2.5 Exposure Incidents: Standard Precautions, OSHA, CDC & Colorado's Blood-Exposure Rule
Key Takeaways
Colorado defines Standard Precautions as infection-control practices that treat all blood, body fluids, broken skin and mucous membranes as potentially infectious (4 CCR 731-1, Rule 1.7(A)(14)).
Under Colorado Rule 1.7(F), a technician must stop the service when a client or technician is injured, follow blood-exposure procedures and resume only when it is safe.
Colorado requires blood-contaminated surfaces to be cleaned and disinfected under Standard Precautions, per the manufacturer's instructions, until all blood is removed.
Colorado requires lancets, razors and other sharps to go into a puncture-resistant container marked with the biohazard symbol (Rule 1.7(D)(4)).
OSHA's Bloodborne Pathogens Standard (29 CFR 1910.1030) requires employers with exposed employees to offer the hepatitis B vaccine, provide PPE and arrange post-exposure follow-up.
What Counts as an Exposure Incident
An exposure incident is specific contact of the eye, mouth or other mucous membrane, broken skin, or a puncture with blood or other potentially infectious material. At the nail table, it usually means a nipper nick on the cuticle area, a file abrasion on a sidewall, or a technician poking a finger with a contaminated implement. The pathogens of concern are the bloodborne pathogens, chiefly hepatitis B virus (HBV), hepatitis C virus (HCV) and HIV. CDC reports that HBV can survive in dried blood on surfaces for at least 7 days, so a "small" spot of dried blood on a table still matters.
PSI's outline names the frameworks: "Procedures for exposure incidents (e.g., Standard/Universal Precautions, OSHA, CDC)."
Standard Precautions
Colorado's Rule 1.7(A)(14) defines Standard Precautions, previously called Universal Precautions, as infection-control practices that prevent transmission of communicable diseases, including HIV, hepatitis B and hepatitis C. Two parts of the definition are commonly tested:
- They apply to all body fluids, including blood, non-intact skin, mucous membranes, secretions and excretions, whether or not blood is visible.
- They include hand washing and personal protective equipment (PPE) such as gloves, gowns and masks whenever contact with blood or body fluid is anticipated.
The core idea is that you cannot tell who is infected by looking. Every client's blood is handled as if infectious, every time.
The Regulatory Layers
| Source | What it contributes |
|---|---|
| Colorado Rule 1.7(F) | Stop the service, follow blood-exposure procedures, clean and disinfect contaminated surfaces using Standard Precautions, return to service only when safe |
| Colorado Rule 1.7(D)(4) | Sharps, including lancets and razors, go into a puncture-resistant container marked with a biohazard symbol and are sent to a collection site when full |
| Colorado Rule 1.6(E)(4) | First aid kit on the premises with at least bandages, gauze and antiseptic |
| OSHA Bloodborne Pathogens Standard (29 CFR 1910.1030) | For employers whose employees have reasonably anticipated exposure: written exposure control plan, training, PPE at no cost, hepatitis B vaccination offered at no cost, and post-exposure evaluation and follow-up |
| CDC guidance | Standard Precautions, hand hygiene, and the facts on survival and transmission of bloodborne viruses |
OSHA standards protect employees, so they bind employers. Booth renters who work for themselves are not "employees," but the same practices protect them and are what PSI tests.
Procedure: The Client Is Cut
The textbooks PSI cites describe a sequence like this, which also satisfies Colorado's rule:
- Stop the service calmly and tell the client what happened.
- Put on gloves if you are not already wearing them.
- Control bleeding with direct pressure using clean gauze or cotton.
- Clean the area with an antiseptic. Apply antiseptic or a liquid or powder styptic with a single-use applicator, never by touching a styptic pencil or container to the wound.
- Cover the wound with an adhesive bandage from the first aid kit.
- Clean and disinfect the workstation surfaces that blood touched, until all blood is removed, following the disinfectant's directions (Rule 1.7(F)(3)).
- Dispose of contaminated single-use items. Many textbooks recommend double-bagging blood-soiled cotton, gauze and gloves and marking the bag with a biohazard label. OSHA classifies items as "regulated waste" only when they would release blood if compressed or are caked with dried blood. Put sharps in the biohazard sharps container.
- Clean and disinfect contaminated implements. Remove them from service, then clean and disinfect them with a hospital disinfectant whose label covers bloodborne pathogens, following its contact time.
- Remove gloves, wash your hands, put on fresh gloves if continuing, and resume the service only if it can be done safely. Do not continue working over the open wound.
Procedure: The Technician Is Cut
Rule 1.7(F)(2) gives the same structure for a licensee injury: stop, follow blood-exposure procedures, and return to service only when safe.
- Stop and move away from the client and the station.
- Wash the wound with soap and water; for an eye or mouth splash, flush with clean water.
- Apply antiseptic and a bandage, and put on a glove over it before returning to work.
- Clean and disinfect contaminated surfaces and implements as above.
- Report the incident. An employer covered by OSHA must arrange a confidential medical evaluation and follow-up after an exposure incident. Even a self-employed technician should seek prompt medical advice after a puncture from an implement used on a client, because post-exposure treatment works best when started quickly.
Procedure: A Blood Spot on a Surface
When blood or body fluid touches a table, chair or floor, Rule 1.7(F)(3) requires you to clean and disinfect the area according to the manufacturer's instructions until all blood and body fluid is removed, using Standard Precautions. In practice:
- put on gloves;
- wipe up the visible material with disposable towels;
- clean the surface with detergent;
- apply the hospital disinfectant and keep the surface wet for the label's full contact time; and
- discard the towels and gloves and wash your hands.
PSI's practical lists the same skill in its infection-control examples: if blood, vomit or feces appears during a service, deal with it "without contaminating ourselves and others."
Prevention Beats Response
- Use nippers only on dead, detached tissue; never cut living skin.
- Keep a firm grip on the client's finger and a fulcrum for electric filing.
- Use sharp, well-maintained nippers so they cut cleanly.
- Decline or modify services on thin, fragile or diabetic skin (Chapter 5).
- Get the hepatitis B vaccine. There is no vaccine for hepatitis C or HIV.
Warning
Never apply a styptic pencil directly to a client's cut and then return it to the drawer. The pencil becomes contaminated with blood, so treat styptic as single-use: liquid or powder dispensed onto a disposable applicator.
According to Colorado's definition in Rule 1.7(A)(14), when do Standard Precautions apply?
To all blood, body fluids, broken skin and mucous membranes, visible blood or not
Only when a client discloses an infectious disease on the intake form
Only in medical spas that perform invasive procedures
Only when blood is visible on a surface or implement
A technician nicks a client's lateral nail fold and it bleeds. What does Colorado Rule 1.7(F) require first?
Apply a styptic pencil and keep working
Stop the service and follow blood-exposure procedures
Ask the client to sign an incident waiver before continuing
Finish the manicure quickly, then clean up
Under 4 CCR 731-1, where must a used lancet or razor blade go?
A paper bag taped shut and placed in a dumpster
The regular lined trash can at the station
A puncture-resistant container marked with a biohazard symbol
The closed container for used implements awaiting disinfection
Which obligation does OSHA's Bloodborne Pathogens Standard place on a salon employer whose employees face reasonably anticipated blood exposure?
Close the salon for 24 hours after any blood spill
Sterilize every implement in an autoclave after each client and keep spore-test records
Offer the hepatitis B vaccine at no cost and provide post-exposure follow-up
Test each client for HIV before services
Sections you finish are checked off in the contents.