Special Topics in Safety Management

Are You Covered by the Bloodborne Pathogens Standard?

Tomorrow, July 28, is World Hepatitis Day. According to the World Health Organization, 400 million people worldwide are currently living with hepatitis B and C, and 1.4 million die of these diseases each year. OSHA is taking workplace exposures to bloodborne pathogens seriously. On June 25, the agency issued enforcement guidance for inpatient healthcare settings that emphasizes bloodborne pathogens compliance—but it’s important to realize that healthcare employers are not the only employers that are covered.

Keep reading to find out whether you need to comply with the requirements of 29 CFR 1910.1030, the bloodborne pathogens standard.

Which Employers are Covered by the Bloodborne Pathogens Standard?

Although OSHA’s enforcement guidance emphasizes healthcare employers, because their workers are at the highest risk of exposure, the agency emphasizes that healthcare workers are not the only workers at risk. “The hazard of exposure to infectious materials affects employees in many types of employment and is not restricted to the healthcare industry,” the enforcement guidelines state.

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That said, specific coverage under the bloodborne pathogens standard (29 CFR 1910.1030) applies to general industry employers and also to shipyard employers. The shipyard standards incorporate the general industry bloodborne pathogens standard by reference in 29 CFR 1915.1030.

In the construction, agriculture, marine terminal, and longshoring industries, the bloodborne pathogens standard does not apply. Bloodborne pathogens hazards do occur in these industries, however, OSHA relies on the General Duty Clause, Section 5(a)(1) of the OSH Act, to cite an employer’s failure to provide a workplace “free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.” Hazards that OSHA specifically mentions as possible grounds for a General Duty Clause citation in these industries include:

  • Failure to provide appropriate evaluation of first-aid incidents (including the determination of whether an exposure incident occurred)
  • Inadequate follow-up of exposure incidents (including a failure to provide the hepatitis B vaccine series free of charge)

Which Employees Are Involved in the Bloodborne Pathogens Program?

When an OSHA inspector is looking closely at your bloodborne pathogens program, the inspector will want to speak with facility administrator or general manager, as well as (where applicable):

  • The director of infection control
  • The occupational health coordinator or administrator
  • The director of training and education
  • The person in charge of environmental services and/or housekeeping

These individuals will be interviewed either during the opening conference or interviewed early in the inspection.

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With respect to employees who are covered by the requirements of the standard, any worker with the potential for occupational exposure must receive immunizations and training as required by the standard. There is a list of affected job titles in the standard that primarily encompasses healthcare workers, laboratory workers, and mortuary workers, but OSHA notes that the scope of the standard is not limited to employees in these jobs. Any employee who is trained in first aid and identified by the employer as responsible for rendering medical assistance as part of his or her job duties is covered by the standard, according to OSHA.

The Bottom Line

If you are in general industry or the shipyard industry, and you have workers who could, as part of their job duties, be exposed to blood, bodily fluids, or other potentially infectious material, you are covered by the standard. If you are in other industries, OSHA will cite serious bloodborne pathogens exposures under the General Duty Clause.

Tomorrow, we’ll look at the recordkeeping requirements that apply—even in workplaces where the other requirements of the bloodborne pathogens standard don’t apply.