Safety Articles

Article # 13105

A Look at OSHA's Far-Reaching Bloodborne Pathogens Regulation

OSHA's regulations dealing with the control of diseases caused by workplace exposure to blood and other body fluids cut across industry lines. These regulations are found in both Federal OSHA regulations, 29 CFR Section 1910.1030, and California regulations, 8 CCR, part 5193. While many employers do not believe that they are regulated by this standard, in fact they are.

The new standard requires that any employer with employees "whose reasonably anticipated duties may result in occupational exposure to a potentially infectious substance must implement an Exposure Control Plan and training program." This job related exposure could involve Police and Fire Department personnel, those who work in the janitorial fields, workers trained in CPR as part of an Emergency Response Team, personnel who work around hazardous waste, end even those employees who might be responsible to render first aid or clean up after a minor medical incident. The latter is the case at a foundry, which primarily produces ductile iron castings. The foundry is in full compliance with OSHA's bloodborne pathogen standard. "Although normal business operations don't lend themselves to exposure to bloodborne pathogens, as someone responsible for rendering first aid, I've got to make sure that we are in compliance," says Josh Kurtz, safety director at the foundry.

Recently, an employee at the foundry received a bad cut and required first aid. "We followed the ‘universal' precaution(which means that all blood or other potentially infectious material will be considered infectious regardless of the perceived status of the source individual)," says Kurtz. "We first put on latex gloves, then brought out the bloodborne pathogen kit and administered first aid. When a little blood dropped on a desk, we closed that area off, put a germicide on the blood, and followed the instructions on the kit for proper disposal."

Prior to the accident, Kurtz made sure everyone responsible for first aid in the plant had been properly trained to use the kit. Depending on the potential exposure, the range of training that is required varies considerably. The basic requirements mandate a training program to include the following elements:
• Description/Overview of the Control Plan
• Description of potential exposure source
• Description of engineering controls to minimize exposure
• Work rules to eliminate potential exposure
• Description of personal protective equipment
• Training on the use of the personal protective equipment
• Decontamination procedures
• Medical waste handling procedures
• Training on the medical surveillance program
• Record keeping requirements
As with most of OSHA mandated training programs, there are no set number of hours required to comply with this standard. Basic training programs for site personnel can be delivered in a two-hour training session. Employees with a moderate threat of exposure such as Police Department personnel may take up to four hours. More complicated programs for workers who have significant exposure can run up to eight hours.
If your company needs Bloodborne Pathogen training or is looking to implement a Bloodborne Pathogen program, contact the National Safety Council at 1-800-621-6244.

When you're unsure about the level of training your company requires, contact your nearest OSHA office for a clarification.