January 22, 2024

OSHA BBP Standards & Post-Exposure Procedures for Healthcare Safety

Every year, millions of healthcare workers are at a high risk of exposure incidents involving blood and/or other potentially infectious materials (OPIM) and the potential transmission of bloodborne pathogens (BBP). Healthcare facilities and employees must be prepared to prevent and address these risks in their daily operations. Moreover, having an exposure control plan is crucial to handling a BBP exposure incident, complying with post exposure procedures, and comprehending the requirements set by official organizations.

What You Need to Know About OSHA's BBP Standard

Bloodborne Pathogens refer to infectious microorganisms present in human blood that are capable of causing disease in humans. These pathogens include, but are not limited to, hepatitis B (HBV), hepatitis C (HCV), and human immunodeficiency virus (HIV). The Occupational Safety and Health Administration's (OSHA) Bloodborne Pathogen Standard 29 CFR 1910.1030 outlines controls to protect employees. These controls include engineering controls, work practice controls, administrative controls, and personal protective equipment (PPE).]

Administrative controls mandated under the Bloodborne Pathogen Standard necessitate the development of policies, procedures, and plans. These include a BBP exposure control plan, employee training, recordkeeping protocols, signage, and biohazard labeling.

BBP Exposure Control Plan: Essential Preparedness

An exposure control plan (ECP) is a written document that details how an organization identifies and mitigates risks associated with BBPs and defines the workplace response in case of exposure. This plan must cater to specific job roles, tasks, and environmental safety needs of each organization.

Elements of the plan include an exposure determination, compliance methods, housekeeping schedules, and post-exposure plans, ensuring a structured approach to managing potential incidents.

The Importance of BBP Post-Exposure Incident Procedures

OSHA outlines requirements and procedures to be followed when the possibility of an exposure incident exists. Employers must be prepared to implement their written procedures after an exposure incident in a timely manner including completing required paperwork, sending the employee subject to the exposure risk to a licensed healthcare professional, and accounting for the source patient.

The post exposure incident procedures should guide immediate actions, such as treating the exposure site, reporting the incident, seeking medical attention from designated healthcare professionals, and post-exposure treatments if necessary. Furthermore, employers must provide comprehensive documentation, confidential medical evaluations, blood testing, counseling, and follow-up appointments for affected employees per OSHA's guidelines.

Understanding and implementing BBP post-exposure incident procedures and complying with OSHA's requirements are pivotal in safeguarding healthcare workers and effectively responding to exposure incidents. These procedures ensure a systematic approach, rapid response, and appropriate medical attention, which reduces the risks associated with incident exposures involving blood or OPIM and ultimately creates a safer healthcare environment.

Stericycle can be a valuable resource in helping your organization minimize risks and develop the necessary elements to achieve and sustain compliance with OSHA’s BBP requirements. Learn how our OSHA Compliance and Training programs can help provide your organization with the resources and information to keep your staff safe and your organization compliant today and in the future. 

Frequently Asked Questions 

What Constitutes a BBP Exposure Incident?

According to OSHA, an exposure incident means a specific eye, mouth, other mucous membrane, non-intact skin, or parenteral contact with blood or other potentially infectious materials that results from the performance of an employee's duties.

What Should a Bloodborne Pathogens Exposure Control Plan (ECP) Include?

Some of the main topics an ECP should cover include:

  • An exposure determination list, providing a list of all job classifications which all employees have occupational exposure as well as those where only some employees have occupational exposure. An exposure determination includes tasks and procedures for the classifications where only some employees have anticipated exposure, typically on an occasional or intermittent basis.
  • The types of engineering, work practice, and administrative controls that an organization will use to prevent or mitigate exposure incidents.
  • A workplace hazard assessment to determine what types of personal protective equipment (PPE) will be selected to prevent or mitigate exposure incidents.
  • An explanation of the organization’s BBP training requirements.
  • Policies outlining the offering of the Hepatitis B vaccination, including when it is warranted for an employee to be vaccinated.
  • Annual evaluation and implementation of safer medical devices designed to prevent contaminated sharps injuries.
  • How to evaluate and respond to exposure incidents. This aspect is of high importance as it will guide an employer through the necessary procedures to take following an incident.

Staff should assist in developing the plan to help ensure policies are relevant to their specific work conditions. ECPs are required to be reviewed and updated annually and whenever necessary to reflect new or modified tasks and procedures, as well as revised employee positions with occupational exposure.

What Questions Should Your Post-Exposure Incident Procedures Answer?

Ensuring a plan is in place before post-exposure incident procedures are needed is crucial to avoid confusion and save valuable time in providing proper medical care for the exposed employee. The plan should address these questions:

  • Who will perform each task, such as filling out the necessary paperwork?
  • ·Who will handle the source patient?
  • Who will assist the injured employee?
  • Which medical facility will be utilized?

What Immediate Actions Should Be Taken After a BBP Exposure Incident? 

In the event of exposure, the first steps are to treat the exposure site, report the incident to your supervisor or the person in your practice responsible for managing exposures, and seek medical treatment with a pre-determined physician or other licensed healthcare professional. If you experienced a contaminated sharps injury or needlestick, or were exposed to the blood or other potentially infectious fluid of a patient through an open wound or a mucous membrane, immediately follow these steps:

  • Wash the site of the needlestick or cut with soap and water.
  • Flush splashes to the nose, mouth, or skin with water.
  • Irrigate eyes with clean water, saline, or sterile irrigants.
  • Report the incident to your supervisor or the person in your practice responsible for managing exposures.
  • Immediately seek medical evaluation from a qualified healthcare professional because, in some cases, post-exposure treatment may be recommended and should be started as soon as possible.

It's important to remember that, per the OSHA BBP Standard's, the definition of a Licensed Healthcare Professional is an individual whose legally permitted scope of practice enables him or her to independently perform the activities outlined in 1910.1030 paragraph (f) for Hepatitis B Vaccination and Post-exposure Evaluation and Follow-up.

In addition, healthcare professionals caring for exposed healthcare workers can call the National Clinicians’ Post-exposure Prophylaxis Hotline (PEPline) for advice on managing occupational exposures to HIV and hepatitis B and C viruses. PEPline is available 24 hours a day, 7 days a week, at 1-888-448-4911. 

Who is Responsible for Managing an Exposure Incident?

The employee who experiences an exposure incident can follow the aforementioned steps, but healthcare employers have significant responsibilities regarding the management of an exposure incident. An employer needs to make the following available at no cost to the affected employee after an exposure:

  • Confidential medical evaluation at a pre-established location.
  • Blood testing.
  • Confidential follow-up appointments.
  • Source patient testing results.
  • Counseling.
  • Evaluation of reported illnesses.
  • Documentation.

How Should Exposure Incidents Be Documented? 

The following documentation is required if an exposure incident occurs:

Provide to Healthcare Professional:

  • A copy of the BBP standard.
  • Description of employee’s duties related to the incident.
  • Route of exposure and circumstances (exposure incident report).
  • Results of source individual blood test (if available).
  • Medical records relevant to the appropriate treatment of the employee including vaccination status.

Obtain from Healthcare Professional

  • Written opinion within 15 days after evaluation (Limited to specific information).

Recordkeeping Requirements

  • Exposure medical records kept confidential.
  • Duration of employment plus 30 years.

Employers must adhere to all federal regulations (including OSHA’s) and state guidelines concerning the documentation and reporting of occupational injuries and exposures. The exposure incident report should be filed within the affected employee’s confidential medical records and a copy provided to the treating healthcare professional.

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