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.