats. Disposable gloves, of course, should be replaced immediately when visibly soiled, torn, or punctured. Finally, a mechanism must be in place for replacement or washing of an employee-owned uniform or clothing if it becomes contaminated. This can be tricky; for example, if shoes are contaminated, replacement is the likely option. If washing of contaminated clothing is needed, is there a washer on site? If the item is dry clean only, then a replacement may be the only option unless a dry cleaner that meets all OSHA, BBP rules can be identified, confirmed and contracted for use.
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30. HBV Vaccination
Within 10 days of initial job assignment, HBV vaccination must be offered to all employees whose jobs include risk of directly contacting blood or other potentially infectious material.
Vaccinations shall be given according to recommendations for standard medical practice.
A declination form must be signed by employee who refuses the HBV vaccination (including those who do not complete the 3 shot series).
Another commonly cited OSHA violations is employers not providing hepatitis B virus (or HBV) vaccination according to the standards. Hepatitis B vaccinations have to be offered, at no cost to the employee, after training is provided on the epidemiology of Hepatitis B virus and the efficacy of the Hepatitis B vaccine, and within 10 days of initial job assignment for all employees whose jobs include risk of directly contacting blood or other potentially infectious material. A list of employees that are at risk of bloodborne pathogen exposure must be created and reviewed yearly.
The vaccinations shall be given according to recommendations for standard medical practice. One issue that has come up is some healthcare organizations had been purchasing pediatric doses of the vaccine and combining them to give the required amount for an adult dose. This practice is not acceptable and is discouraged by the CDC. Combining the two pediatric doses has resulted in more healthcare providers demonstrating a suboptimal antibody response.
Employees who refuse the hepatitis B vaccine for any reason or do NOT complete all 3 of the vaccine shots must sign a declination form. If employees don’t receive the second or third vaccination, despite numerous reminders by the end of a year from starting the series, then employers must obtain a declination form for each of the missing HBV immunizations. This is a frequent citation.
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31. Despite employers and healthcare providers best efforts using all the control measures just described, exposures sometimes do still happen. Employers who have employees at risk for BBP exposure must have a post-exposure policy in place.
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32. Post-Exposure Evaluation and Follow-up
Following report of an exposure incident, the employer shall make immediately available to employee a confidential medical evaluation and follow-up
Employer shall document the route of exposure, HBV and HIV status of the source patient, if known, and the circumstances under which the exposure occurred
Employer shall notify the source patient of the incident, obtain consent if necessary and test the source for HIV or HBV unless known positive
When an occupational exposure to bloodborne pathogens has been reported, first determine if the exposure met the definition and posed a significant risk of exposure (that is, blood or other potentially infectious materials (OPIM), and employee contact to non-intact skin, a splash to a mucous membrane, or injury from a needle stick or sharp).
Per OSHA: If a significant occupational exposure to a bloodborne pathogen is determined to have occurred, the employer shall make immediately available to employee a confidential medical evaluation and follow-up.
Employers must document in the report the route of exposure, the Hepatitis B and C, and/or HIV status of the source patient, if known, and the circumstances under which the exposure occurred. Employers must notify the source patient of the incident, obtain consent if necessary (consent is not required by law in NC), and test the source for HIV or HBV unless known positive. These OSHA rules are consistent with the NC Communicable Disease rules covered in Section A.
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33. Post-Exposure and Evaluation Follow-up
Employer shall offer to collect a blood sample from the exposed person as soon as possible to test for HIV, HBV, and HCV (if requested, must hold for 90 days)
Employer shall offer HIV testing of baseline, 6 weeks, and 6 months after exposure
Follow-up shall include counseling, medical evaluation of any febrile illness that occurs within 12 weeks
Post-exposure prophylaxis when indicated, as recommended by US Public Health Service
Employers must offer (but cannot force) to collect a blood sample from the exposed person as soon as possible to test for HIV and or HBV status. And if requested by the employee, the employer must hold the blood sample for up to 90 days to allow the employee time to decide on testing.
The post-exposure testing must be offered free to the employee, and for HIV, testing should be done at baseline, 6 weeks, and 6 months after exposure. In addition, post-exposure follow-up must include counseling, and medical evaluation of any febrile illness that occurs within 12 weeks.
If the source is known or tested positive for a bloodborne pathogen, post-exposure prophylaxis may be indicated as recommended by US Public Health Service. The US Public Health service follows the CDC Guidelines. An Infectious Disease specialist may be needed to determine an appropriate regimen for prophylaxis for someone on HIV treatment because of the risk of resistance.
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34. Sharps Injury Log
Revisions to OSHA’s Recordkeeping rule, effective January 1, 2002, requires a record of all sharps injuries.
May use the OSHA’s recordkeeping rules 300, 301, 300A forms or must use a separate sharps injury log that is equivalent.
Sample forms in January 19, 2001 Federal Register Recordkeeping Revision
Revisions to OSHA’s Recordkeeping rule that became effective January 1, 2002, require a record of all sharps injuries.
Employers may use OSHA’s revised recordkeeping rules, now called the 300, 301, 300A sharps injury logs, or must use a separate sharps injury log that contains equivalent information.
Sample sharps injury forms are available at the back of the January 19, 2001 Federal Register 1904 Recordkeeping Revision or on the OSHA website.
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35. Post-exposure Management Program
Clear policies and procedures
Education of healthcare provider
Rapid access to
Clinical care
Post-exposure prophylaxis (PEP)
Testing of source patients/healthcare provider
Despite our best efforts, blood exposures will likely continue to occur. Post-exposure management remains an important component of a complete program to prevent infection following exposure to blood. Elements of an effective post-exposure management program include:
Policies and procedures that clearly state how to manage exposures.
Education of healthcare provider in prevention strategies (including evaluation of safety devices), principles of post-exposure management, the importance of prompt reporting, and post exposure prophylaxis (or PEP) efficacy and toxicity.
Resources for rapid access to clinical care, post-exposure prophylaxis, as well as testing of both source patients and exposed healthcare providers (preferably with a rapid HIV test).
Except for institutional settings that have an in-house occupational health specialist, coordination with off-site infection control or occupational health services likely will be necessary. A healthcare professional who is qualified to manage, counsel, and provide medical follow-up should be selected before staff are placed at risk. Ensure that this person is familiar with the OSHA application of risk assessment and management.
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36. Now we are changing to the topic of hazard communication
Now we are changing to the topic of hazard communication. This is a reminder that not just regulated waste needs to have a biohazard label. Refrigerators that contain any items that meet the OSHA regulated waste definition must have a biohazard tag or label that meets the OSHA requirements as shown here.
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37. Tags, Labels, and Bags
Tags that are orange-red in color with a contrasting background are acceptable;
Tags shall contain the word “BIOHAZARD” or the biological hazard symbol and;
State the specific hazardous condition or the instructions to be communicated;
Word and message must be understandable to all.
Biohazard signage must be orange-red in color with a contrasting background. Tags shall contain the word “BIOHAZARD” or the biological hazard symbol and state the specific hazardous condition or the instructions to be communicated, and the words and message must be understandable to all who come in contact with the item.
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38. Tags, Labels, and Bags (cont)
Label or tag may be part of container or affixed as closely as possible by wire or adhesive to prevent their loss
Red bags or red containers may be substituted for labels on containers of IW
All employees must be informed of meaning of labels/tags
OSHA requires that equipment that may be contaminated with BBPs should be completely decontaminated prior to being shipped offsite for repairs, or returned to the rental company. If the equipment or parts of it cannot be completely cleaned and disinfected prior to transport, it must have a label or tag, on or affixed as closely as possible to the contaminated parts by wire or adhesive to prevent their loss.
Red containers or red bags may be substituted for labels of NC regulated medical waste. OSHA requires that all employees will be informed of the meaning of labels/tags. This should be included in orientation and annual OSHA BBP training updates.
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39. Handling Specimens
Employers may avoid labeling only if all employees who have contact with specimen containers can recognize them as requiring Universal (Standard) Precautions and the employees have been trained to follow Universal (Standard) Precautions.
Employers must label or color-code specimen containers whenever they leave the facility.
What are the OSHA requirements for handling specimens? Employers may avoid labeling requirements such as for laboratory collection containers only if all employees who have contact with specimen containers can recognize them as requiring Universal (Standard) Precautions, and all the employees have been trained to follow Standard Precautions. However, employers must label or color-code specimen containers whenever they leave the facility.
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40. Housekeeping Practices
Employer shall assure that the worksite is maintained in a clean and sanitary condition.
Employer shall determine and implement an appropriate cleaning schedule for rooms at risk for BBP contamination, depending on the site, type of surfaces, and amount of soil present.
Employer shall ensure that housekeepers wear appropriate PPE including general purpose utility gloves during all cleaning of BBP and decontamination procedures.
For healthcare facilities the employer must assure that the worksite is maintained in a clean and sanitary condition.
The employer must determine and implement an appropriate cleaning schedule for rooms where there may be a risk for BBP contamination by the type of surfaces and the amount of soil present. Such a schedule may be daily or whenever there is visible contamination present in patient rooms, and every shift for lab benches, based on level of BBP exposure.
Employers must ensure that housekeepers wear appropriate PPE, including general purpose utility gloves, during all cleaning of BBP and decontamination procedures.
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41. Laundry Practices
Laundry provider wears protective gloves and other appropriate PPE during handling and sorting of linen.
Contaminated laundry shall be bagged at the location of use and not sorted or rinsed in patient areas.
Contaminated laundry shall be placed and transported in labeled or color-coded bags that prevent leakage.
When a facility uses Universal (Standard) Precautions in the handling of all soiled laundry, alternative labeling is acceptable if recognizable by all healthcare providers.
OSHA states that employers must ensure that laundry providers wear protective gloves and other appropriate PPE during handling and sorting of linen. Other protective attire depends on the level of contamination; for example, attire ranging from disposable gowns to plastic aprons are occasionally used. The use of masks has been sometimes enforced by OSHA for those actively sorting large amounts of linen.
Contaminated laundry shall be bagged at the location of use and not sorted or rinsed in patient areas.
Contaminated laundry shall be placed and transported in bags that are labeled or color-coded and that prevent leakage. This does not mean all laundry needs to be placed in disposable plastic bags or melt away dissolvable bags. Only laundry that is so saturated that it presents a risk of wetting through requires special bagging. Special bagging may mean a second bag if the outside of the bag has become contaminated or there is minor wet-through; or it may mean a reusable cloth bag with a rubber lining that prevents wet-through or leakage. An OSHA acceptable resort, though not environmentally friendly, for those unique situations where laundry is saturated, is the use of disposable plastic bags.
Healthcare providers should be taught to roll the wettest portion of linen to the inside. When a facility uses Standard Precautions in the handling of all soiled laundry, alternative labeling is acceptable if recognizable by all healthcare providers. For example, if all linen is treated as potentially contaminated by all healthcare providers, no additional labeling is required for linen that is visibly contaminated.
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42. provider Education and Training
Strategies to prevent occupational exposure to blood
Importance of reporting exposure incidents
New employee orientation
Annual inservices
New procedure or equipment
Education should be focused on strategies to prevent occupational exposure to blood or acquisition of BBPs by emphasizing the importance of reporting exposure incidents.
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43. Training
Employers must train at-risk employees at no cost and on paid time.
Must train at time of initial assignment and at least annually thereafter, or if new occupational exposure is recognized from the literature, or new procedure or use of a new type of equipment is introduced.
Employers must train at-risk employees at no cost and on paid time. Employers must train at the time of initial assignment and at least annually thereafter, or if a new source of occupational exposure is recognized from reports in the literature, or a new procedure or type of equipment is initiated in the facility or the organization.
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44. Training Content Training program must include
accessible copy of regulatory text of standard and explanation
general epidemiology and symptoms of BBP
explanation of modes of transmission
explanation of employer’s exposure control plan and how to get a copy
The OSHA bloodborne pathogen standard requires that training programs include specific content that must be covered, including the following elements:
where an accessible copy of regulatory text of standard and explanation is located at the worksite;
the general epidemiology and symptoms of BBPs including other BBPs of significance such as syphilis - not just HBV, HIV, HCV;
an explanation of modes of transmission;
and an explanation of employer’s exposure control plan and how the employees can obtain a copy.
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45. Training Content Training program must include
explanation of appropriate methods for recognizing tasks that may involve exposure
explanation of the use and limitations of methods to prevent exposures
info on types, use, locations, removal, handling of PPE
explanation of basis for selection of PPE and safety devices
The training program must also include:
an explanation of appropriate methods for recognizing tasks that may involve exposure;
an explanation of the use and limitations of methods to prevent exposures;
information on the types, use, locations, removal, and handling of PPE specific to the organization or facility; explanation of basis for selection of PPE and safety devices.
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46. Training Content Training program must include
info on actions and persons to contact for exposure to BBP
method for reporting on exposure incidents
info on post-exposure evaluation and follow-up
explanation of signs and labels
opportunity to question trainer about standard; therefore training cannot be totally by videotape
The employee training program must include
information on actions to take and persons to contact for exposure to BBP (OSHA inspectors frequently will ask employees this question during inspections of facilities);
the method for reporting on exposure incidents;
information on post-exposure evaluation and follow-up;
explanation of signs and labels.
It is also required that the Bloodborne Pathogen training be interactive. If a video or computer training program is used, as is most commonly done now for annual updates, OSHA requires someone with expertise in bloodborne pathogens to be immediately available either by phone or computer at the time the healthcare providers are attending the training. The idea is that healthcare providers can have their questions answered immediately and not have to wait any amount of time to speak directly with a trainer.
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47. Recordkeeping
The employer must keep training records with the following information:
The dates of the training session
The contents or a summary of the training session
The names and qualifications of the persons conducting the training
The names and job titles of all persons attending the training sessions
Employers must keep these records for 3 years from the date of the training session
OSHA requires that all healthcare organizations must keep training records with the following information:
The dates of the training session,
The contents or a summary of the training session,
The names and qualifications of the persons conducting the training,
The names and job titles of all persons attending the training sessions
Employers must keep these records for 3 years from the date of the training session.
It is recommended that the training records are kept in a central location such as a notebook or scanned into a file that can be easily accessed should OSHA visit your organization. OSHA will most certainly request this information.
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48. OSHA NC ORGANIZATIONS Director - (919) 807-2900
Consultative Services - (919)
Infection Control - (919)
Compliance Bureau
Eastern: (336)
Western: (919)
NC Department of Labor
1-800-LABOR NC
If you would like to contact NC OSHA directly, this slide contains the pertinent phone numbers. They provide consultative services to answer questions about OSHA rules and implementation.
Congratulations on completing module B. You may now continue on to Module C, Epidemiology and risk of infection.
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