Enforcement Procedures for the Occupational Exposure Of Bloodborne Pathogens

The Occupational Safety & Health Administration (OSHA) is a federal agency established for maintaining a safe and healthy work environment for America's workers. On their website, OSHA provides a directive entitled, "Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens." It includes specific procedural instructions to ensure uniform inspections of facilities where hazards, such as bloodborne pathogens, exist for employees.

Regulated Occupations

• According to OSHA, some of the occupations that place employees at risk for exposure to bloodborne pathogens include health care providers, dentists, emergency medical technicians, paramedics, firefighters, police, correctional officers, hospital laundry workers, employees in blood banks, home health care workers and maintenance employees in hospitals and clinics.

Employer's Reports

• Employers are responsible for maintaining an exposure control plan that is accessible to all employees. The plan identifies job-related tasks that involve possible exposure to bloodborne pathogens and outlines procedures that reduce exposure. The OSHA inspector reviews the exposure control plan to make certain it contains the information necessary to safeguard employees from risk of contamination. Also evaluated during the inspection are incident reports and documentation of injuries.

Employee Interviews

• Interviews with employees aid in determining compliance with OSHA regulations, adequacy of training and level of adherence to procedural standards. The inspector gathers information from employees regarding engineering controls provided by the employer such as needle-less devices to prevent needle-stick injuries, and work practices like proper handling of contaminated sharps (needles) to eliminate hazard exposure.

Employer Responsibilities

• The employer is responsible for providing, cleaning and disposing of personal protective equipment (PPE) such as uniforms, surgical masks, protective eyeglasses or face shields. The employer or a staff member with a thorough knowledge of the OSHA standards must provide training for employees, with retraining at least once a year. The employer must keep records of all injuries in logs, such as the sharps injury log. Employers are also responsible for paying for hepatitis B vaccinations (HBV) for employees at risk of coming into contact with blood.

Cleaning

• OSHA inspectors check for written procedures and instructions for cleaning, sterilization and decontamination of every implement, surface and location within the facility subject to contamination by blood and other potentially infectious material. The written instructions must fully describe accepted procedures for decontamination of places like patient treatment rooms, surgical rooms, counters, floors and instruments exposed to blood and other sources of contamination.

Signs and Labels

• The OSHA inspector also checks for required signs and labels. Warning signs and labels indicating hazards or infectious materials must be visible to alert all employees to the danger of possible contamination.