BLOODBORNE  PATHOGENS
 Arkansas Workers’ Compensation Commission/ Health & Safety Division
www.awcc.state.ar.us   1-800-622-4472   FAX: 501-683-3169
Health&Safety@awcc.state.ar.us
GOAL
					
This program is designed to ensure the health and safety of workers with occupational exposure to Bloodborne Pathogens.

OBJECTIVE 

This information will assist employers in developing an Exposure Control Plan specific to their facility.

BACKGROUND

In the mid 1980's, workers from the healthcare field petitioned OSHA for a standard to protect those at risk of contracting Hepatitis B Virus (HBV), Human Immunodeficiency Virus (HIV), and other bloodborne pathogens.  OSHA responded to this concern by developing the Bloodborne Pathogens Standard, 29 CFR 1910.1030.

When the standard came into effect on June 4, 1992, the public thought of it as solely regulating the healthcare industry.  However, the standard also applies to any employer whose employee’s duty is to work with blood, body fluids, or other potentially infectious materials.  This includes first aid responders, medical researchers, teachers, school nurses and others who may be required to offer assistance to an injured person.  

The standard is based on universal precautions.  Universal precautions were developed in 1987 when the Centers for Disease Control published guidelines with instructions to treat all people as if they are infected with a bloodborne disease.  These precautions are intended to protect workers at risk of exposure. 

DEFINITIONS

The standard lists definitions for terminology associated with bloodborne pathogens.  Some of the more critical definitions are:

Other Potentially Infectious Material - any human body fluids (semen, vaginal secretions, cerebrospinal, synovial pleural, pericardial, peritoneal, amniotic fluids, saliva; any body fluid that is visibly contaminated with blood, and all body fluids in situations where it is difficult or impossible to differentiate between body fluids; any unfixed tissue or organ from a human (living or dead); HIV-containing cell or tissue cultures, organ cultures, and HIV- or HBV-containing culture medium or other solutions; and blood, organs, or other tissues from experimental animals infected with HIV or HBV.

Contaminated - the presence or the reasonably anticipated presence of blood or other potentially infectious materials on an item or surface. 

Parenteral - piercing mucous membranes or the skin barrier through such events as needle sticks, human bites, cuts and abrasions.  

Occupational Exposure - reasonably 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. 

Engineering Controls - controls (e.g., containers for disposing sharp objects, self-sheathing needles) that isolate or remove the bloodborne pathogens hazard from the workplace. 

Work Practice Controls - controls that reduce the likelihood of exposure by altering the manner in which a task is performed (e.g., prohibiting recapping of needles using a two-handed technique.)

EXPOSURE CONTROL PLAN

The standard requires employers to develop a written Exposure Control Plan.  This plan is divided into 3 sections:

1.	Exposure determination, 
2.	Schedule for methods of implementing sections of the standard, and 
3.	Procedures for evaluating an exposure incident as described under the section, “Evaluation Of An Exposure”.

The plan must be reviewed and updated at least annually or whenever new personnel, tasks or procedures effect occupational exposure.  It must be available to all employees upon request. 

EXPOSURE DETERMINATION

The exposure determination is made by reviewing job classifications within the work environment without regard to the use of personal protective equipment.  The job classifications are then listed into two types.  Type I include job classifications in which all employees have occupational exposure, such as operating room scrub nurses.  Type II includes those classifications in which some employees have occupational exposure.  Specific tasks and procedures causing occupational exposure must be listed for Type II employees. For instance, some workers might be assigned the task of handling contaminated laundry in a hospital laundry room while other laundry personnel would not.  Once employees with occupational exposure have been identified, the hazards must be communicated to these employees.  

SCHEDULE & IMPLEMENTATION

This portion addresses the schedule and method for implementing sections of the Bloodborne Pathogens rule.  These sections cover compliance; hepatitis B vaccination and post-exposure evaluations and follow-up; hazard communication (labels and information training); and required recordkeeping. 

Methods of Compliance.  Compliance to the Bloodborne Pathogens standard involves three facets: engineering and work practice controls, personal protective equipment, and housekeeping.  

Engineering and work practice controls are the primary methods used to eliminate or minimize occupational transmission of HBV and HIV.  Personal protective equipment and clothing are also necessary when occupational exposure to bloodborne pathogens remains even after instituting these controls. 

Engineering controls reduce employee exposure by either removing, or isolating the hazard, or isolating the worker from exposure.  Self-sheathing needles, puncture-resistant disposal containers for contaminated sharp instruments, hand washing facilities, resuscitation bags, and ventilation devices are examples of engineering controls.  Engineering controls must be examined and maintained or replaced on a scheduled basis to ensure effectiveness. 

Work practice controls alter the manner in which a task is performed.  In work areas where a reasonable likelihood of occupational exposure exists, work practice controls required include:

•	Restricting eating, drinking, smoking, applying cosmetics or lip balm, and handling contact lenses;
•	Prohibiting mouth pipetting (apparatus whereby fluid is drawn by suction and retained by closing the upper end);
•	Preventing the storage of food and/or drink in refrigerators or other locations where blood or other potentially infectious materials are kept;
•	Requiring the use of hand washing facilities; routinely checking equipment and decontaminating it prior to servicing and shipping. 

Other work practice requirements include:

•	Washing hands when gloves are removed and as soon as possible after skin contact with blood or other potentially infectious materials occurs. 
•	Recapping, removing or bending needles is prohibited unless the employer can demonstrate that no alternative is feasible or that such action is required by a specific medical procedure. 
•	When recapping, bending or removing contaminated needles is required by a medical procedure, this must be done by mechanical means, such as the use of forceps, or a one-handed technique. 
•	Shearing or breaking contaminated needles is not permitted. 

Personal Protective Equipment helps reduce occupational exposure to infectious materials. Such equipment includes: gloves, gowns, laboratory coats, face shields or masks, eye protection, etc.   Personal protective equipment must also be used if occupational exposure remains after instituting engineering and work practice controls, or if those controls are not feasible. 

Personal protective equipment is considered appropriate only if it prevents direct contact of blood or other potentially infectious materials with clothes, skin, eyes, mouth, or other mucous membranes.   This equipment should protect the worker under normal conditions of use and for the duration of time which the protective equipment is used. 

 Under the standard, employers must provide, make accessible, and require the use of personal protective equipment at no cost to the employee.  Personal protective equipment also must be provided in appropriate sizes.  Hypoallergenic gloves or other similar alternatives must be made available to employees who have an allergic sensitivity to gloves. Employers also must ensure that protective equipment is properly used, cleaned, laundered, repaired or replaced, as needed.

The employer must also ensure that employees observe the following precautions for safe handling and using personal protective equipment: 

•	Remove protective equipment before leaving the work area and after a garment becomes contaminated. 
•	Place used protective equipment in appropriately designated areas or containers when being stored, washed, decontaminated, or discarded. 
•	Wear appropriate gloves when it can be reasonably anticipated that the employee may have contact with blood, other potentially infectious materials; when performing vascular access procedures; and when handling or touching contaminated items or surfaces.  Replace gloves if torn, punctured, contaminated, or their ability to function as a barrier is compromised.  Never wash or decontaminate disposable gloves for reuse. 
•	Utility gloves may be decontaminated for reuse if their integrity is not compromised.  Discard utility gloves when they show signs of cracking, peeling, tearing, puncturing, or deteriorating. 
•	 Wear appropriate face and eye protection such as a mask with glasses with solid side shields or a chin-length face shield when splashes, sprays, spatters, or droplets of blood or other potentially infectious materials pose a hazard to the eye, nose or mouth. 
•	Wear appropriate protective body covering such as gowns, aprons, caps and boots when occupational exposure is anticipated.  The type and characteristics will depend upon the task and degree of exposure anticipated.

Under the standard, clean and sanitary Housekeeping must be kept for each place of employment. The employer must develop and implement a cleaning schedule that includes appropriate methods of decontamination and tasks or procedures to be performed This written schedule must be based on the location within the facility, the type of surfaces to be cleaned, the type of contamination present, the tasks or procedures to be performed, and their location within the facility. 

The employer must also ensure the following housekeeping procedures are followed:

•	Clean and decontaminate all equipment and environmental and work surfaces that have been contaminated with blood or other potentially infectious materials. 
•	Decontaminate work surfaces with an appropriate disinfectant, after completion of procedures; immediately when overtly contaminated; after any spill of blood or other potentially infectious materials; and at the end of the work shift when surfaces have become contaminated since the last cleaning. 
•	Remove and replace protective coverings such as plastic wrap and aluminum foil when contaminated. 
•	Inspect and decontaminate, on a regular basis, reusable receptacles such as bins, pails, and cans that have a likelihood for becoming contaminated.  When contamination is visible, clean and decontaminate receptacles immediately or as soon as feasible. 
•	Always use mechanical means such as tongs, forceps, or a brush and a dust pan to pick up contaminated broken glassware; never pick up with hands even if gloves are worn. 
•	Store or process reusable sharp objects in a way that ensures safe handling. 
•	Place other regulated waste (liquid, liquid-blood, items contaminated with blood or other potentially infectious materials, contaminated sharps, etc.) in closable and labeled or color-coded containers.  When storing, handling, transporting or shipping, place other regulated waste in containers that are constructed to prevent leakage. 
•	Discard contaminated sharp objects, place them in containers that are closable, puncture resistant, appropriately labeled or color-coded, and leakproof on sides and bottom. 
•	Ensure that containers for sharp objects are easily accessible to personnel and located as close as is feasible to the immediate area where sharps are used or can be reasonably anticipated to be found. Sharps containers must also be kept upright throughout use, replaced routinely, closed when moved, and not allowed to overfill. 
•	Never manually open, empty, or clean reusable containers where sharp objects are stored. 
•	Discard all regulated waste according to federal, state and local regulations. 
•	Bag contaminated laundry at its location after use. Never sort or rinse contaminated laundry in areas of its use.  Laundry should be handled as little as possible using appropriate personal protective equipment. Wet contaminated laundry must be placed in leakproof, labeled or color-coded containers before transporting. 

Hepatitis B Vaccination. Employers are required to make the hepatitis B vaccine and vaccination series available to all employees who have occupational exposure, as well as post-exposure evaluation and follow-up to all employees who experience an exposure incident.  The vaccine and vaccination must be made available at no cost to the employee, provided at a reasonable time and place, and performed by or under the supervision of a licensed physician or another licensed health care provider.  

Employees who decline the vaccination must sign a declination form.  Employees reserve the right to request and obtain the vaccination at a later date and at no cost, if the employee continues to be exposed. 

The vaccine and vaccination series must be offered within 10 working days of initial assignment to employees who have occupational exposure to blood or other potentially infectious materials unless:

1.	the employee has already received the complete hepatitis B vaccination series, 
2.	antibody test reveals that the employee is immune, or 
3.	medical reasons prevent taking the vaccinations. 

Evaluation of an Exposure.  Once a report of an exposure has been documented the standard requires the post-exposure medical evaluation and follow-up be made available immediately for employees who have had an exposure incident. At a minimum, the evaluation and follow-up must include the following elements:

•	Document the routes and circumstances of exposure. 
•	Identify and obtain consent for testing of the source individual to determine HIV and HBV infectivity and document the source’s blood test results. 
•	Provide the exposed employee with the source individual’s test results and information about applicable disclosure laws and regulations concerning the source identity and infectious status.  Collect and test exposed employee’s blood as soon as feasible for HBV and HIV serological status after obtaining consent. 
•	If the employee does not give consent for HIV serological testing during the collection of blood for baseline testing, preserve the baseline blood sample for at least 90 days. 
•	Provide HBV and HIV serological testing, counseling, and safe and effective post-exposure prophylaxis following the current recommendations of the U.S. Public Health Service. 

*  If  consent  is not obtained, the employer must show that legally required consent could not be obtained.  If the source individual is known to be infected with either HIV or HBV, testing need not be repeated to determine the known infectivity. 

The health care provider responsible for the employee’s hepatitis B vaccination and post-exposure evaluation and follow-up must be given a copy of the 29 CFR 1910.1030 standard.  The provider must also receive a description of the employee’s job duties, results of the incident investigation including the source individual’s blood test results, if available, and all relevant employee medical records. 

When the evaluation is completed, the employee must receive a copy of the health care provider’s written opinion within fifteen days.  The written opinion must state if the HBV vaccination is indicated and if the vaccination has been received.  The written opinion for post-exposure evaluation must document that the employee has been informed of the results of the medical evaluation and of any medical conditions resulting from the exposure incident that may require further evaluation or treatment. All medical records must be kept in accordance with 29 CFR 1910.20.

Hazard Communication.  Communicating hazards of occupational exposure to bloodborne pathogens is accomplished through labels and information and training. 

The colors and symbols are a large part of the universal precautions system.  Warning labels for bloodborne pathogens are required to be fluorescent orange or orang-red with the word BIOHAZARD and the biohazard symbol in a contrasting color.

These labels must be attached (by means to prevent loss or unintentional removal) to containers of regulated waste, refrigerators and freezers containing blood or other potentially infectious materials, and other containers used to store, transport or ship blood or other potentially infectious materials. 

The labels are not required when red bags or red containers are used; when containers of blood, blood components, or blood products are labeled as to their contents and have been released for transfusion or other clinical use and when individual containers of blood or other potentially infectious materials are placed in a labeled container during storage, transport shipment or disposal.  The following table provides guidelines on the labeling requirements of the standard: 

LABELING REQUIREMENTS

	ITEM					BIOHAZARD LABEL		RED CONTAINER

Regulated waste container
(contaminated sharps containers)			X		or		X

Reusable contaminated sharps containers
(surgical instruments soaking in a tray)			X		or		X

Refrigerator/freezer holding blood or other 
potentially infectious materials				X

Containers used for storage, transport or 
shipping of blood					X		or		X

Blood/blood products for clinical use				No labels required

*Individual specimen containers of blood or 
other potentially infectious materials remaining 
in facility						X		or 		X

**Contaminated equipment needing service
(dialysis equipment, suction apparatus)			X

Specimens and regulated waste shipped from 
the primary facility to another for service or disposal	X		or		X

***Contaminated laundry				X		or		X

Contaminated laundry sent to another facility 
that does not use Universal Precautions			X		or		X

*No label is needed if Universal Precautions are used and 
specific use of container or item is known to all employees 
or 
**Include a label specifying where the contamination exists.
***Alternative labeling or color coding is sufficient if it permits 
all employees to recognize the containers as requiring compliance 
with Universal Precautions. 

Information and training must be provided at no charge to occupationally exposed employees at the time of initial assignment and on a yearly basis thereafter. Additional training is needed when existing tasks are modified or new tasks involving occupational exposure to bloodborne pathogens affect the employee’s exposure.  Training must be conducted by a person knowledgeable about the subject matter.  The information provided must be appropriate in content and vocabulary to educational level, literacy and language of the audience.  Training must contain the following:

•	Information on obtaining a copy of the standard and an explanation of its contents;
•	Information on the epidemiology , symptoms, and transmission of bloodborne diseases;
•	Information on recognizing tasks that might result in occupational exposure;
•	Explanation of the Exposure Control Plan and the means by which an employee can obtain a copy;
•	Explanation of the use and limitations of work practice and engineering controls, and personal protective equipment;
•	Information on the types, selection, proper use, location, removal, handling, decontamination, and disposal of personal protective equipment;
•	Information on hepatitis B vaccination such as safety benefits, efficacy, methods of administration and availability;
•	Information on who to contact and what to do in an emergency to include reporting an exposure incident;
•	Information on the post-exposure evaluation and medical follow-up;
•	Information on warning labels, signs, and color-coding; and 
•	Question and answer session on any aspect of training. 
 
Recordkeeping Requirements. Medical and training records must be maintained under the standard.  Medical records must be kept according to 29 CFR 1910.20 and include specific bloodborne pathogens requirements.  These records must be kept confidential and maintained for at least the duration of employment plus 30 years.  The medical records must contain:

•	Employee’s name and social security number,
•	HBV status including dates and any records related to employee’s ability to receive vaccinations,
•	Results of examinations, medical testing, and post-exposure evaluation and follow-up procedures,
•	Health care provider’s written opinion, and
•	A copy of the information provided to the healthcare provider

Training records must be maintained for 3 years and include training dates, content/summary of training, names and qualifications of trainers, and names and job titles of training attendees.  These records must be available to employees or their representatives upon request. 

Employers must also comply with the Arkansas Workers’ Compensation Law regarding work-related injuries or illnesses.  Once an employer becomes aware that an employee has become infected through occupational exposure, the employer is required to complete the Arkansas Workers’ Compensation First Report of Injury or Illness (Form 1A-1).

REFERENCES

Videos pertinent to this subject may be obtained from the Arkansas Department of Labor/ Arkansas Workers’ Compensation Commission’s Health and Safety Resource Center at (501) 682-9090.