Welcome to this session of OSHA regulations and how the bloodborne pathogen standard affects you.
In this section we will discuss how OSHA’s regulation on Bloodborne Pathogens affects you. We will discuss the history and effective dates of the regulation, the purpose of the regulation, requirements that the employer must follow and discuss the exposure control plan. With the advent of the Needlestick Prevention Act in 2000, there are some additional requirements that we’ll point out .
This is a relatively new OSHA regulation! It was first released in 1991 and most recently was updated after ten years of evolution! The bloodborne pathogen standard was first published in 1991 with an effective date of March the next year. All employees were required to have a written exposure control plan by May of the next year. In 2000, President Clinton signed into law the Needlestick Safety and Prevention Act which called for a review and updated of OSHA’s Bloodborne Pathogen standard to reflect changes in technology and procedures which could reduce the number of needlestick injuries in the medical field.
The purpose of the standard was to reduce the number of incidents and illnesses that were caused by diseases transmitted by blood. Specifically, Aids and Hepatitis were targeted in this regulation. The regulation only covers those instances that are work related!!
Employers are required to provide training about bloddborne diseases to any employee who has the potential to be exposed to that type of disease. Employers were required to provide equipment and protective measure and to keep records of their actions. Employers must protect their workers from these bugs!!
Originally, the thrust of the regulation was aimed at hospitals and care providers. As time went on, other workers were included in the regulation, due to their exposure to blood and body fluids that could carry nasty diseases. Still, the emphasis is on Aids and Hepatitis.
The regulation currently affects other workers who may come into contact with this type of hazard as a result of their occupation. Maintenance workers are often called in to clean up after an accident, soiled linens and towels are often found in the housekeeping area and waste handling personnel are often exposed to blood in the normal routine of their daily tasks.
Every once in a while a medical worker gets stuck with a needle. This can happen during the process of administering medication or drawing blood.
When a needlestick injury occurs you have to record it in the needlestick log. It may also be recordable on the OSHA recordkeeping log, so check with your administrator. Treat the worker in accordance with the rules of bloodborne pathogens. If the worker has not been vaccinated for hepatitis, gamma globulin may be called for. Try to find out if the blood was contaminated! Be careful of the privacy issues, too!
Bloodborne Pathogen rules are made to cover workers who normally are exposed and these workers should be trained on the hazards that they are exposed to. On the other hand, OSHA didn’t want to punish a worker for saving a fellow employees life when they become contaminated with blood. During these rare cases, a De Minimus violation citation would be issued to OSHA. This violation does not carry a fine, but does remind workers that they need to protect themselves from bloodborne pathogens. Most first responders and medical personnel are trained on the requirements of the standard, but in isolated cases a non-medical person may provide first aid who would normally not be covered by the regulation. We certainly don’t want people to stand around and watch a worker die because “OSHA won’t let me help you”,.. Do we? This rule normally does NOT apply to health care providers who are supposed to be trained. (OSHA doesn’t have too many “gimme’s”, do they?)
OSHA defines an occupational exposure as any reasonably anticipated contact with blood or any other potentially infections material that could result from the workers normal duties. In other words, it must be job related, and it must be reasonably anticipated. Most office workers do not have to be trained in this standards, but those office workers who are designated as first responders or first aid providers must be trained to this standard.
This is a list of various materials that may contain bloodborne pathogens. You can see that it is not limited to just blood.
Because of all the types of exposures out there, it is important that workers be trained on HIV/AIDS and Hepatitis. There is currently no cure for Aids, but there is treatment for Hepatitis and there is a vaccine to keep people from getting Hepatitis. Your children may have gotten this vaccination at school already!
Hepatitis is a disease that affects the liver. It causes the skin and eyes to become yellowed, or jaundices. Patients often have abdominal pain, fever and vomit. They become fatigued and their urine becomes dark.
Aids is the Acquired Immune Deficiency Syndrome and reduced the bodies ability to fight off normal diseases. Some of the symptoms of AIDS are Fever, swollen glands, diarrhea, weight loss and mental disorientation.
Needles are a primary source of bloodborne pathogen contamination. Manufacturers make safe needles and some that are not as safe. The issue of cost comes into play and your administrator has a say there, so you have to convince them that it is a wise investment to spend a little more money to get a safer needle!
Employees who may become infected on the job or exposed to these diseases must be trained in the methods in which the pathogens can get into their body.
The regulation requires employers to provide engineering controls to reduce the chances of exposure to bloodborne pathogens. Some examples of engineering controls are surgical gloves and masks, sharps containers and self retracting needles.
Control methods that can keep workers safe include simple hand washing techniques and methods to recap needles without getting contaminated. Procedures for removing contaminated gloves are a good example of a work practice control.
Other types of control measures are the simple use of Personal Protective Equipment. Gloves, gowns and face shields can provide some protection for open cuts or skin abrasions and keep infected material from getting into the body through the eyes, nose or mouth.
Universal Precautions are a special measure of control. In this case, all blood or body fluids are assumed to be contaminated and workers are required to protect themselves from exposure to that blood. This is a very effective approach to infection control.
According to the Center for Disease Control, HBV Vaccinations are the most important part of HBV infection control. This is due to the fact that we still get a lot of needle sticks or workers who don’t wear their PPE all the time. The vaccination is a set of three inoculations that will protect workers from Hepatitis for a period of up to ten years!
Let’s say that a worker does get some blood on their skin. For some reason, in the normal routine of their job, they are cleaning up a machine or working on a patient, lift their hand and find some one elses blood on their hand.
The worker must report this incident to the supervisor. The company must provide a confidential medical evaluation which will include how the blood got on the worker, the status of the individual whose blood it is (if we can find that person!) and a testing of the blood sample as soon as possible. If the worker hasn’t been inoculated against Hepatitis, a post exposure vaccine may be administered. The worker may require counseling, as well! After all, how would you feel if this happened to you and you had to go home and tell your family that you may have AIDS….
Waste disposal of this type of material is critical. They must be disposed of in leak proof bags that are tagged and labeled. What type of materials are we talking about? Anything that may contain a contaminated sample that is pourable, drippable or compressible. If you squeeze the material and blood is released, you should consider it to be a regulated waste.
Your work area should be maintained in a clean and sanitary condition anyway. If you find that there is a contamination, clean the area with a VIRUCIDE. Something that will kill the virus. Normal soap won’t do it. Hospital grade virucides are available at most cleaning companies, but if you don’t have any, use a solution of 1 part bleach to ten parts of water. That has been proven to be very effective against the virus. Don’t use full strength bleach, follow the 1/10 rule!!!
We want all of our workers to know that this waste is NOT just some thing to toss into the dumpster. So we have to label the bags with labels that alert them to the hazard and the fact that this is a biological waste product.
When there is an incident, the company must document information and keep it confidential and accurate. They must record the name and social security number of the worker, include a copy of the medical records and physicians written opinion regarding the exposure on file.
For each employee with an occupational exposure incident, the employer shall maintain these records for as long as the employee works for the company. When the worker leaves the company, the records must still be maintained for a period of 30 years! These records must be kept confidential!
Whenever there is a needlestick, the incident must be recorded. Information regarding the type and brand or device that caused the incident must be recorded, along with the area or department that the incident occurred in. A brief description of how the incident happened is also required to be documented.
The employers exposure control plan must identify the methods used to determine how a bloodborne exposure could occur and how the company will train their workers. Methods of control and vaccination procedures must be documented, as well as the follow up procedures for those times when an incident does occur. Procedures to dispose of contaminated waste and the type of tags and labels used for the waste must be documented in the exposure control plan as well. Finally, a section on record keeping must be included to specify how incidents will be documented and how to maintain a sharps injury log.
The exposure control plan must be reviewed on an annual basis in order to consider the technological changes that occurred in the past year. These changes could be new types of needles or needleless systems on the market. Consideration of safer medical devices must be documented. Further, employers are required to solicit input from non-managerial employees and this solicitation must be documented in the annual exposure control plan review. In other words, once a year the people who are affected by the exposure control plan must assess it against new technology and procedures and their assessment must be documented in writing.
When President Bill Clinton signed the Needlestick Safety and Prevention Act on November 6, 2000 OSHA was instructed to revise their standard on Bloodborne Pathogens. The Needlestick Law required that this revision be enacted within 6 months in order for the law to be enforceable under the Federal Safety and Health rules. Congress specifically exempted OSHA from the normal promulgations procedures for this standard. Those standards would have required OSHA to issue a proposed regulation, then a draft and then a final regulation with opportunities for public comment along each step of the way. In order for the needlestick law to be effective, this procedure was not required and OSHA developed revisions to the standard to comply with the directives from congress.
It was determined that there were four areas of the bloodborne pathogen standard that would have to be modified. New technology and procedures had introduced new terms and definitions that could be used regarding engineering controls. These new techniques would require that any existing Exposure Control Plan be updated or revised to accommodate the new technology. Input from the employees was specifically called for in the needlestick Act so that the end use of the product would have a say in the type of needles being used, since quite often the type of needle was selected by management or procurement officers who did not use the end product, but who based their decision on cost as opposed to efficacy. The intent of the revision is to require input from non-management employees responsible for direct patient care. This requirement is to be determined in a “performance oriented” method wherein the employer must demonstrate that this solicitation has been obtained. Recordkeeping has been changed to require employers to maintain a sharps injury log to identify high risk areas and for evaluating devices. This standard
The revised regulation contains three new definitions. Engineering controls means those controls that isolate or remove the bloodborne pathogens hazard from the workplace. This could be sharps disposal containers, self-sheathing needles, safer medical devises such as sharps with engineered sharps injury protections and needleless systems. A needleless system is a device that does not use needles for the collection or withdrawal of fluids after initial venous or arterial access is established or that does not use needles for the administration of medication or fluids or any other procedure involving the potential for occupational exposure to bloodborne pathogens due to injuries from contaminated sharps. Sharps with engineered sharps injury protection means a nonneedle sharp or a need device used for withdrawing body fluids, accessing a vein or artery or administering medication or other fluids with a built-in safety feature or mechanism that effectively reduces the risk of an exposure incident.
Your mother was right!!! We should all wash our hands more often. A survey of different cities came up with these interesting statistics. Only 74% of women wash their hands after using the toilet. Only 61% of the men do! And those of us who do wash our hands generally place our hands on the door handles that those unclean hands were on when we leave the rest room! And how about the Atlanta Braves Baseball Game? A lot more women were washing their hands their,but the guys?? Hey, are you gonna eat that burger??? EEEuuuuuck!
Hanta Virus is another disease that we don’t know a lot about, but is becoming more and more widespread. It is a virus that is carried in the fecal droppings of mice. When the virus becomes airborne and human beings inhale it, the virus gets into the lungs, creates flu like symptoms and runs its course very quickly. It has a 50% mortality rate!