3.6 Blood, Body Fluids and Client Contact Procedures (§ 160.19)

Blood, Body Fluids and Client Contact Procedures

Exam Focus: Expect at least one item on the first action after a cut and one on disposal containers. The order is fixed: stop, glove, control the bleeding, clean and cover, then decontaminate the implement and the station. Know that plastic bags and a rigid sharps container must be at the station before services begin.

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1. The Universal Precautions Rule

19 NYCRR § 160.19 opens with the governing principle:

All blood encountered in the workplace shall be treated as if it is infectious. Direct contact with blood should be avoided and disposable gloves used whenever such contact can be reasonably anticipated.

This is universal precautions: the licensee's behaviour does not depend on what the client discloses or on how the client looks. Many carriers of hepatitis B, hepatitis C and HIV are asymptomatic and unaware.

2. Step-by-Step Blood Exposure Incident Protocol

If a client or practitioner experiences an accidental cut, puncture, or abrasion involving blood during a service, the cosmetologist must execute the following 10-step blood exposure protocol in exact chronological order:

┌─────────────────────────────────────────────────────────────┐
│           10-STEP BLOOD EXPOSURE INCIDENT PROTOCOL          │
└─────────────────────────────────────────────────────────────┘
                               │
  1. STOP SERVICE IMMEDIATELY (Inform client calmly)
                               │
  2. PUT ON PROTECTIVE GLOVES (Nitrile or vinyl)
                               │
  3. APPLY GENTLE PRESSURE (Sterile gauze / cotton pad)
                               │
  4. CLEANSE INJURY WITH ANTISEPTIC (Wipe / liquid)
                               │
  5. APPLY STERILE ADHESIVE BANDAGE (Completely seal wound)
                               │
  6. CLEAN & DISINFECT WORKSTATION (EPA hospital disinfectant)
                               │
  7. DOUBLE-BAG CONTAMINATED ITEMS (Biohazard label / red bag)
                               │
  8. REMOVE GLOVES & WASH HANDS (Liquid soap, 20+ seconds)
                               │
  9. REPLACE TOOLS & RESUME SERVICE (Only with clean tools)
                               │
  10. DOCUMENT INCIDENT IN SALON LOG (Date, time, details)

Detailed Breakdown of Action Steps

1. Stop Service Immediately: Immediately halt the service. Calmly inform the client that you have experienced or caused a minor cut and must pause to follow safety protocol. Never panic or draw undue salon attention.
2. Don Protective Gloves: Put on a pair of single-use disposable protective gloves (nitrile or vinyl) to protect yourself and prevent cross-contamination.
3. Apply Direct Pressure: Apply gentle, continuous pressure to the wound using a clean, sterile gauze pad or cotton ball until bleeding subsides.
4. Cleanse with Antiseptic: Cleanse the injured area thoroughly with an antiseptic skin wipe, spray, or solution.
5. Bandage the Wound: Apply a sterile adhesive bandage (e.g., Band-Aid) to cover and protect the cut completely.
6. Clean & Disinfect Workstation: Spray and wipe down all contaminated surfaces and work areas using an EPA-registered hospital-grade disinfectant with proven efficacy against HIV and Hepatitis B. Ensure the surface remains wet for the manufacturer's full contact time.
7. Double-Bag Contaminated Waste: Place all single-use contaminated items (bloody gauze, cotton, disposable wipes) inside a sealable plastic bag. Place that bag inside a second sealable trash bag bearing a Biohazard warning label or inside a designated red biohazard waste container. Dispose of in accordance with local regulations.
8. Remove Gloves & Wash Hands: Remove gloves by peeling them inside out from the wrist, discard them into the biohazard waste bag, and thoroughly wash your hands with warm water and liquid antibacterial soap for at least 20 seconds. Dry hands with a clean disposable paper towel.
9. Replace Implements & Resume Service: Put on a fresh pair of gloves. Retrieve clean, freshly disinfected implements or unopened single-use supplies before resuming the client service.
10. Document Incident: Complete an entry in the salon's Incident / Injury Log Book recording the date, time, client name, practitioner name, nature of injury, and specific remedial actions taken.

3. The § 160.19 Disposal Requirements

New York specifies containers, not just intentions.

The practical examination reflects this rule directly: candidates are instructed to set out a container for blood contamination at the workstation during initial setup, alongside a plastic bag for disposables, before any procedure begins.

4. Decontaminating the Implement and the Station

After an exposure incident, the implement and the surrounding area are contaminated.

1. Do not reuse the implement. If it is disposable — a razor, an emery board, an orangewood stick — bag it and discard it.
2. If reusable, clean it with warm water and soap or detergent to remove all visible blood, rinse, dry, and then follow the § 160.17(c)(2) reprocessing route for skin-abrading implements: complete immersion in EPA hospital-grade disinfectant per manufacturer directions and no less than 10 minutes. Any implement that penetrated skin must be sterilised or discarded under § 160.17(c)(3).
3. Clean and disinfect the station, the chair, the trolley surface and anything else visibly contaminated, using an EPA hospital-grade disinfectant with a bloodborne pathogen claim, observing the label's contact time.
4. Remove gloves last, turning them inside out as they come off so contamination stays inside, bag them, and wash hands with soap and water.
5. Record the incident in the salon's log with the date, what happened, and what was done. This supports both OSHA compliance and any later question about the service.

5. Emergency First Aid at the Chair

Emergency First Aid Protocols in the Salon

6. Two Rules Candidates Get Wrong

• The first action is not "apply pressure". It is to stop the service and put on gloves. Bare-handed pressure on a bleeding cut is the exposure the whole rule exists to prevent.
• The waste stream is separated. Blood-contaminated disposables go into a sealed plastic bag; blood-contaminated sharps go into a rigid puncture-proof container. A single bin does not satisfy § 160.19, and used towels and linens go into their own covered receptacle under § 160.24.