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Employer and Employee Compliance

Adherence to the OSHA blood-borne pathogen standard is mandatory for all hospitals and healthcare facilities. To be in compliance with the standard employers must establish a written plan for controlling exposure to blood-borne pathogens. This plan should include 1) an assessment of risk situations, 2) a determination of which employees are at risk and when they are at risk, and 3) specific actions the employer will use to control and manage exposure to blood-borne pathogens. The plan must be reviewed and updated annually and it must be accessible to all employees, as outlined below.

  • Implement standard precautions, ensure that employees knowhow to use standard precautions, and ensure they use standard precautions.
  • Provide personal protective equipment (PPE) at no cost to all employees who need it. Indicate critical or common timesPPE should bedonned.
  • Provide initial training and annual training on blood-borne pathogens to all employees. This training should include 1) areview of the OSHA Blood-borne pathogens standard, 2) information on the risks of exposures and how exposures happen, 3) information on how to prevent exposures to blood-borne pathogens,and

4) Information on the benefits and risk of vaccination against hepatitis B.

  • Use engineering controls to control risk. Engineering controls that control the risk of exposure to blood-borne pathogens wouldinclude providing sharps disposal boxes, using safe medical devices, using needles that do not need to be re-capped, providing proper waste disposal containers, and using appropriate signs to warn of danger and to instruct employees on the proper use ofequipment.
  • Use work practice controls. The employer must have a plan orplans in place for the proper handling and disposal of blood and other specimens, the proper handling and disposal of contaminated waste, and for the proper cleaning and decontamination of equipment, patient rooms, and patient careareas.
  • Offer vaccination against hepatitis B to all employees who maybe reasonably expected to have an occupational exposure to the hepatitis Bvirus.
  • Have a plan to handle employee exposure to blood-borne pathogens. This plan should include provisions for immediate care (i.e., evaluation, first aid, laboratory screening tests, post-exposure prophylactic medications) and follow-upcare.

All health employees must comply with the requirements of the blood- borne pathogens standard. The ones that address needlestick injuries and exposure to a blood-borne pathogen will be discussed separately.

Other requirements of standard 1910.1030 that apply to healthcare workers include:

  1. Understanding and following the engineering and work practice controls established by the employer such as proper waste disposal and adhering to the employer’s safety and sanitaryrules.
  • Using PPE correctly; the employee is required to wear the appropriate PPE. The PPE must be removed immediately upon removing the work area, or as soon as possible, and it mustbe placed in a container specifically designated for the purpose of receiving contaminatedwaste.
  • Proper handling of blood and other bodyfluids.
  • Understanding and using UniversalPrecautions.
  • Proper use of medical equipment; i.e., do not bend, break, or re- cap needles. Do not re-use disposable medicalequipment.
  • Proper disposal of contaminated or potentiallycontaminated medicalequipment.
  • Disposable gloves must be discarded as soon as possible afterthey have become contaminated, punctured, or torn. Gloves are not required to be worn when giving an injection as long as hand contact with blood or other potentially infectious material is not reasonablyexpected.
  • Employees must wash their hands immediately after removing gloves or as soon as possible after removing gloves. Employees must wash their hands after contact with blood or otherpotentially infectious material and before and after performing patient care. If hand washing with soap and running water is not possible, the employee must use either an antiseptic hand cleaner with clean cloth or paper towels or antiseptic towelettes. After usingan antiseptic hand cleaner or a towelette, employees must wash their hands with soap and running water as soon as feasible.
  • Food and drink should not be stored in refrigerators, cabinets, etc., where blood or other potentially infectious material willbe stored.
  1. Double-bagging specimens are required if the outside of the specimen container is contaminated or if the specimencould puncture the primarycontainer.