Recordkeeping

Q. What is contained in the medical record?

A. The medical record includes the name and social security number of the employee; a copy of the employee’s hepatitis B vaccination status including the dates of all the hepatitis B vaccinations, and any medical records relative to the employee’s ability to receive the vaccination; copies of all results of examinations, medical testing, and the follow-up procedures; copies of the healthcare professional’s written opinion; and a copy of the information provided to the healthcare professional.

Q. Who keeps the medical records?

A. The employer is responsible for the establishment and maintenance of medical records. However, these records may be kept off-site at the location of the healthcare provider.

Q. How long must the medical records be kept?

A. Medical records must be kept for the duration of employment plus 30 years.

Q. What information must be included on the sharps injury log?

A. The sharps injury log, which protects the confidentiality of the injured employee, must contain at a minimum, the type and brand of device involved in the incident; the department or work area where the exposure incident occurred; and an explanation of how the incident occurred.

Q. How long must the sharps injury log be retained?

A. The sharps injury log must be retained for five years following the end of the year to which it relates.

Q. What is included in the training record?

A. The training record contains the dates of the training, the contents or a summary of the training sessions, the names and job titles of all persons attending the training, and the names and qualifications of the persons conducting the training.

Q. How long must the training records be kept?

A. Training records must be retained for three years from the training date.

Communication of Hazard to Employees | Bloodborne Pathogens

Q. When are labels required?

A. A warning label that includes the universal biohazard symbol, followed by the term “biohazard,” must be included on bags/containers of contaminated laundry, on bags/containers of regulated waste, on refrigerators and freezers that are used to store blood or OPIM, and on bags/containers used to store, dispose of, transport, or ship blood or OPIM (e.g., specimen containers). In addition, contaminated equipment which is to be serviced or shipped must have a readily observable label attached which contains the biohazard symbol and the word “biohazard” along with a statement relating which portions of the equipment remain contaminated.

Q. What are the required colors for the labels?

A. The background must be fluorescent orange or orange-red or predominantly so, with symbols and lettering in a contrasting color. The label must be either an integral part of the container or affixed as close as feasible to the container by a string, wire, adhesive, or other method to prevent its loss or unintentional removal.

Q. Can there be substitutes for the labels?

A. Yes. Red bags or red containers may be substituted for the biohazard labels.

Q. What are the exceptions to the labeling requirement?

A. Labeling is not required for:

• Containers of blood, blood components, and blood products bearing an FDA required label that have been released for transfusion or other clinical uses.

• Individual containers of blood or OPIM that are placed in secondary labeled containers during storage, transport, shipment, or disposal.

• Specimen containers, if the facility uses Universal Precautions when handling all specimens, the containers are recognizable as containing specimens, and the containers remain within the facility.

• Laundry bags or containers, containing contaminated laundry, may be marked with an alternative label or color-coded provided the facility uses Universal Precautions for handling all soiled laundry and the alternative marking permits all employees to recognize the containers as requiring compliance with Univeral Precautions. If contaminated laundry is sent off-site for cleaning to a facility which does not use Universal Precautions in the handling of all soiled laundry, it must be placed in a bag or container which is red in color or labeled with the biohazard label described above.

• Regulated waste that has been decontaminated.

Q. Does OSHA accept Department of Transportation’s (DOT) labels for waste and specimens which will be shipped or transported?

A. The labeling requirements do not preempt either the U.S. Postal Service labeling requirements (39 CFR Part III) or the Department of Transportation’s Hazardous Materials Regulations (49 CFR Parts 171-181).

DOT labeling is required on some transport containers (i.e., those containing “known infectious substances”). It is not required on all containers for which 29 CFR 1910.1030 requires the biohazard label. Where there is an overlap between the OSHA-mandated label and the DOT-required label, the DOT label will be considered acceptable on the outside of the transport container provided the OSHA-mandated label appears on any internal containers which may be present. Containers serving as collection receptacles within a facility must bear the OSHA label since these are not covered by the DOT requirements.

Q. Which employees must be trained?

A. All employees with occupational exposure must receive initial and annual training.

Q. Should part-time and temporary employees be trained?

A. Part-time and temporary employees are covered and are also to be trained on company time.

Q. Who has the responsibilty for training workers employed by agencies which provide personnel (e.g., nurses) to other employers?

A. As stated in a similar answer, OSHA considers personnel providers, who send their own employees to work at other facilities, to be employers whose employees may be exposed to hazards. Since personnel providers maintain a continuing relationship with their employees, but another employer (your client) creates and controls the hazard, there is a shared responsibilty for assuring that your employees are protected from workplace hazards. The client employer has the primary responsibility for such protection, but the “lessor employer” likewise has a responsibility under the Occupational Safety and Health Act.

In the context of OSHA’s standard on Bloodborne Pathogens, the personnel provider would be required to provide the general training outlined in the standard. The client employer would be responsible for providing site-specific training.

The contract between the personnel provider and the client should clearly describe the training responsibilities of both parties in order to ensure that all training requirements of the standard are met.

Q. What are the qualifications that a person must possess in order to conduct employee training regarding bloodborne pathogens?

A. The person conducting the training is required to be knowledgeable in the subject matter covered by the elements in the training program and be familiar with how the course topics apply to the workplace that the training will address. The trainer must demonstrate expertise in the area of occupational hazards of bloodborne pathogens.

Q. Who are some examples of persons who could conduct training on the bloodborne standard?

A. Examples of health care professionals include infection control practitioners, nurse practitioners, and registered nurses. Non-health care professionals include industrial hygienists, epidemiologists or professional trainers, provided that they can demonstrate evidence of specialized training in the area of bloodborne pathogens.

Hepatitis B Vaccination and Post-Exposure Follow-Up Procedures

Q. Who must be offered the hepatitis B vaccination?

A. The hepatitis B vaccination series must be made available to all employees who have occupational exposure. The employer does not have to make the hepatitis B vaccination available to employees who have previously received the vaccination series, who are already immune as their antibody tests reveal, or who are prohibited from receiving the vaccine for medical reasons.

Q. When should the hepatitis B vaccination be offered to employees?

A. The hepatitis B vaccination must be made available within 10 working days of initial assignment, after appropriate training has been completed. This includes arranging for the administration of the first dose of the series. In addition, see page 17 for vaccination of designated first aiders.

Q. Can pre-screening be required for hepatitis B titer? Post-screening?

A. No. The employer cannot require an employee to take a pre-screening or post-vaccination serological test. An employer may, however, decide to make pre-screening available at no cost to the employee. Routine post-vaccination serological testing is not currently recommended by the CDC unless an employee has had an exposure incident, and then it is also to be offered at no cost to the employee.

Q. If an employee declines the hepatitis B vaccination, can the employer make up a declination form?

A. If an employee declines the hepatitis B vaccination, the employer must ensure that the employee signs a hepatitis B vaccination declination. The declination’s wording must be identical to that found in Appendix A of the standard. A photocopy of the Appendix may be used as a declination form, or the words can be typed or written onto a separate document.

Q. Can employees refuse the vaccination?

A. Employees have the right to refuse the hepatitis B vaccine and/or any post-exposure evaluation and follow-up. Is important to note, however, that the employee needs to be properly informed of the benefits of the vaccination and post-exposure evaluation through training. The employee also has the right to decide to take the vaccination at a later date if he or she so chooses. The employer must make the vaccination available at that time.

Q. Can the hepatitis B vaccination be made a condition of employment?

A. OSHA does not have jurisdiction over the issue.

Q. Is a routine booster does of hepatitis B vaccine required?

A. Because the U.S. Public Health Service (USPHS) does not recommend routine booster doses of hepatitis B vaccine, they are not required at this time. However, if a routine booster dose of hepatitis B vaccine is recommended by the USPHS at a future date, such booster doses must be made available at no cost to those eligible employees with occupational exposure.

Q. Whose responsibility is it to pay for the hepatitis B vaccine?

A. The responsibility lies with the employer to make the hepatitis B vaccine and vaccination, including post-exposure evaluation and follow-up, available at no cost to the employees.

Q. What information must the employer provide to the healthcare professional following an exposure incident?

A. The healthcare professional must be provided with a copy of the standard, as well as the following information:

• A description of the employee’s duties as they relate to the exposure incident;

• Documentation of the route(s) and circumstances of the exposure;

• The results of the source individual’s blood testing, if available; and

• All medical records relevant to the appropriate treatment of the employee, including vaccination status, which are the employer’s responsibility to maintain.

Q. What serological testing must be done on the source individual?

A. The employer must identify and document the source individual if know, unless the employer can establish that identification is not feasible or is prohibited by state or local law. The source individual’s blood must be tested as soon as feasible, after consent is obtained, in order to determine HIV and HBV infectivity. The information on the source individual’s HIV and HBV testing must be provided to the evaluating healthcare professional. Also, the results of the testing must be provided to the exposed employee. The exposed employee must be informed of applicable laws and regulations concerning disclosure of the identity and infectious status of the source individual.

Q. What if consent cannot be obtained from the source individual?

A. If consent cannot be obtained and is required by state law, the employer must document in writing that consent cannot be obtained. When the source individual’s consent is not required by law, the source individual’s blood if available shall be tested and the results documented.

Q. When is the exposed employee’s blood tested?

A. After consent is obtained, the exposed employee’s blood is collected and tested as soon as feasible for HIV and HBV serological status. If the employee consents to the follow-up evaluation after an exposure incident, but does not give consent for HIV serological testing, the blood sample must be preserved for 90 days. If, within 90 days of the exposure incident, the employee elects to have the baseline sample tested for HIV, testing must be done as soon as feasible.

Q. What information does the healthcare professional provide to the employer following an exposure incident?

A. The employer must obtain and provide to the employee a copy of the evaluating healthcare professional’s written opinion within 15 days of completion of the evaluation. The healthcare professional’s written opinion for hepatitis B is limited to whether hepatitis B vaccination is indicated and if the employee received the vaccination. The written opinion for post-exposure evaluation must include information that the employee has been informed of the results of the evaluation and told about any medical conditions resulting from exposure that may further require evaluation and treatment. All other findings or diagnoses must be kept confidential and not included in the written report.

Q. What type of counseling is required following an exposure incident?

A. The standard requires that post-exposure counseling be given to employees following an exposure incident. Counseling should include USPHS recommendations for prevention of HIV. These recommendations include refraining from blood, semen, or organ donation; abstaining from sexual intercourse or using measures to prevent HIV transmission during sexual intercourse; and refraining from breast feeding infants during the follow-up period. In addition, counseling must be made available regardless of the employee’s decision to accept serological testing.

Q. What information about exposure incidents is recorded on the OSHA 300 Log?

Revision 10/02 A. All work-related needlestick injuries and cuts from sharp objects that are contaminated with another person’s blood or other potentially infectious materials must be recorded. Enter the case on the 300 Log as an injury. To protect the employee’s privacy, do not enter the employee’s name. Enter the case on the sharps injury log or enter comparable data on the OSHA 300 Log.

Laundry | Bloodborne Pathogens

Q. What does OSHA mean by the term “contaminated laundry?”

A. Contaminated laundry means laundry which has been soiled with blood or other potentially infectious materials or may contain sharps.

Q. How should contaminated laundry be handled?

A. Contaminated laundry shall be handled as little as possible with a minimum of agitation. Contaminated laundry shall be bagged or containerized at the location where it was used and shall not be sorted or rinsed in the location of use. Other requirements include:

• Contaminated laundry shall be placed and transported in bags or containers labeled or color-coded in accordance with paragraph (g)(1)(i) of the standard. When a facility utilizes Universal Precautions in the handling of all soiled laundry, alternative labeling or color-coding is sufficient if it permits all employees to recognize the containers as requiring compliance with Universal Precautions.

• Whenever contaminated laundry is wet and presents a reasonable likelihood of soak-through or leakage from the bag or container, the laundry shall be placed and transported in bags or containers which prevent soak-through and/or leakage of fluids to the exterior.

• The employer shall ensure that employees who have contact with contaminated laundry wear protective gloves and other appropriate personal protective equipment.

• When a facility ships contaminated laundry off-site to a second facility which does not utilize Universal Precautions in the handling of all laundry, the facility generating the contaminated laundry must place such laundry in bags or containers which are labeled or color-coded in accordance with paragraph (g)(1)(i) of the standard.

Q. Are employees allowed to take their protective equipment home and launder it?

A. Employees are not permitted to take their protective equipment home and launder it. It is the responsibility of the employer to provide, launder, repair, replace, and dispose of personal protective equipment.

Q. Do employers have to buy a washer and dryer to clean employees personal protective equipment?

A. There is no OSHA requirement stipulating that employers must purchase a washer and dryer to launder protective clothing. It is an option that employers may consider. Another option is to contract out the laundering of protective clothing. Finally, employers may choose to use disposable personal protective clothing and equipment.

Q. Are there guidelines to be followed when laundering personal protective equipment? What water temperature and detergent types are acceptable?

A. The decontamination and laundering of protective clothing should be handled by washing and drying the garments according to the clothing manufacturers instructions.

Housekeeping | Bloodborne Pathogens

Q. What type of disinfectant can be used to decontaminate equipment or working surfaces which have come in contact with blood or OPIM?

A. EPA registered tuberculocidal disinfectants are appropriate for the cleaning of blood or OPIM. A solution of 5.25 percent sodium hypochlorite, (household bleach), diluted between 1:10 and 1:100 with water, is also acceptable for cleaning contaminated surfaces.

Quaternary ammonium products are appropriate for use in general housekeeping procedures that do not involve the cleanup of contaminated items or surfaces.

The particular disinfectant used, as well as the frequency with which it is used, will depend upon the circumstances in which a given housekeeping task occurs (i.e., location within the facility, type of surface to be cleaned, type of soil present, and tasks and procedures being performed). The employers written schedule for cleaning and decontamination should identify such specifics on a task-by-task basis.

Regulated waste

Q. What does OSHA mean by the term “regulated waste”?

A. The Bloodborne Pathogens Standard uses the term, “regulated waste,” to refer to the following categories of waste which require special handling at a minimum: (1) liquid or semi-liquid blood or OPIM; (2) items contaminated with blood or OPIM and which would release these substances in a liquid or semi-liquid state if compressed; (3) items that are caked with dried blood or OPIM and are capable of releasing these materials during handling; (4) contaminated sharps; and (5) pathological and microbiological wastes containing blood or OPIM.

Q. Are feminine hygiene products considered regulated waste?

A. OSHA does not generally consider discarded feminine hygiene products, used to absorb menstrual flow, to fall within the definition of regulated waste. The intended function of products such as sanitary napkins is to absorb and contain blood. The absorbent material of which they are composed would, under most circumstances, prevent the release of liquid or semi-liquid blood or the flaking off of dried blood.

OSHA expects these products to be discarded into waste containers which are properly lined with plastic or wax paper bags. Such bags should protect the employees from physical contact with the contents.

At the same time, it is the employers responsibility to determine the existence of regulated waste. This determination is not based on actual volume of blood, but rather on the potential to release blood, (e.g., when compacted in the waste container). If OSHA determines, on a case-by-case basis, that sufficient evidence of regulated waste exists, either through observation, (e.g., a pool of liquid in the bottom of a container, dried blood flaking off during handling), or based on employee interviews, citations may be issued.

Q. How do I dispose of waste?

A. Regulated waste shall be placed in containers which are:

• Closable;

• Constructed to contain all contents and prevent leakage of fluids during handling, storage, transport or shipping;

• Labeled or color-coded in accordance with paragraph (g)(1)(i) of the standard; and

• Closed prior to removal to prevent spillage or protrusion of contents during handling, storage, transport, or shipping.

If outside contamination of the regulated waste container occurs, it shall be placed in a second container. The second container shall be:

• Closable;

• Constructed to contain all contents and prevent leakage of fluids during handling, storage, transport, or shipping;

• Labeled or color-coded in accordance with paragraph (g)(1)(i) of the standard; and

• Closed prior to removal to prevent spillage or protrusion of contents during handling, storage, transport, or shipping.

Disposal of all regulated waste shall be in accordance with applicable regulations of the United States, states and territories, and political subdivisions of states and territories.

Personal Protective Equipment

Q. What type of personal protective equipment (PPE) should employees in a dental office wear?

A. The standard requires that PPE be “appropriate.” PPE will be considered “appropriate” only if it does not permit blood or OPIM to pass through to, or reach, the skin, employees underlying garments, eyes, mouth, or other mucous membranes under normal conditions of use and for the duration of time that the PPE will be used. This allows the employer to select PPE based on the type of exposure and the quantity of blood or OPIM which can be reasonably anticipated to be encountered during performance of a task or procedure.

Q. Who is responsible for providing PPE?

A. The financial responsibility for repairing, replacing, cleaning, and disposing of PPE rests with the employer. The employer is not obligated under the standard to provide general work clothes to employees, but is responsible for providing PPE. If laboratory jackets or uniforms are intended to protect the employees body or clothing from contamination, they are to be provided by the employer.

Q. Does protective clothing need to be removed before leaving the work area?

A. Yes. OSHA requires that personal protective equipment be removed prior to leaving the work area. While work area must be determined on a case-by-case basis, a work area is generally considered to be an area where work involving occupational exposure occurs or where the contamination of surfaces may occur.

Q. What type of eye protection do I need to wear when working wth blood or OPIM?

A. The use of eye protection would be based on the reasonable anticipation of facial exposure. Masks in combination with eye protection devices such as glasses with solid side shields, goggles, or chin-length face shields, shall be worn whenever splashes, spray, spatter, or droplets of blood or OPIM may be generated, and eye, nose, or mouth contamination can be reasonably anticipated.

Methods of Control | Bloodborne Pathogens

Q. What is meant by the term universal precautions?

A. Universal Precautions is OSHAs required method of control to protect employees from exposure to all human blood and OPIM. The term, “Universal Precautions,” refers to a concept of bloodborne disease control which requires that all human blood and certain human body fluids are treated as if known to be infectious for HIV, HBV, and other bloodborne pathogens.

Q. What are engineering controls?

A. The term, “engineering controls,” refers to controls (e.g., sharps disposal containers, self-sheathing needles, safer medical devices, such as sharps with engineered sharps injury protections and needleless systems) that isolate or remove the bloodborne pathogens hazards from the workplace.

Q. Can employees of an ambulance medical rescue service eat or drink inside the cab of the unit?

A. Employees are allowed to eat and drink in an ambulance cab only if the employer has implemented procedures to permit employees to wash up and change contaminated clothing prior to entering the ambulance cab, has prohibited the consumption, handling, storage, and transport of food and drink in the rear of the vehicle, and has procedures to ensure that patients and contaminated materials remain behind the separating partition.

Q. What alternatives are acceptable if soap and running water are not available for handwashing?

A. Antispetic hand cleaner in conjunction with clean cloth/paper towels or antiseptic towelettes are examples of acceptable alternatives to running water. However, when these types of alternatives are used, employees must wash their hands (or other affected areas) with soap and running water as soon as feasible. This alternative would only be acceptable at worksites where soap and running water are not feasible.

Exposure Control | Bloodborne Pathogens

Q. What is an exposure control plan?

A. The exposure control plan is the employers written program that outlines the protective measures an employer will take to eliminate or minimize employee exposure to blood and OPIM.

The exposure control plan must contain at a minimum: (1) the exposure determination which identifies job classifications and, in some cases, tasks and procedures where there is occupational exposure to blood and OPIM; (2) the procedures for evaluating the circumstances surrounding an exposure incident; and (3) a schedule of how and when other provisions of the standard will be implemented, including methods of compliance, HIV and HBV research laboratories and production facilities requirements, hepatitis B vaccination and post-exposure follow-up, communication of hazards to employees, and recordkeeping.

Q. In the exposure control plan, are employers required to list specific tasks that place the employee at risk for all job classifications?

A. No. If all the employees within a specific job classification perform duties where occupational exposure occurs, then a list of specific tasks and procedures is not required for that job classification. However, the job classification (e.g., “nurse”) must be listed in the plans exposure determination and all employees within the job classification must be included under the requirements of the standard.

Q. Can tasks and procedures be grouped for certain job classifications?

A. Yes. Tasks and procedures that are closely related may be grouped. However, they must share a common activity, such as “vascular access procedure,” or “handling of contaminated sharps.”

Q. Does the exposure control plan need to be a separate document?

A. No. The exposure control plan may be part of another document, such as the facility’s health and safety manual, as long as all components are included. However, in order for the plan to be accessible to employees, it must be a cohesive entity by itself or there must be a guiding document which states the overall policy and goals and references the elements of existing separate policies that comprise the plan. For small facilities, the plans schedule and method of implementation of the standard may be an annotated copy of the final standard that states on the document when and how the provisions of the standard will be implemented. Larger facilities could develop a broad facility program, incorporating provisions from the standard that apply to their establishments.

Q. How often must the exposure control plan be reviewed?

A. The standard requires an annual review of the exposure control plan. In addition, whenever changes in tasks, procedures, or employee positions affect or create new occupational exposure, the existing plan must be reviewed and updated accordingly.

Q. Must the exposure control plan be accessible to employees?

A. Yes, the exposure control plan must be accessible to employees, as well as to OSHA and NIOSH representatives. The location of the plan may be adapted to the circumstances of a particular workplace, provided that employees can access a copy at the workplace during the workshift. If the plan is maintained solely on computer, employees must be trained to operate the computer.

A hard copy of the exposure control plan must be provided within 15 working days of the employees request in accordance with 29 CFR 1910.1020.

Q. What should be included in the procedure for evaluating an exposure incident?

A. The procedure for evaluating an exposure incident shall include:

• the engineering controls and work practices in place,

• the protective equipment or clothing used at the time of the exposure incident,

• an evaluation of the policies and “failures of control” at the time of the exposure incident.

Bloodborne Pathogens: Questions and Answers

Revision 12/05 On December 6, 1991, OSHA issued the Occupational Exposure to Bloodborne Pathogens standard, §1910.1030. This standard is designed to protect workers in the health care and related occupations from the risk of exposure to bloodborne pathogens such as HIV and HBV.

Through its enactment, OSHA received numerous questions regarding how to implement the provisions of the standard. The following information provides answers to many of those questions; however, it is not intended to be used as a substitute for the standard’s requirements. Please refer to §1910.1030 for the complete text.

Scope

Q. Who is covered by the standard?

A. The standard applies to all employees who have occupational exposure to blood or other potentially infectious materials (OPIM).

• Occupational exposure is defined as “reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or OPIM that may result from the performance of the employees duties.”

• Blood is defined as human blood, human blood components, and products made from human blood.

• OPIM is defined as the following human body fluids: saliva in dental procedures, semen, vaginal secretions, cerebrospinal, synovial, pleural, pericardial, peritoneal, and amniotic fluids; body fluids visibly contaminated with blood; along with all body fluids in situations where it is difficult or impossible to differentiate between body fluids; unfixed human tissues or organs (other than intact skin); HIV-containing cell or tissue cultures, organ cultures, and HIV- or HBV- containing culture media or other solutions; and blood, organs, or other tissues from experimental animals infected with HIV or HBV.

Q. Will the bloodborne pathogens standard apply to employees in agriculture, maritime, and construction industries?

A. The standard will not apply to agriculture. The standard applies to maritime in shipyards and boatyards (where 29 CFR 1910 applies), in commercial fishing vessels, towboats, barges, tugs and other vessels where OSHA has jurisdiction. However, the standard does not apply to longshoring and marine terminals. The construction industry is not covered by the standard. However, the General Duty Clause (Section 5(a)(1) of the OSH Act) will be used to enforce bloodborne hazards in construction.

Q. Are volunteers and students covered by the standard?

A. Volunteers and students may be covered by the standard depending on a variety of factors including compensation.

Q. Are physicians who are not employees of the hospital in which they work covered by the standard?

A. Physicians of professional corporations are considered employees of that corporation. The corporation which employs these physicians may be cited by OSHA for violations affecting those physicians. The hospital where the physician practices may also be held responsible as the employer who created or controlled the hazard. Physicians who are sole practitioners or partners are not considered employees under the OSH Act, and therefore, are not covered by the protections of the standard. However, if a non-incorporated physician were to create a hazard to which hospital employees were exposed, it would be consistent with current OSHA policy to cite the employer of the exposed employees for failure to provide the protections of the Bloodborne Pathogens Standard.

Q. We have employees who are designated to render first aid. Are they covered by the standard?

A. Yes. If employees are trained and designated as responsible for rendering first aid or medical assistance as part of their job duties, they are covered by the protections of the standard. However, OSHA will consider it a de minimis violation — a technical violation carrying no penalties — if employees, who administer first aid as a collateral duty to their routine work assignments, are not offered the pre-exposure hepatitis B vaccination, provided that a number of conditions are met. In these circumstances no citations will be issued.

The de minimis classification for failure to offer hepatitis B vaccination in advance of exposure does not apply to personnel who provide first aid at a first aid station, clinic, or dispensary, or to the health care, emergency response or public safety personnel expected to render first aid in the course of their work.

Exceptions are limited to persons who render first aid only as a collateral duty, responding solely to injuries resulting from workplace incidents, generally at the location where the incident occurred. To merit the de minimis classification, the following conditions also must be met:

• Reporting procedures must be in place under the exposure control plan to ensure that all first aid incidents involving exposure are reported to the employer before the end of the work shift during which the incident occurs.

• Reports of first aid incidents must include the names of all first aid providers and a description of the circumstances of the accident, including date and time, as well as a determination of whether an exposure incident, as defined in the standard, has occurred.

• Exposure reports must be included on a list of such first aid incidents that is readily available to all employees and provided to OSHA upon request.

• First aid providers must receive training under the Bloodborne Pathogens Standard that covers the specifics of the reporting procedures.

• All first aid providers who render assistance in any situation involving the presence of blood or other potentially infectious materials, regardless of whether or not a specific exposure incident occurs, must have the vaccine made available to them as soon as possible but in no event later than 24 hours after the exposure incident. If an exposure incident as defined in the standard has taken place, other post-exposure follow-up procedures must be initiated immediately, per the requirements of the standard.

Q. Are employees such as housekeepers, maintenance workers, or janitors covered by the standard?

A. Housekeeping workers in health care facilities may have occupational exposure to bloodborne pathogens, as defined by the standard. Individuals who perform housekeeping duties, particularly in patient care and laboratory areas, may perform tasks, such as cleaning blood spills and handling regulated wastes, which constitute occupational exposure.

While OSHA does not generally consider maintenance personnel and janitorial staff employed in non-health care facilities to have occupational exposure, it is the employers responsibility to determine which job classifications or specific tasks and procedures involve occupational exposure. For example, OSHA expects products such as discarded sanitary napkins to be discarded into waste containers which are lined in such a way as to prevent contact with the contents. But at the same time, the employer must determine if employees can come into contact with blood during the normal handling of such products from initial pick-up through disposal in the outgoing trash. If OSHA determines, on a case-by-case basis, that sufficient evidence of reasonably anticipated exposure exists, the employer will be held responsible for providing the protections of 29 CFR 1910.1030 to the employees with occupational exposure.

Recordkeeping | Bloodborne Pathogens

OSHA requires that all needlestick and sharps injuries and illnesses that result from bloodborne pathogens exposure be recorded on the OSHA 300 Log, the sharps injury log, and employee-related medical and training records.

OSHA 300 Log

Revision 12/05 All occupational bloodborne pathogens exposure incidents that are work-related and involve contamination with another person’s blood or potentially infectious material, such as needlesticks and lacerations, must be recorded on the OSHA 300 Log as an injury. However, to protect an employee’s privacy, do not enter the name on the Log.

Medical records

A confidential medical record for each employee with potential for exposure must be preserved and maintained according to OSHA’s standard governing access to employee exposure and medical records at §1910.1020. This standard requires that medical records must be kept confidential and maintained for at least the duration of employment plus 30 years. Also, if you contract with a healthcare provider, the medical records may be kept at their worksite.

In addition, under the bloodborne pathogens standard, medical records also must include the following information:

• Employee’s name and social security number;

• Employee’s hepatitis B vaccination status, including dates of all hepatitis B vaccinations and any medical records related to the employee’s ability to receive vaccinations;

• Results of examinations, medical testing, and post-exposure evaluation and follow-up procedures;

• The employer’s copy of the health care professional’s written opinion; and

• A copy of information provided to healthcare professional.

Sharps injury log

Employers having workers with occupational exposure to BBP must establish and maintain a sharps injury log for the recording of percutaneous injuries from contaminated sharps. The information in the sharps injury log has to be recorded and maintained in such manner as to protect the confidentiality of the injured employee. The sharps injury log need to contain, at a minimum:

• The type and brand of device involved in the incident,

• The department or work area where the exposure incident occurred, and

• An explanation of how the incident occurred.

Revision 12/05 This applies to any employer who is required to maintain a log of occupational injuries and illnesses under OSHA’s injury and illness recordkeeping standard, part 1904. However, employers may use the OSHA 300 Log and 301 incident report to meet the sharps injury log requirements. To use the recordkeeping forms, the type and brand of the device has to be entered on either the 300 or 301 form, and the records must be maintained in a way that segregates sharps injuries from other types of work injuries. However, if you prefer to maintain a separate sharps injury log, there is a sample form on page 77 of this chapter.

Training records

The bloodborne pathogens standard also requires you to maintain and to keep accurate training records. Training records are not considered to be confidential and may be stored onsite where they are easily accessible. They must be retained for three years from the training date. Employee training records must include the following:

• Training dates,

• Content or a summary of the training,

• Names and qualifications of trainer(s), and

• Names and job titles of trainees.

Records access

Upon request, both medical and training records must be made available to both NIOSH and OSHA officials. Training records must be available to employees or employee representatives upon request. Medical records can be obtained only by the employee or anyone having the employee’s written consent.

Also, if an employer ceases to do business, medical and training records must be transferred to the successor employer. If there is no successor employer, the employer must notify the director of NIOSH for specific directions regarding disposition of the records at least three months prior to intended disposal.