OSHA Bloodborne Pathogen Standard

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Bloodborne Pathogens Regulatory Review

OSHA requires all employers that can “reasonably anticipate” exposure of employees to infectious materials to prepare and implement a written exposure control plan. Non-health care workers are not covered under this standard unless they are trained to provide first aid and or cardiopulmonary resuscitation (CPR) as a mandatory part of their employment. As long as first aid and /or CPR are voluntary, most of KPA’s clients are not affected by this regulation. In the absence of an infirmary, clinic, or hospital within 3-4 minutes of the workplace (per OSHA clarification of CFR1910.151), which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render first aid. Adequate first aid supplies shall be readily available and this Bloodborne Pathogens regulation will be applicable.

Bloodborne Pathogens Discussion

The following is a brief summarization of California Code of Regulations (CCR) and Code of Federal Regulations (CFR) that apply to bloodborne pathogens and how auto dealerships may be affected.

OSHA requires that the dealership perform an exposure determination concerning certain job classifications and whether or not these employees may incur a possible exposure to blood or other potentially infectious materials.
Non-health care workers are not covered under this section unless they are trained to provide first aid and/or cardiopulmonary resuscitation (CPR) as a mandatory part of their employment.
In the absence of an infirmary, clinic, or hospital within 3-4 minutes of the workplace (per OSHA clarification of CFR1910.151), which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render first aid. Adequate first aid supplies shall be readily available and the dealership may have to implement a “Bloodborne Pathogens Exposure Control Plan.”
If dealers are going to rely on third party emergency care providers for all of their emergency care OSHA recommends that they should:
- Contact the emergency care provider to ensure they are able to respond within the necessary time frame
- Ensure all employees are trained on how to contact the preferred emergency care provider
If an “occupational exposure” is present, then the dealership will be required to implement a written “Bloodborne Pathogens Exposure Control Plan” consisting of job classification, methods of compliance, engineering and work practice controls, personal protective equipment, disposal and labeling of contaminated items, housekeeping, hepatitis B vaccination and post-exposure evaluation and follow up, training, and record-keeping.
Universal precautions should be observed at the dealership. All blood or potentially infectious material should be considered infectious regardless of the perceived status.
Sinks with running potable water should be located in every department where employees can wash with soap and water should they have a potential exposure to infectious blood or materials. If a sink is not feasible, then antiseptic hand cleanser or towelettes should be available to employees. Hand washing should still take place as soon as possible after the potential exposure.
Employees must not eat, drink, smoke, or handle contact lenses in areas that may have exposure possibilities.
All personal protective equipment such as gloves, eye protection, and mouthpieces must be provided by the dealership.
When personal protective equipment (PPE) is removed, it shall be placed in a designated area or container for storage, washing, decontamination or disposal.
Employers must ensure that the worksite is maintained in a clean and sanitary condition.
Contaminated work surfaces must be decontaminated with a disinfectant after being exposed to blood or other infectious materials.
Whenever contaminated laundry is wet and presents a reasonable likelihood of soak-through of or leakage from the bag or container, the laundry shall be placed and transported in bags or containers which prevent soak-through and/or leakage of fluids to the exterior.
The dealership must make available the hepatitis B vaccine and vaccination series to all employees who have occupational exposure, and post-exposure evaluation and follow-up to all employees who have had an exposure incident and at no cost to the employee.
The dealership must label all contaminated laundry, bags, and containers with the appropriate international orange-red biohazard symbol.
Designated workers must receive training that includes a copy of the regulations, how bloodborne pathogens are transmitted, use of PPE, controls and work practices, vaccination program for exposed employees, emergency response, and labeling requirements. Training records must be kept for 3 years.
All exposure incidents must be documented.

See this OSHA interpretation letter.

Bloodborne Pathogens Definitions

1)	Blood:	human blood, human blood components, and products made from human blood.
2)	Bloodborne Pathogens:	pathogenic microorganisms that are present in human blood and can cause disease in humans. These pathogens include, but are not limited to, hepatitis B virus (HBV), hepatitis C virus (HCV) and human immunodeficiency virus (HIV).
3)	CCR:	California Code of Regulations.
4)	CFR:	Code of Federal Regulations.
5)	Contaminated:	the presence or the reasonably anticipated presence of blood or other potentially infectious materials on a surface or in or on an item.
6)	Contaminated Laundry:	laundry which has been soiled with blood or other potentially infectious materials or may contain sharps.
7)	Decontamination:	the use of physical or chemical means to remove, inactivate, or destroy bloodborne pathogens on a surface or item to the point where they are no longer capable of transmitting infectious particles and the surface or item is rendered safe for handling, use, or disposal.
8)	Engineering Controls:	controls (e.g., sharps disposal containers, self-sheathing needles, safer medical devices, such as sharps with engineered sharps injury protections and needleless systems) that isolate or remove the bloodborne pathogens hazard from the workplace.
9)	Exposure Incident:	specific eye, mouth, other mucous membrane, non-intact skin, or parenteral contact with blood or other potentially infectious materials that results from the performance of an employee’s duties.
10)	Handwashing Facilities:	facility providing an adequate supply of running potable water, soap, and single use towels or hot air drying machines.
11)	HBV:	hepatitis B virus.
12)	HCV:	hepatitis C virus.
13)	HIV:	human immunodeficiency virus.
14)	Occupational Exposure:	reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee’s duties.
15)	Other Potentially Infectious Materials (OPIM):	(1) The following human body fluids: semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva in dental procedures, any body fluid that is visibly contaminated with blood, and all body fluids in situations where it is difficult or impossible to differentiate between body fluids; (2) Any unfixed tissue or organ (other than intact skin) from a human (living or dead); and (3) HIV- containing cell or tissue cultures, organ cultures, and HIV, HBV, or HCV-containing culture medium of other solutions; and blood, organs, or other tissues from experimental animals infected with HIV, HBV, or HCV.
16)	Personal Protective Equipment:	specialized clothing or equipment worn by an employee for protection against a hazard. General work clothes (e.g., uniforms, pants, shirts or blouses) not intended to function as protection against a hazard are not considered to be personal protective equipment.
17)	Source Individual:	any individual, living or dead, whose blood or other Potentially infectious materials may be a source of occupational exposure to the employee. Examples include, but are not limited to, hospital and clinic patients; clients in institutions for the developmentally disabled; trauma victims; clients of drug and alcohol treatment facilities; residents of hospices and nursing homes; humans remains; and individuals who donate or sell blood or blood components.
18)	Universal Precautions:	an approach to infection control. According to the concept of Universal Precautions, all human blood and certain human body fluids are treated as if known to be infectious for HIV, HBV, HCV, and other bloodborne pathogens.
19)	Work Practice Controls:	controls that reduce the likelihood of exposure by altering the manner in which a task is performed.