THE COHEN GROUP
  Environmental Health & Safety Consulting Services

The Cohen Group Newsletter - Volume 5  Issue 2, Article 3,  April 2003

Is Your Bloodborne Pathogens Program Up To Date?

By Joy E. Fleming, MPH

Now that we are well into 2003, it may be time to perform annual updates and training for Health and Safety Programs.  The Bloodborne Pathogens Standard requires that the Exposure Control Plan be updated and employee training be performed at least annually or whenever there have been changes to the plan. 

The Bloodborne Pathogens Standard is applicable to general industry employers that have occupational exposures with “reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potential infectious materials (OPIM) that may result from the performance of an employee’s duties. 

Are ERT Members Covered?

In addition to obvious job tasks that involve blood or OPIM, an employee, whose primary job duty is to provide first aid to workers such as someone who is designated to provide first aid as part of an Emergency Response Team, is covered under the standard.   According to Cal/OSHA, Emergency response team members, who are assigned to administer first aid only as a duty that is collateral to their routine work assignment, are included in these requirements, however, the employer is not required to offer a pre-exposure Hepatitis B vaccination. If a first aider is exposed to blood while rendering first aid, then the individual must be vaccinated with 24 hours of the exposure.

Are Janitors or Housekeepers Covered?

Occupations such as janitors, housekeepers, plumbers and maintenance workers should not be overlooked for inclusion in the plan.  Training on recognizing the potential hazards should be provided.   Laundry workers, especially those involved in cleaning bedding or protective garments, need to be included in the plan.  Dry cleaning establishments that maintain contracts with health care facilities, fire departments, and/or police departments and could reasonably anticipate clothing contaminated by blood or other potentially infectious materials will have to adhere to this standard. 

What about Construction?

The construction industry with SIC codes 152-179 are exempted from coverage under the standard but construction industry employers still have a regulatory responsibility to protect their employees from bloodborne pathogens.  Employees designated to render first aid may have occupational exposures to blood or OPIMs.  Therefore, construction employers are subject to the Injury and Illness Prevention Program requirements and personal protective equipment requirements.

There have not been any regulatory changes to the Bloodborne Pathogens Standard since 2001.  Federal OSHA released a new compliance directive CPL 2-2.69 effective November 2001 that clarified the position on needle removal in order to re-use phlebotomy blood tube holders.  The compliance directive stated that removing the needle from a used blood-drawing device is rarely, if ever, required by a medical procedure.  Since this device also utilizes a double-ended needle, then the removal would expose employees to additional risk.  In order to prevent exposure to the contaminated hollow bore needle at both the front and back ends, the blood tube holder with the needle attached must be immediately discarded into an accessible sharps container.

There are many more aspects of the Bloodborne Pathogens Standard that affect many employers.  If you do not currently have a program, we advice you do to conduct a hazard assessment to determine if there are assigned duties that would potentially expose an employee to blood or blood products. Something as simple as handling sharps may pose a risk of exposure to your employees.   Remember, according to the standard, actual exposure is not needed to be subject to these requirements.  If there is such a task, then you should promptly develop and implement an Exposure Control Plan. If there is no such task, keep a copy of your hazard assessment to demonstrate that you have evaluated your workplace for possible exposures.