August 17, 2020

Ensuring Compliance with OSHA’s Bloodborne Pathogens Standard

The Occupational Safety and Health Administration (OSHA) requires workplaces of all types and sizes to actively work to preserve employee safety and prevent incidents that could lead to harm. Although healthcare organizations must comply with all applicable OSHA regulations, there are a few rules that are considered especially important because they address prime healthcare safety risks. The Bloodborne Pathogen Standard is one such OSHA rule.

What Is the Bloodborne Pathogens Standard?

The Bloodborne Pathogen Standard addresses the inadvertent transmission of bloodborne pathogens (BBPs) that can cause illness. It applies to workplaces where employees are regularly exposed to blood or other potentially infectious material as part of their jobs, and it requires organizations to put safeguards in place to mitigate the risk of employee harm.

Although the BBP standard is one of the most critical OSHA regulations for healthcare organizations, it is also one of the most challenging. The standard is a frequent source of citations and the primary noncompliant standard for small healthcare facilities.

How Can Organizations Comply with OSHA’s Bloodborne Pathogen’s Standard?

To comply with the standard, organizations must have an Exposure Control Plan, provide comprehensive staff training, offer Hepatitis B immunizations to at-risk staff, clearly label biohazardous material, and follow safe sharps disposal procedures.

What Is a Bloodborne Pathogen?

A bloodborne pathogen is a microorganism that may be present in blood or other body fluids that can lead to serious disease. Bloodborne pathogens include viruses, bacteria, fungi, prions or any other microorganisms, including parasites. Human Immunodeficiency Virus (HIV), Hepatitis B (HBV) and Hepatitis C (HCV) are three of the most frequently addressed pathogens.

Transmission of bloodborne pathogens can occur when workers are stuck or cut with a contaminated sharp object, such as a needle or scalpel, or have an open wound that comes into contact with bio-contaminated material.

What Is a BBP Exposure Control Plan?

OSHA requires healthcare organizations to have a written Exposure Control Plan that details how an organization prevents staff exposure to and spread of bloodborne pathogens, as well as what happens if an incident occurs.

Should an organization receive a visit from an OSHA inspector, this document is one of the first things the inspector will ask for after arriving onsite. Since these inspections are not typically scheduled, organizations should make sure their Exposure Control Plans are accessible at a moment’s notice.

Some of the main topics a Bloodborne Pathogens Exposure Control Plan should cover include:

  • How an organization identifies which workers could be exposed during their jobs 

  • Training and safety protocols like personal protective equipment and other controls to prevent exposure

  • How an organization protects staff ranging from information about universal and standard precautions, engineering controls, work practice controls, administrative controls and personal protective equipment

  • A confirmation of BBP training and documentation that staff have participated in and completed training

  • Policies outlining Hepatitis B vaccination, including when it’s warranted

  • A plan for alerting staff to potential hazards, including how the organization will properly label containers that house biohazardous material

  • Processes for required documentation and recordkeeping

  • How to evaluate and properly respond to exposure incidents

How Often Should Organizations Review Their Exposure Control Plans?

Healthcare organizations are required to annually review and update their Exposure Control Plan to remain OSHA compliant. They should document when reviews occur, including the time and date. As part of the review process, organizations are required to annually consider whether there are safer medical devices that could prevent worker exposure and whether requiring the use of those devices is warranted. Documentation of this review is required.

OSHA requires organizations to seek and document input from non-managerial employees. Staff must be able to readily access the plan when needed.

What Are the Training Requirements for the Bloodborne Pathogens Standard?

Organizations must provide training to any employee who is determined to be at risk for bloodborne pathogen exposure. This may include nurses, nursing assistants, physicians, housekeeping staff and other clinical and operational employees. Some key topics to cover include:

  • The epidemiology and symptoms of bloodborne diseases

  • How bloodborne pathogens may be transmitted

  • The steps workers can take to protect themselves from exposure

  • Proper personal protective equipment for preventing exposure

  • Why receiving the Hepatitis B vaccine is important

  • How to report BBP exposures

  • What steps to take in an exposure incident

BBP training should occur as part of orientation and at least annually as a refresher. In addition, employees should receive supplemental training if and when they assume new or modified roles that increase their exposure risk.

Online training modules can be helpful in meeting the standard’s training and education requirements because staff can access the content at their convenience and gain a complete picture of their role in preserving safety. Modules should be updated as needed, so organizations can be sure they are consistently in compliance with OSHA’s regulations.

What Will an OSHA Officer Look for When Assessing Bloodborne Pathogens Standard Compliance?

An OSHA Compliance Safety and Health Officer will want to thoroughly assess all aspects of compliance, especially since bloodborne pathogens exposure is a significant healthcare worker safety risk. Assessment will involve asking to review an organization’s Exposure Control Plan. In addition, the officer may spend time observing and talking with staff about their familiarity with the standard and how they can preserve safety.

The best way to prepare for these interactions is to make sure the organization’s plan is fully up to date, has been reviewed within the last year and all documentation is in order. Also, be sure staff training has occurred and is documented, and employees are able to answer an OSHA officer’s questions.

Periodic walk-arounds and mock surveys where organization leaders look for potential compliance issues can be beneficial when preparing for an OSHA inspection. These give organizations a chance to resolve problems before they surface during an onsite inspection.

Ensure Your Healthcare Organization’s Bloodborne Pathogens Standard Compliance

To learn how Stericycle can help your organization ensure Bloodborne Pathogens Standard compliance and safeguard employees, visit our Bloodborne Pathogens Training and OSHA compliance pages.

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