2.5 Exposure Incidents: Standard Precautions, OSHA & MIOSHA, CDC & Michigan's Blood-Spill Rule
Key Takeaways
Standard Precautions treat all blood and body fluids as potentially infectious, regardless of a client's health history.
CDC reports that hepatitis B virus can survive on environmental surfaces for at least 7 days; a vaccine prevents HBV, but none exists for hepatitis C.
Michigan's blood-spill rule requires sterilizing any tool that contacted blood and discarding porous items such as buffers and pumice stones (R 338.2179e).
Michigan lets you use sodium hypochlorite or a hospital-grade disinfectant on floors and surfaces soiled with blood.
Michigan prohibits resuming a service until bleeding has stopped and the wound is covered, and bans styptic pencils and lump alum.
The pathogens you are protecting against
Nail services involve sharp tools, abrasives and broken skin around the nail folds. The bloodborne viruses in the textbooks are these:
| Virus | Key fact for the test |
|---|---|
| Hepatitis B virus (HBV) | Very hardy. CDC states HBV can survive on environmental surfaces for at least 7 days and still infect. A vaccine is available. |
| Hepatitis C virus (HCV) | Spread mainly by blood-to-blood contact. There is no vaccine. |
| Human immunodeficiency virus (HIV) | Fragile outside the body and killed by EPA-registered disinfectants with HIV claims. It is still handled under the same precautions. |
Standard Precautions (CDC) treat blood, body fluids, non-intact skin and mucous membranes as potentially infectious for every client. OSHA's older term Universal Precautions carries the same idea for blood. You never decide based on how healthy a client looks or what the intake form says.
What the law requires of employers
OSHA's Bloodborne Pathogens Standard, 29 CFR 1910.1030, applies to employers whose employees have reasonably anticipated exposure to blood or other potentially infectious materials. Michigan runs its own OSHA-approved state plan, MIOSHA. Its Part 554, Bloodborne Infectious Diseases (R 325.70001 and following), applies to Michigan employers with employees who have occupational exposure. Core employer duties under the federal standard:
- a written exposure control plan
- hepatitis B vaccination offered at no cost within 10 working days of initial assignment
- gloves and other personal protective equipment
- labeling of regulated waste
- training at hire and at least annually
A booth renter or sole owner without employees may fall outside the employer rules. The PSI test still expects you to follow the precautions.
The exposure incident procedure (textbook sequence)
If you cut a client, or blood appears for any reason:
- Stop the service and stay calm. Tell the client what happened.
- Put on gloves before touching the wound, supplies or contaminated items.
- Clean the injured area and give the client what they need to apply pressure with clean gauze or cotton.
- Apply an antiseptic. If needed, use liquid or powder styptic on a single-use applicator, never a pencil. Cover with an adhesive bandage.
- Clean and disinfect the workstation with an EPA-registered disinfectant that has the claims needed for blood, such as HBV and HIV, or tuberculocidal.
- Discard contaminated single-use items in a sealed bag. Textbooks teach double-bagging and a biohazard label or sticker before the bag goes into a covered waste container.
- Clean and then disinfect or sterilize the multi-use tools that touched blood. Michigan requires sterilizing them, as explained below.
- Remove gloves, turning them inside out, and wash your hands.
- Record the incident. Recommend medical follow-up if the wound is deep or shows signs of infection later.
If you are the one cut, stop and wash the wound. Apply antiseptic and a bandage, then cover the bandage with a glove or finger cover. Disinfect anything your blood touched, and report the incident to the employer. Michigan forbids performing services with an uncovered open sore, cut, burn or other wound.
Michigan's blood-spill rule: R 338.2179e
| Step | Michigan requirement |
|---|---|
| Service | Temporarily suspend it |
| Bleeding person | Give them adequate first aid supplies so they can stop the bleeding and cover the wound |
| Tools that contacted blood | Sterilize any equipment, tool or implement that contacted blood |
| Porous items | Immediately throw away porous materials involved: abrasive boards, blocks and buffers, orangewood sticks and pumice stones |
| Floors and durable surfaces | Immediately clean with sodium hypochlorite (such as household bleach) or another approved hospital-grade disinfectant |
| Waste | Put blood-spill waste in clearly labeled containers or bags |
| Resuming | Do not perform services until all bleeding has stopped and the wound is covered |
| Your own wounds | Keep any open sore, cut, burn or wound covered while working |
The Michigan rule is stricter than the textbook's "disinfect or sterilize." Disinfection alone does not meet the rule for a tool that contacted blood. Related Michigan prohibitions in R 338.2179g: no lump alum or styptic pencil, and no blades.
Other body fluids and contamination events
The PSI practical names blood, vomit and feces as body fluids you must handle without contaminating yourself or others. Use the same pattern:
- Stop and glove.
- Contain the fluid with disposable absorbent material.
- Bag the waste.
- Clean, then disinfect the surface for the label contact time.
- Throw away porous items that the fluid touched.
- Wash your hands, and re-set the station before continuing.
Common traps
- Putting styptic directly from the bottle onto a wound contaminates the bottle. Dispense it onto a single-use applicator.
- Spraying disinfectant on a client's skin is wrong. Disinfectants are for surfaces and tools. Antiseptics are for skin.
- Continuing to file "because it's only a little blood" violates both the textbook procedure and Michigan's rule.
- Disinfecting a nipper that cut skin, then using it on the next client, fails Michigan's sterilization requirement.
During a Michigan pedicure, a metal nipper nicks the client's skin and draws blood. Under R 338.2179e, how must the nipper be processed before reuse?
Wiped with an alcohol pad and air-dried
Disinfected with an EPA-registered disinfectant for 10 minutes
Sterilized, by liquid sterilant or autoclave
Rinsed and stored in a UV cabinet
Which method of stopping minor bleeding violates Michigan's rules?
Gentle pressure with clean gauze
Liquid styptic applied with a single-use cotton swab
Covering the wound with a bandage once bleeding stops
A styptic pencil touched directly to the cut
Why do Standard Precautions require gloves and the full exposure procedure for every client, even one whose health form lists no illnesses?
Because a signed health form serves as the salon's legal waiver of liability
Because infection is often unknown or undisclosed, so all blood is treated alike
Because HIV survives on dry surfaces much longer than hepatitis B does
Because wearing gloves replaces the need for hand washing between clients
Sections you finish are checked off in the contents.