Training At-Risk Employees | Bloodborne Pathogens

All employees with a potential for exposure must be provided with adequate training and information including:

1. General explanations of the modes of transmission, symptoms, epidemiology, warning signals relating to possible exposure, and procedures to follow if exposure occurs.

2. Appropriate methods for recognizing tasks that may involve exposure to blood or other potentially infectious materials and the use and limitations of practices that would reduce exposure. This includes engineering controls, work practices, and personal protective equipment.

3. Information on the use, location, and decontamination/disposal of personal protective equipment and clothing, and information on what to do in an emergency.

Each occupationally exposed employee must be given free BBP information and training at the time of initial assignment and at least once a year thereafter. The training must be provided during working hours. Additional training is needed when existing tasks are modified or new tasks are required which affect the employees' occupational exposure.

A variety of written material, oral presentations, films, videos, computer programs, or audiotapes can be used in the training program. The information that is presented must be appropriate to the employee's education, literacy level, and language.

OSHA requires that the trainer provide opportunities for interactive questions and answers with trainees. That means that training done solely with a video or film without a discussion period would be a violation of the BBP standard. However, direct access to a qualified trainer via a telephone hot line or an immediate e-mail answer is an acceptable alternative.

Training Program Elements

Training sessions must be comprehensive, including information on bloodborne pathogens as well as on OSHA regulations relating to this standard and the employer's exposure control plan.

At a minimum, the training program must include the following elements:

• An accessible copy and explanation of the standard;

• A general explanation of the epidemiology and symptoms of bloodborne diseases;

• An explanation of the modes of transmission of bloodborne pathogens;

• An explanation of the written exposure control plan and how to obtain a copy;

• An explanation of how to recognize events that may involve exposure to blood and other potentially infectious materials;

• An explanation of the basis for selecting personal protective equipment, including information on the types, selection, proper use, location, removal, handling, decontamination, and disposal of personal protective equipment;

• An explanation of the use and limitations of safe work practices, engineering controls, and personal protective equipment;

• Information on hepatitis B vaccination, such as safety, benefits, effectiveness, and availability;

• An explanation of the procedures to follow if an exposure occurs, including methods of reporting and the medical follow-up that will be made available;

• Information on the post-exposure evaluation and follow-up required in the event of an exposure, and information on emergencies that relate to blood or other potentially infectious materials, follow-up procedures, and medical counseling;

• An explanation of information on warning signs, labels, and color-coding.

Trainer Qualifications

The person conducting the training must be knowledgeable in the subject matter, especially as it relates to the workplace that the training addresses. Trainer competency should be based on the completion of specialized courses, degree programs, or work experience.

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.

Identify Who Has Occupational Exposure

A majority of workers in the health care field routinely come into contact with blood and body fluids that potentially contain bloodborne pathogens. These workers are known to be at-risk. Other occupations where workers may be exposed to BBP and must be covered by an employer's exposure control plan include the following.

Emergency Responders, Firefighters, And Law Enforcement Personnel

For emergency responders such as firefighters, law enforcement agents, and other emergency response personnel, the potential sources of contamination from bloodborne pathogens are varied. Emergency responders assist when there is illness and at accidents and fires where there frequently is trauma, such as open wounds. Also, exposure and potential infection can result from handling discarded emergency medical items such as needles and sharps, bandages, or gauze.

Today's firefighters and emergency responders play a greater role in emergency situations, frequently as health care providers, and are often the first to arrive at the scene of an accident. For example, up to 80 percent of all field emergency medical care today is provided by fire service personnel. Although not officially classified as health care workers, fire and rescue personnel are consistently faced with the potential for exposure to infectious blood, blood products, blood components, and body fluids.

Emergency responders frequently face unpredictable, uncontrollable, dangerous, and life-threatening circumstances. Anything can happen in an emergency situation, including exposure to blood and contaminated equipment. This especially applies to fire and rescue personnel and, in many instances, law enforcement personnel who often operate under hostile circumstances. There is an extremely diverse range of potential situations that can put law enforcement officers at risk.

At crime scenes, when processing suspects, or as a result of fights and/or assaults, law enforcement officers may be at risk of exposure. The informed judgment and awareness of the individual officer is critical when unusual circumstances or events arise that can jeopardize his/her safety or health. It is the responsibility of emergency responders' employers to ensure that their employees are properly informed and adequately protected at the work site and in emergency situations.

In-Plant First Aid Responders

Employees who are trained and designated as responsible for rendering first aid or medical assistance as part of their job duties have the potential for exposure and must receive bloodborne pathogens training.

Maintenance Workers

While OSHA does not generally consider maintenance personnel and janitorial staff employed in non-health care facilities to have occupational exposure, it is the employer's responsibility to determine which job classifications or specific tasks and procedures involve occupational exposure. For instance, if maintenance or janitorial personnel are required to clean up following an incident involving body fluids, they would need bloodborne pathogens training.

Also, OSHA expects products such as used 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.

Note

Occupational exposure is defined as "reasonable anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee's duties." The definition of "other potentially infectious materials" includes any body fluid that is visibly contaminated with blood. Urine, feces, sweat, tears, nasal secretions, and vomitus which are not visibly contaminated with blood are not considered to by "other potentially infectious materials."

Personnel Service/Contract Workers

If your company uses personnel service workers and you, as the the host employer, exercise day-to-day supervision over those workers, then they are considered the employees of the host employer, as well as of the personnel service. In this situation, the host employer must comply with all provisions of the BBP standard with respect to these workers.

Regarding Hepatitis B vaccination, post-exposure evaluation and follow-up, recordkeeping, and generic training, the host employer's obligation is to take reasonable measures to assure that the personnel service firm has complied with these provisions.

Independent contractors that provide a service, such as a cleaning service, provide supervisory personnel, as well as rank-and-file workers to carry out the services. These companies and the host employers are responsible for complying with all provisions of the BBP standard according to OSHA's multi-employer worksite guidelines.

The Exposure Control Plan | Bloodborne Pathogens

A written exposure control plan is necessary for the safety and health of workers. Covered employers must develop a plan that identifies and documents the tasks, procedures, and job classifications covering instances where there is exposure to blood or other potentially infectious materials.

The written exposure control plan must document the following key elements:

• Job classifications: Identify job classifications and, in some cases, the tasks where there is exposure to blood and other potentially infectious materials.

• Schedule: Outline how and when the provisions of the standard will be implemented, including schedules and methods for communication of hazards to employees, hepatitis B vaccination and post-exposure evaluation and follow-up, recordkeeping and implementation of the methods of compliance, such as:

  • Engineering and work practice controls,

  • Personal protective equipment, and

  • Housekeeping.

• Evaluation: Procedures for evaluating the circumstances of an exposure incident.

The schedule of how and when the provisions of the standard will be implemented may be a calendar with brief notes describing the methods, an annotated copy of the standard, or part of another document, such as the infection control plan.

The written exposure control plan must be accessible to employees and must be reviewed and updated at least annually and whenever necessary to reflect new or modified tasks and procedures which affect occupational exposure and to reflect new or revised employee positions with occupational exposure. The review and update must also:

• Reflect changes in technology that eliminate or reduce exposure to bloodborne pathogens; and

• Document annually consideration and implementation of appropriate commercially available and effective safer medical devices designed to eliminate or minimize occupational exposure.

The employer must also request input from non-managerial employees responsible for direct patient care who are potentially exposed to injuries from contaminated sharps in the identification, evaluation, and selection of effective engineering and work practice controls. This process must be documented in the exposure control plan. Planning begins with identifying employees who have occupational exposure.