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, 180).
Employee information and training | Occupational Exposure to Bloodborne Pathogens
Paragraph (g) ensures that employees receive sufficient warning through labels, signs, and training to eliminate or minimize their exposure to bloodborne pathogens.
1. Labels, paragraph (g)(1). Labels must be provided on containers of regulated waste, on refrigerators and freezers that are used to store blood or OPIM, and on containers used to store, transport, or ship blood or OPIM. This requirement alerts employees to possible exposure since the nature of the material or contents will not always be readily identifiable as blood or OPIM.
2. DOT labeling is required on some transport containers (i.e., those containing “known infectious substances”). It is not required on all containers for which §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 that 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.
3. Inspection and citation guidelines: The Compliance Officer should determine that the warning labels in the facility are used as required by paragraphs (g)(1)(i)(A) through (D) and include the term “BIOHAZARD.”
4. Paragraphs (g)(1)(i)(E) through (G). These paragraphs list exemptions from the labeling requirements which are additional to those exemptions listed for specimens in paragraph (d)(2)(xiii)(A) and for laundry in paragraph (d)(4)(iv)(A)(2).
Blood and blood products bearing an identifying label as specified by the Food and Drug Administration, which have been screened for HBV and HIV antibodies and released for transfusion or other clinical uses, are exempted from the labeling requirements.
When blood is being drawn or laboratory procedures are being performed on blood samples, then the individual containers housing the blood or OPIM do not have to be labeled, provided the larger container into which they are placed for storage, transport, shipment, or disposal (e.g., a test tube rack) is labeled.
5. Paragraph (g)(1)(i)(I). Regulated waste that has been decontaminated by incineration, autoclaving, or chemical means, prior to disposal is not required to bear the BIOHAZARD warning label. Failure to ensure adequate decontamination procedures prior to removal of the hazard label should be cited under paragraph (g)(1)(i)(A), since the material would still be regulated waste.
6. Information and training — Paragraph (g)(2). All employees with occupational exposure must receive initial and annual training on the hazards associated with blood and OPIM, and the protective measures to be taken to minimize the risk of occupational exposure. Retraining must take place when changes in procedures or tasks occur which affect occupational exposure. While the provisions for employee training are performance oriented, with flexibility allowed to tailor the program to, for example, the employee’s background and responsibilities, the categories of information listed in paragraph (g)(2)(vii) must be covered, at a minimum. These requirements include some site-specific information.
Inspection guidelines: The Compliance Officer should verify that the training is provided at the time of initial employment and at least annually thereafter as well as whenever a change in an employee’s responsibilities, procedures, or work situation is such that an employee’s occupational exposure is affected. “At the time of initial assignment to tasks where occupational exposure may take place” means that employees must be trained prior to being placed in positions where occupational exposure may occur. The annual retraining for these employees must be provided within one year of their original training. This refresher training must cover topics listed in the standard to the extent needed and must emphasize new information or procedures. It does need to be an exact repetition of the previous annual training.
Part-time and temporary employees, and healthcare employees, known as “per diem” employees, are covered and are also to be trained on company time.
The Compliance Officer should interview a representative number of employees from different work areas to determine that the training (including written material, oral presentations, films, videos, computer programs, or audiotapes) was presented in a manner that was appropriate to the employee’s education, literacy level, and language. If an employee is only proficient in a foreign language, the trainer or an interpreter must convey the information in that foreign language.
7. Paragraphs (g)(2)(vii)(B) and (C). These paragraphs require that HIV and HBV and other blood-borne diseases be described. The employer must convey the idea that a number of bloodborne diseases other than HIV and HBV exist, such as hepatitis C (HCV) and syphilis. At the same time, the employer need not cover such uncommon diseases as Creutzfeldt-Jakob disease unless it is appropriate, for example, for employees working in a research facility with that particular virus.
HCV is the most common chronic bloodborne infection in the United States. Persons who are chronically infected with HCV may not be aware of their infection because they may not be clinically ill. The infection may lead to chronic liver disease that develops slowly, often taking two or more decades before it is recognized. It is important that training include information on the transmission and symptoms of HCV.
8. Paragraph (g)(2)(vii)(F). This paragraph requires that training include an explanation of the use and limitations of methods that will prevent or reduce exposure, including appropriate engineering controls, work practices, and personal protective equipment.
This requirement is very important, because the development of safer engineering controls introduces a variety of new techniques and practices to the work environment. Manufacturers market passive safety features, active devices, integrated safety designs, and accessory safety devices. The Record Summary respondents “repeatedly” emphasized the necessity of effective training and education whenever new engineering controls are implemented. Training must include instruction in any new techniques and practices. “Hands-on” training is particularly useful. Employee participation in the selection of new devices, which plays a major part in their acceptance and correct use, is also required. (See above discussion in paragraphs (c)(1)(iv), (c)(1)(v) and (d)(2) on engineering and work practice controls.)
9. Paragraph (g)(2)(vii)(J). The word “emergency” in this paragraph refers to blood or OPIM exposure outside the normal scope of work. This does not refer to hospital emergency rooms or emergency medical technicians’ work.
10. Paragraph (g)(2)(vii)(N). This paragraph requires that there be an opportunity for interactive questions and answers with the person conducting the training session. During training, it is critical that trainees have an opportunity to ask and receive answers to questions where material is unfamiliar to them. Frequently, a trainee may be unable to go further with the training or to understand related training content until a response is received.
Training the employees solely by means of a film or video without the opportunity for a discussion period would constitute a violation of this paragraph.
Similarly, a generic computer program, even an interactive one, is not considered appropriate unless the employer supplements such training with the site-specific information required (e.g., the location of the exposure control plan and the procedures to be followed if an exposure incident occurs) and a person is accessible for interaction.
Trainees must have direct access to a qualified trainer during training. OSHA’s requirement can be met if trainees have direct access to a trainer by way of a telephone hot line. The use of an electronic mail system to answer employee questions is not considered direct access to a qualified trainer, unless the trainer is available to answer e-mailed questions at the time the questions arise.
11. Paragraph (g)(2)(viii). The person conducting the training is required to be knowledgeable in the subject matter covered by the elements contained in the training program as it relates to the workplace that the training will address. In addition to demonstrating expertise in the area of the occupational hazard of bloodborne pathogens, the trainer must be familiar with the manner in which the elements in the training program relate to the particular workplace.
The Compliance Officer should verify the competency of the trainer based on the completion of specialized courses, degree programs, or work experience, if he/she determines that deficiencies in training exist.
Possible trainers include a variety of healthcare professionals such as infection control practitioners, nurse practitioners, registered nurses, occupational health professionals, physician’s assistants, and emergency medical technicians.
Non-healthcare professionals, such as but not limited to, industrial hygienists, epidemiologists, or professional trainers, may conduct the training provided they are knowledgeable in the subject matter covered by the elements contained in the training program as it relates to the workplace. One way, but not the only way, knowledge can be demonstrated is the fact that the person received specialized training.
In some workplaces, such as dental or physicians’ offices, the individual employer may conduct the training, provided he or she is familiar with bloodborne pathogen exposure control and the subject matter required by paragraphs (g)(2)(vii)(A) through (N).
12. Paragraphs (g)(2)(ix)(A)-(C). “Standard microbiological practices” as used in these paragraphs refer to procedures outlined in “Biosafety in Microbiological and Biomedical Laboratories.” The requirement that “proficiency” be demonstrated means that employees who are experienced laboratory workers may not need to be retrained in accordance with these paragraphs. Education such as a graduate degree in the study of viral diseases, or another closely related subject area with a period of related laboratory research experience, would also constitute “proficiency.” The employer is responsible for evaluating the employee’s proficiency and for documenting the mechanism used to determine proficiency.
The Hazard Communication Standard requires chemical manufacturers, importers, and distributors to ensure that all containers of hazardou...
As part of a hazard communication written program, you will need to compile a list of all hazardous chemicals used, or present in your workp...
Q. Who must be offered the hepatitis B vaccination? A. The hepatitis B vaccination series must be made available to all employees who ...
§1910.1030(f) This paragraph provides a means to protect employees from infection caused by the hepatitis B virus by requiring employers to...
Days Away, Restricted, or Transferred (DART) Rate This includes cases involving days away from work, restricted work activity, and transf...