Bloodborne Pathogens in the Workplace: Keep Your Workers Safe

Every day, more than 5.6 million workers are at risk to bloodborne pathogen exposures. Commercial and industrial facilities workers face challenges not seen elsewhere, with heavy machinery, sharp objects, and forklift injuries creating bloodborne pathogen infection.

An estimated 800,000 injuries from contaminated sharp objects occur in the U.S. every year. Workers in commercial and industrial environments that can reasonably expected to have contact with blood or other potentially infectious materials (OPIM) are at risk.

It is the employer’s responsibility to provide proper training and containment plans to ensure employees are protected and qualified to work in this particular environment.

What are Bloodborne Pathogens Exactly?

Bloodborne pathogens are contagious microorganisms in blood that can produce disease in humans. Without the proper precautions, employees can become infected by a wide array of diseases. The three most common are Human immunodeficiency virus (HIV), hepatitis B virus (HBV), and hepatitis C virus (HCV).  Job-related exposure can occur through mucous membranes, the eyes and skin, as well as contact with blood and OPIM.

In commercial and industrial facilities most bloodborne pathogen infections occur from:

• An accident or scrape releasing blood
• Helping an injured co-worker who released blood
• Using equipment with blood from a previous injured user
• Cleaning up after an accident involving blood
• Disposing of blood-contaminated waste materials

How to Prevent Exposure

All companies are required by OSHA to create an Exposure Control Plan (ECP). It outlines the necessary strategies to eliminate or reduce bloodborne pathogen exposure. Annually update the ECP for position changes, procedure input from frontline workers, and implementation of technological changes to minimize occupational exposure.

The ECP includes:

• Determination of employee exposure
• Engineering and work practice controls
• Personal Protective Equipment (PPE)
• Housekeeping
• Hepatitis B vaccinations
• Post-exposure evaluation and follow-ups
• Hazard communication and training
• Recordkeeping
• Evaluation procedures for exposure incidents
• Determination of Employee Exposure

For the ECP, list job classifications for workers with occupational exposure procedures performed creating that exposure.

• Identify the type of fluid whether blood or OPIM.
• Determine the type of exposure such as mucous membranes and injuries that break the skin resulting in blood exposure, and include them in the ECP.

Engineering and Work Practice Controls

Engineering controls eliminate or minimize exposure by isolating a hazard or removing one. For example updating outdated machinery with safer replacements. Work practice controls reduce exposure by changing how a task is performed or by prohibiting behavior.

• Do not manually clean any reusable sharps that expose employees to injury.
• Applying cosmetics, lip balm, or contact lenses, eating, smoking or drinking are prohibited where there is potential for occupational exposure.
• Antiseptic hand cleansers or towelettes with clean cloth or paper towels are allowable options where soap and running water are not accessible.

In an exposure incident:
 

• Immediately wash hands and flood any other skin with soap and water
• Flush mucous membranes with water
• Clean wound with soap and water or skin disinfectant when available
• Immediately report this to the employer and seek medical treatment
   

Solicit and document engineering and work practice controls input from workers with direct contact with machinery and have exposure potential. Evaluate and document consideration of new procedures or new products regularly and document changes made annually.

Personal Protective Equipment  

Remove PPE before leaving the work area and do not take it home to launder it. When applicable, decontaminate all PPE before laundering.

• Remove garments penetrated by blood or OPIM as soon as possible, avoiding contact with outer surface.
• Remove contaminated PPE and place in a designated area for storage, washing, decontamination, or disposal.
• Dispose and replace gloves when they’ve become contaminated, or unable to act as a barrier.

When providing first aid, always wear disposable gloves. Single use, disposable gloves cannot be washed or decontaminated for reuse. Hands must always be washed after the removal of gloves.

Housekeeping

Provide a written cleaning and decontamination protocol within the location for tasks to be performed detailing existent soil, and surfaces to be cleaned. Dried blood can house the hepatitis B virus for up to 7 days so clean promptly and treat as infectious.

Surfaces and Equipment

• Decontaminate equipment and working surfaces with EPA-registered tuberculocidal disinfectants
• Use diluted bleach solutions and FDA cleared, EPA-registered disinfectants
• Remove all blood and OPIM before applying disinfectant
• Leave surfaces wet with the disinfectant for 10 minutes
• Decontaminate equipment before servicing or shipping
• If not, label those portions of equipment with the required biohazard label
• Use soap and water cleaning before decontamination of grossly contaminated equipment
• Decontaminate pails, bins and all reusable containers regularly and immediately after visible contamination
• Dispose infected sharps ASAP in sealable, puncture-resistant, leakproof containers labeled or color-coded appropriately
• Pick up broken glassware using mechanical means, such as tongs, forceps or a brush and dustpan as it may be contaminated.

Laundry

• Wear appropriate PPE when handling contaminated laundry or objects
• Sort and rinse contaminated laundry at the proper facility
• Handle contaminated laundry as little as possible
• Place contaminated laundry in leak-proof bags or containers labeled or color-coded in accordance with the standard
• Designate a person, PPE used, and labeling method for contaminated laundry, equipment or regulated waste brought into or leaving the facility
• Designate what companies launder which contaminated articles.
• Housekeeping exposes workers to cleaning chemicals that can cause allergic reactions or dermatitis.
• Mixing cleaning products with ammonia and chlorine can create a deadly gas.
• Clean up floor spills right away, one passageway at a time and dry with mats when necessary to prevent slips, trips and falls.

Hepatitis B Vaccinations
 

• Offer free hepatitis B vaccinations after required bloodborne pathogens training and within 10 days of potential occupational exposure.
• Get tested for antibody to hepatitis B surface antigen, one to two months following the three-dose vaccination series with continued exposure.
• Get revaccinated if there is no response to the primary vaccination series. Non-responders to the second series must be medically evaluated.
• Employees who refuse the hepatitis B vaccine must be informed of the benefits and sign a hepatitis B vaccine declination.
• The Employee has the right to decide to take it at a later date. At no time is there a cost to employees.

Post-Exposure Evaluation and Follow-ups
 

• After an exposure incident, record routes of exposure, how it occurred and the employee’s job duties.
• Test exposed workers’ blood, if the worker consents.
• Test the source individual for HBV and HIV infection if they consent, or if the law does not require consent.
• Provide exposed workers the test results while informing of laws regarding the disclosure of the source’s identity and infectious status.
• When the source individual is known to be HIV, HCV and or HBV infected, new testing is not necessary.

Post-Exposure Evaluation and Follow-ups
 

• Provide a healthcare professional with this information and relevant medical records including vaccination status
• Have the healthcare professional provide a free, confidential medical evaluation as soon as possible
• Offer post-exposure prophylaxis counseling and assess reported illnesses
• Make available a no cost post-exposure evaluation and follow-up to any occupationally exposed worker
• If employee doesn’t permit HIV serological testing, keep baseline blood sample for 90 days in case they provide permission
• A designated healthcare professional must deliver a written confidential opinion of employee diagnoses to the employer within 15 days
• It must include if the hepatitis B vaccination was recommended
• If the worker received it and was informed of the evaluation results
• If there is any further evaluation or treatment required due to any medical condition resulting from the exposure

Hazard Communication and Training

Inform employees of OSHA’s Hazard Communications standard (HCS), hazardous properties of chemicals worked with, safe handling and actions to safeguard. Employers must acquire hazardous chemical information used by other employers when their employees may be exposed.

Safety Data Sheets (SDSs) are usually prepared by the manufacturer and warn of hazardous chemicals. Employers must also create SDSs, when for example, they  create SDSs for products to be used for a particular workplace. Provide the chemical name, work area where it’s used, manufacturer, dates of use, and quantity used for all hazardous chemicals. When new chemicals are received, this list is updated within 30 days.

Fill out all sixteen sections of the SDS containing information on stability and reactivity, toxicological, exposure control, and other information. Make SDSs accessible during work shifts. Alternative formats to SDS paper copies must be described and how employees may access.

Employees with occupational exposure to bloodborne pathogens must receive training on the transmission of bloodborne pathogen diseases covering:

Explanation and copy of the OSHA bloodborne pathogen standard
 

• Explanation and copy of ECP
• How to recognize exposure activities and what constitutes an exposure incident
• Explanation for using PPE, engineering controls, and work practices
• Explanation and types, uses, location, removal, handling, decontamination, and disposal of PPE
• Explanation for PPE selection
• Protocol and contact person for a blood or OPIM emergency
• Explanation of signs, labels or color-coding required by the standard
• Procedures in an exposure incident, including reporting the incident and the medical follow-up that will be provided

Each employee must also attend a health and safety orientation that will be repeated prior to introducing a new chemical hazard that will include…

• Hazardous chemicals present in the work area
• Physical and health risks of the hazardous chemicals
• Overexposure symptoms
• Hazardous chemicals presence determination
• Exposure prevention of hazardous chemicals through control procedures, work practices and PPE
• Procedures for employees overexposed to hazardous chemicals
• How to read labels and SDSs for hazard information
• SDS file and Hazard Communication program location
• OSHA hazard communication standard overview

For non-routine tasks performed with chemicals such as unlabeled pipes work, provide the chemical in the pipes, potential hazards, and required safety precautions. Contract personnel providers must supply training on the standard, employees’ vaccinations, and correct follow-up opinions following an exposure incident.

The client employer has the primary responsibility for control of exposure conditions and must provide site-specific training on PPE. Training must be conducted within one year of employee’s previous training and by an expert in the area of occupational hazards of bloodborne pathogens. Training must provide opportunity for interactive questions and answers with the expert.

Recordkeeping

Organizations who have in excess of 10 employees must maintain Occupational Injury and Illness Recording for employees exposed to bloodborne pathogens. They must also maintain medical records and a sharps injury log. Only OSHA designated companies such as clothing stores, legal services organizations and data processors are exempt.

Medical records include employee name and social security, hepatitis B vaccination copy and date, copies of all examination results, medical testing and follow-up procedures and the healthcare professional's written opinion. Medical records must be kept for the duration of employment plus 30 years.

Training Records
 

• Complete for employees upon conclusion of training
• Provide dates, content of training, and names and job titles of those conducting and attending the training
• Retain for 3 years from the training date
• Make available upon request to authorized representatives within 15 working days
• Comply with the requirements involving transfer of records

Keep Injury and illness records for on-the-job injuries and cuts from sharp objects that are contaminated with another worker’s blood or OPIM. In addition to recordkeeping requirements, the privacy-protected sharps injury log must record all contaminated sharps injuries. It must record all occupational injuries and illnesses such as incident description and location, device type and brand, body part affected, and objects or substances involved.

Employers can use the OSHA 300, 300A and 301 forms to satisfy sharps injury log requirements, if they enter the type and brand of the machinery or device. If these alternative systems are used, they must segregate sharps injuries from other types of on the job injuries and illnesses, or maintain in a manner to be easily separated.  Review it regularly and during the ECP update. The records are preserved for at least five years following the end of the calendar year they cover.

Contaminated objects need to be documented on the OSHA 300 Log of Work-Related Injuries and Illnesses as well as the OSHA 301 Injury and Illness Incident Report.

Evaluation procedures for exposure incidents

After an exposure incident, assess the elements of all exposure incidents to decide:
 

• Engineering controls used
• Work practices followed
• Description of device used including brand and type
• PPE used
• Incident location
• Procedure performed during incident
• Employee’s training

Consequences

OSHA imposes a $13,653 fine for serious violations and a $136,532 fine for willful or repeated actions. OSHA fined an organization in Brooklyn, Maryland $342,000 for exposing workers to bloodborne pathogen hazards. Criminal penalties are also possible for willful violations that result in worker death. Occupational blood exposures create psychological stress and job-related depression for employees, reducing productivity and increasing worker’s comp claims.

Conclusion

Employees in commercial and industrial facilities are the backbone of the manufactured goods we all rely upon. Providing the right technology, proper practices, and protection for these employees saves lives. By safeguarding the lives of these workers, organizations increase the quality of their products and preserve the well being of their employees.