Bloodborne Pathogens

29 CFR 1910.1030

Components of the Standard

• Exposure Control Plan

• Methods of Compliance– Universal Precautions– Engineering and Work Practice Controls– Personal Protective Equipment– Housekeeping

Components of the Standard

Continued...

• Hepatitis B Vaccination

• Hazard Communication

• Recordkeeping

Exposure Control Plan

• Key provision of the standard, requires employer to identify exposed or potentially exposed workers, i.e., those who need training, PPE, vaccination, and situations where engineering controls would “eliminate or minimize exposure”

• The plan must be available to employees; 1910.1020 requires a hard copy be made available to workers within 15 days of request.

• The plan must also include the procedures for evaluating the circumstances surrounding an exposure incident

Exposure Control Plan

• (c)(1)(iv) requires plan to be reviewed and updated at least annually.– Plan must be updated to reflect changes in

technology that eliminate or reduce employee exposure.

– Plan MUST document consideration and implementation of appropriate, commercially available and effective engineering controls

Exposure Control Plan

• Needlestick Safety and Prevention Act– Public Law 106-430 on November 6, 2000

• An Act: To require changes in the bloodborne pathogens standard in effect under the Occupational Safety and Health Act of 1970.

Universal Precautions...

• …shall be observed to prevent contact with blood or potentially infectious materials. Under circumstances in which differentiation between body fluid types is difficult or impossible, all body fluids shall be considered potentially infectious materials. 1030(d)(1)

• In Other Words....

Engineering and Work Practice Controls

• Engineering and work practice controls to be instituted as the PRIMARY means of eliminating or minimizing exposure.– Conforms to OSHA’s traditional “hierarchy of

controls.”– The employer MUST use engineering and work

practice controls to eliminate exposure or reduce it to the lowest feasible extent.

– IF engineering and work practice controls do not eliminate exposure, the use of PPE is required.

Engineering and Work Practice Controls

• “Where engineering controls will reduce employee exposure either by removing, eliminating or isolating the hazard, they must be used.” CPL 2-2.44D

– The employer should be using - or at least have considered, and documented in exposure control plan why he/she CANNOT be using - engineering and work practice controls for work operations involving exposure to blood or OPIM.

Cost of Safer Devices

DEVICE UNIT PRICE UNIT PRICE

(conventional) (safer design)

• Phlebotomy $0.10 $0.33 needles

• “Butterfly” $0.65 $0.90 needles

• IV Catheter $0.75 $1.75

• Hypodermic $0.05 $0.25 needle/syringe

Housekeeping (4)(i)

• Employer must develop and implement a written cleaning and decontamination schedule based upon:– location within the facility– type of surface to be cleaned– type of soil present– type of procedures being performed

Housekeeping

• Areas and equipment must be cleaned and decontaminated after contact with blood etc.

• Broken glassware which MAY be contaminated must be handled by mechanical means, e.g. tongs, forceps

• Contaminated reusable sharps must to processed and stored in a manor that precludes employees from handling them

Sharps Containers

Contaminated sharps shall be discarded immediately or as soon as feasible in containers that are:

• Closable

• Puncture resistant

• Leakproof on sides and bottoms

• Labeled or color-coded

Laundry

• Contaminated laundry must be handled as little as possible, with minimum agitation

• Bagged at location of use in labeled or color-coded bags or containers

• NOT sorted or rinsed at location of use

HBV Vaccinations

• Employer must provide hepatitis B vaccination to to all employees who have an occupational exposure to BBP

• Employer must provide a post-exposure evaluation to all employees who have had an exposure incident.

Hazard Communication

• Labels and Signs– Biohazard symbol– Red bags or containers may be substituted

• Information and Training– at time of initial assignment– annually thereafter – upon task and/or procedure change

Training Material

• Appropriate for educational level, literacy and language

• Explains symptoms and epi. of BB disease

• modes of transmission• Exposure Control Plan

• Use and limitations of engineering , PPE and work practice controls

• Hepatitis B vaccine• BBP Exposure &

follow-up procedures• Must be interactive

Interactive Training

• The trainer must be knowledgeable in the subject matter as it relates to the workplace

• Unsupervised video tape and/or computer training classes are not appropriate

Recordkeeping

• Medical Records– for each employee with occupational exposure– HBV vaccine dates and status– for duration of employment + 30 years

• Training Records– dates and summary of session– name of participants and trainers– maintained for 3 years

Needlestick Prevention

• OSHA estimates that 5.6 million workers in the health care industry and related occupations are at risk of occupational exposure to bloodborne pathogens.

• CDC estimated that 600,000 to 800,000 needlestick injuries (NSI’s) and other percutaneous injuries occur annually among health care workers.

• 1/3 of all sharps injuries have been reported to be related to the disposal process.

• 62% – 88% of sharps injuries can potentially be prevented by the use of safer medical devices.

• Needlestick requirements take effect April 18, 2001.

• Occupational Exposure to Bloodborne Pathogens; Needlestick and Other Sharps Injuries; Final Rule (2001, January 18).

• There is a need for employers to select safer needle devices as they become available and to involve employees in identifying and choosing the devices.

• The updated standard requires employers to maintain a log of injuries from contaminated sharps.

• The revised OSHA bloodborne pathogens standard obligates employers to consider safer needle devices when they conduct their annual review of their exposure control plan.

• Safer sharps are considered appropriate engineering controls, the best strategy for worker protection.

• The new needlestick log will help both employees and employers track all the needlesticks to help identify problem areas or operations

• The Needlestick Safety and Prevention Act took effect November 6, 2000. It specified revisions of OSHA’s bloodborne pathogens standard and directed the agency to make these changes within 6 months.

Bloodborne Pathogen Questions

Glenn Lamson

glamson@osha-slc.gov

801-524-7914