Bloodborne Pathogen Program Notes

OSHA requires employers to establish Bloodborne Pathogen control and training programs if they have employees who are or may be "Occupationally exposed" to Bloodborne Pathogens. Obviously any health care providers are considered "occupationally exposed", however, also included are any employees who, as apart of their training or job description, provide first aid, are expected to cleanup any spills of body fluids or are involved in laundry operations that may include clothing that is potentially contaminated with body fluids.

The first step is to establish what employees and what areas may be covered under this OSHA standard. OSHA defines "Occupational Exposure" as 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.

If you have any employees or situations that meet this definition you must create and implement an Exposure Control Plan. You must make a copy of the Exposure Control Plan accessible to employees.  The Exposure Control Plan must be reviewed and updated at least annually and whenever necessary to reflect new or modified tasks and procedures which affect occupational exposure and to reflect new or revised employee positions with occupational exposure.

The Exposure Control Plan must contain at least the following elements:

Exposure Determination - A list of all job classifications in which all employees in those job classifications have occupational exposure. A list of job classifications in which some employees have occupational exposure. A list of all tasks and procedures or groups of closely related task and procedures in which occupational exposure occurs and that are performed by employees in job classifications.

Methods of Compliance - This includes establishing

Universal precautions
PPE selections and use
Container labeling
Control of BBP areas
Procedures for:
Sharps
Waste Disposal
Housekeeping
Decontamination
Collection
Handling
Processing
Storage
Transport
Shipping

Hepatitis B Vaccination - provide, at no cost to the employee, 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.

Post-exposure Evaluation and Follow-up - make available to the exposed employee a confidential medical evaluation and follow-up, including at least the following:

• Documentation of the route of exposure, and the circumstances under which the exposure incident occurred
• Identification and documentation of the source individual and blood test results
• Counseling

 

Employee Training
Training must be provided to all employees covered in the exposure determination process. Training program must be:

provided at no cost to the employee and during working hours.

at the time of initial assignment to tasks where occupational exposure may take place;

annual re-training must be provided within one year of previous training.

provide when changes such as modification of tasks or procedures or institution of new tasks or procedures affect the employee's occupational exposure.

appropriate in content and vocabulary to educational level, literacy, and language of employees shall be used.

structured to provide an opportunity for interactive questions and answers with the person conducting the training session.

provided by a person knowledgeable in the subject matter covered by the elements contained in the training program as it relates to the workplace that the training addresses.

Before allowing an employee to engage in tasks that could cause exposure, you must verify their proficiency in all exposure controls is adequate.

Training program elements include:

Copy of the OSHA Standard
Explanation of its contents
Epidemiology, symptoms & transmission
Exposure control plan
Methods for recognizing tasks that could lead to exposure
Use & limitations of engineering controls, work practices
Selection, use, disposal & limitations of PPE
Hepatitis B vaccinations
Emergency procedures & contact information
Exposure and reporting procedures
Medical follow-up after exposure
Signs & labels

Records
Medical Records - establish and maintain an accurate record for each employee with occupational exposure. This record must include:

• Name & social security number
• Employee's hepatitis B vaccination status
• Results of any post-exposure examinations, medical testing, and follow-up procedures
• Healthcare professional's post-exposure written opinion

Employee medical records must be kept confidential and not disclosed or reported without the employee's express written consent to any person within or outside the workplace except as required by this section or as may be required by law.

Maintain the records for at least the duration of employment plus 30 years.

Training Records.

Training records shall include the following information:

• Dates of training
• Contents or a summary of the training
• Names & qualifications of persons conducting the training
• Names & job titles of all persons attending the training sessions.
• Training records must be maintained for 3 years from the date on which the training occurred.