Back to Basics is a weekly feature that highlights important but perhaps overlooked information that any EHS professional should know.This week we examine Bloodborne Pathogens Standards and Enforcement.
Bloodborne pathogens (BBPs) are infectious microorganisms in human blood and other body fluids, known as “other potentially infectious agents,” that can cause hepatitis B (HBV), hepatitis C (HCV), and human immunodeficiency virus (HIV) and other diseases.
Of course, health care workers face the greatest risk from BBP. The Centers for Disease Control and Prevention (CDC) estimates that 5.6 million workers in health care and related occupations are at risk of occupational exposure to BBP.
But, did you know that the lodging industry is the second most cited industry for Occupational Safety and Health Administration (OSHA) BBP standards?
“Safer needles” with sharps protection are essential not only in hospitals and doctors’ offices, but also in retail pharmacies offering vaccinations.
BBP hazards can also appear in unexpected places, such as tag guns used to affix price tags to clothing.
A recent analysis released by the National Institute for Occupational Safety and Health (NIOSH) showed that 84% of sharps injuries occur among health care workers. The injury rate among health care workers is 16.7 per 10,000 full-time employees (FTE), which is more than six times the injury rate for all workers, which is 2.7 per 10,000 FTE.
NIOSH emphasizes the need for standardized education for all workers exposed to hazards to prevent sharps injuries.
Workplace violence is perhaps the most feared occupational hazard for health care workers, especially in acute psychiatric care and addiction treatment facilities, where patients sometimes grab, kick, punch, push, and trip staff. However, the risk of contracting hepatitis or HIV with BBP is also real.
For example, OSHA cited a Colorado psychiatric hospital for failing to protect employees from workplace violence, but also cited the facility’s repeated violations of BBP standards. The hospital failed to review and update its exposure control plan annually and consider adopting commercially available safer equipment, and it failed to locate sharps disposal containers near sites where lancets, syringes and other equipment are used in patient care.
While NIOSH researchers recognize that sharps injuries are a problem unique to health care workers, they have found that sharps injuries occur among workers in other industries as well. NIOSH researchers found that besides health care, sharps injuries most commonly occur in four other industries:
- justice, public order and security;
- tourist accommodation;
- professional schools such as colleges, universities, and junior colleges; and
- Pharmacies and pharmacies.
Following recent OSHA inspections and citations, drugstore chain Rite Aid agreed to implement a program to protect employees at approximately 370 stores in New Jersey and New York, including front-end customer service workers, from BBP hazards to resolve the agency’s citations. In February 2022, a retail employee at a Niagara Falls Rite Aid store was directed to clean up spilled blood after a customer was injured, the agency cited the pharmacy chain.
During the course of the investigation, OSHA learned that the employee had not been vaccinated against hepatitis B before or after the incident and that Rite Aid lacked an appropriate exposure control plan.
Under the regulatory settlement between OSHA and Rite Aid, the pharmacy chain agreed to several worker protections, including the following:
- Develop and implement an exposure control plan with safety precautions for retail employees who may be required to clean up or otherwise handle blood or other potentially infectious materials.
- Offer the hepatitis B vaccination series free of charge to all retail employees who may be required to clean up or otherwise handle or come into contact with blood or potentially infectious materials.
- Have store managers and third-party consultants monitor stores for compliance with the protocol’s requirements and report compliance to OSHA.
OSHA’s BBP standard is the fourth most cited standard for pharmacies and pharmacies in fiscal year (FY) 2022. While ambulatory health services, nursing and residential care facilities, and hospitals are the industries most cited for this standard, the second most cited industry is the lodging industry.
OSHA’s BBP Standard
Requirements of the BBP standard include exposure control plans, training, hepatitis B vaccination at the time of exposure, and other safeguards such as engineering controls to prevent needlestick and other sharps injuries. This standard protects workers who can reasonably be expected to be exposed to blood or other potentially infectious materials in the course of their job duties.
In 1986, unions representing health care employees petitioned OSHA to develop an Emergency Temporary Standard (ETS) to protect employees from occupational exposure to blood-borne diseases. The agency issued a proposed rule in 1989 and a final rule in 1991 establishing BBP standards.
In 2000, Congress passed the Needlestick Safety and Prevention Act, which directed OSHA to revise the standard to include several new provisions, including:
- Definition of Engineering Controls;
- Exposure control plans require the inclusion of technologies to eliminate or reduce exposure to BBP;
- Require employers to document annually consideration of exposure control plans and implementation of safer medical devices;
- Requires employers to require non-managerial employees responsible for direct patient care to provide input in the identification, evaluation, and selection of engineering and work practice controls and to document employee input in the exposure control plan; and
- Require that a log of percutaneous injuries caused by contaminated sharps be maintained.
Since the agency’s 2001 revision, BBP standards have required the use of engineering controls, such as safer needle devices with sharps injury prevention features, work practices, and personal protective equipment (PPE), if necessary, to prevent exposure to needles. Thorns and BBP.
According to OSHA, best practices to prevent sharps and needlestick injuries include:
- Plan safe handling and disposal before starting any procedures.
- Use safe and effective needle alternatives if available.
- Use needles with engineered sharps injury protection (SESIP).
- Always activate your device’s security features.
- Used sharps must not be passed between workers.
- Do not break, re-rope or cut contaminated needles.
- Immediately place contaminated needles in a properly secured, puncture-resistant, closable, leak-proof, labeled sharps container. Research shows that up to one-third of sharps injuries occur during disposal.
- Complete BBP training.
Work practices in the standards include housekeeping requirements for decontamination of equipment and surfaces that come into contact with blood or other potentially infectious materials. Labeled sharps containers must be closed before removal or replacement to prevent any spillage or protrusion. If a leak or spill is possible, sharps containers must be placed in a second container to prevent leaks.
Regulated waste must be placed in containers that meet the following conditions:
- Can be closed;
- Constructed to contain all contents and prevent leakage of liquids during handling, shipment, storage or transportation;
- Marking or color coding according to standard requirements; and
- Close before removal to prevent contents from spilling or protruding during handling, shipping, storage or transportation.
Contaminated clothing must be placed in color-coded, labeled bags. The Centers for Disease Control and Prevention (CDC) has infection control guidelines for laundering clothes, fabrics, and textiles.
OSHA Enforcement
When OSHA revised the standard in 2001 to incorporate changes mandated by the Needlestick Safety and Prevention Act, the agency updated its BBP Enforcement Policy (CPL 02-02-069). BBP compliance inspections include reviews of exposure control plans and employee interviews to assess compliance with standards.
During the opening meeting or inspection of a healthcare facility, the facility compliance safety and health officer (CSHO) will meet with facility administrators and directors of employee education and training, employee occupational health, housekeeping, and infection control.
The CSHO will review the facility’s sharps injury log and any exposure incident reports. If a healthcare facility has more than one employer, OSHA’s multi-employer citation policy (CPL 02-00-124) applies.
OSHA’s BBP standard is one of three standards the agency enforces for aircrews on operating aircraft, the other two being hazard communication and occupational noise exposure standards. In 1975, the Federal Aviation Administration (FAA) reaffirmed its responsibility for the operational safety of all civil aircraft, including the health and safety of aircrews. However, in a 2014 Memorandum of Understanding (MOU), the FAA accepted OSHA’s enforcement of BBP, hazard communication, and noise standards.
Share marker gun
The BBP standard applies to any industry where occupational exposure to blood and other potentially infectious materials can reasonably be expected, including garment workers who may become stuck in tag guns shared by workers.
Contaminated needlestick injuries occur when a worker accidentally punctures his skin with the needle of a marking gun, and another worker using the same gun and the same needle suffers the same injury.
The California Department of Occupational Safety and Health (Cal/OSHA) reminds apparel manufacturing and processing plants that frequently use tag guns that employers must comply with the state’s BBP standards. Cal/OSHA says the standard’s applicability to retail clothing stores depends on the specific circumstances of the workplace.
The agency recommends that one way to control exposure is to assign employees their own tag guns and implement and enforce a policy that prohibits employees from using any tag guns other than the one assigned to them.
The California Department of Public Health (CDPH) also recommends assigning workers personal tag guns, labeled with each worker’s name. Additional precautions CDPH recommends employers take include:
- Provide workers with lockers or other safe spaces to store tag guns when they are not in use,
- Provide appropriate biohazard waste containers for disposal of used needles,
- Instruct workers to report needlestick injuries to supervisors,
- Provide workers with training on the safe use of tag guns,
- Provide workers with training on BBP,
- Familiar with Cal/OSHA BBP standards, and
- Develop an Injury and Illness Prevention Plan (IIPP).
According to Cal/OSHA, California’s BBP standards cover two categories of workplaces: facilities and operations involving occupational exposure due to the inherent nature of the work performed, such as hospitals and other healthcare facilities, and workplaces where activities or tasks involve exposure to blood or other potentially infectious materials. These include laundry facilities and lodging facilities.
However, California’s BBP standards also apply across industries whenever employees are designated to provide first aid.
Federal and state BBP regulations apply whenever there is a reasonable expectation that workers will be exposed to blood or other substances (body fluids) that pose a risk of infection. Are your workers at risk? Are you ready to comply with BBP standards?