9.1 Bloodborne Pathogens Exposure Control (29 CFR 1910.1030)

Bloodborne Pathogens Exposure Control (29 CFR 1910.1030)

Infectious Agents & Occupational Risks

Bloodborne pathogens are pathogenic microorganisms present in human blood that can cause disease in humans. Under the OSHA Bloodborne Pathogens standard (29 CFR 1910.1030), employers must protect workers who have occupational exposure. Occupational exposure is defined as reasonably anticipated skin, eye, mucous membrane, or parenteral contact (such as needlesticks, cuts, or abrasions) with blood or other potentially infectious materials (OPIM) resulting from an employee's duties.

Three bloodborne viruses represent the primary occupational hazards for workers:

• Hepatitis B Virus (HBV): A highly infectious virus causing liver inflammation. HBV is resilient and can survive in dried blood on surfaces for at least seven days. It is preventable via a three-dose vaccine.
• Hepatitis C Virus (HCV): The most common chronic bloodborne infection in the United States, causing chronic liver disease. There is currently no vaccine available for HCV.
• Human Immunodeficiency Virus (HIV): The virus that destroys CD4+ T-cells, compromising the immune system and leading to AIDS. While fragile outside the body, parenteral transmission is a critical risk.

OPIM includes semen, vaginal secretions, cerebrospinal, synovial, pleural, pericardial, peritoneal, and amniotic fluids, any body fluid contaminated with blood, and cases where body fluids are indistinguishable.

The Written Exposure Control Plan (ECP)

Employers must establish and maintain a written Exposure Control Plan (ECP) to eliminate or minimize exposures. The ECP must be accessible to employees and contain:

1. Exposure Determination: A list of all job classifications and tasks where occupational exposure occurs, made without regard to personal protective equipment (PPE).
2. Implementation Schedules: Details on how universal precautions, engineering controls, work practices, PPE, housekeeping, and vaccinations will be implemented.
3. Incident Evaluation Procedures: Protocols for investigating and documenting the circumstances of any exposure incident.

The ECP must be reviewed and updated at least annually (every 12 months) and whenever tasks or procedures change. The review must document the consideration of commercially available safer medical devices (e.g., sharps with engineered safety controls). Employers must solicit and document input from non-managerial, front-line employees who perform procedures involving sharps when selecting these controls.

Universal Precautions & Control Hierarchy

Universal Precautions is an infection control approach where all human blood and OPIM are treated as if known to be infectious.

• Engineering Controls: These isolate or remove the hazard from the workplace. Examples include puncture-resistant, leakproof, and labeled sharps disposal containers (replaced when 2/3 to 3/4 full), self-sheathing needles, and needleless systems.
• Work Practice Controls: These alter how tasks are performed. Employees are prohibited from recapping, bending, or removing contaminated needles unless they can prove no alternative exists, in which case a one-handed scoop technique or mechanical device is required. Handwashing must occur immediately after removing gloves or other PPE. Eating, drinking, smoking, applying cosmetics, or handling contact lenses is prohibited in areas with exposure risk. Food and drinks must never be stored in refrigerators or cabinets where blood or OPIM is present.
• Personal Protective Equipment (PPE): When occupational exposure remains after engineering and work practice controls are implemented, PPE must be used. The employer must provide, clean, and maintain appropriate PPE (such as gloves, gowns, face shields, and masks) at no cost.

Hepatitis B Vaccination Requirements

The Hepatitis B vaccine series must be offered at no cost to all employees with occupational exposure. It must be made available at a reasonable time and place, under the supervision of a licensed healthcare professional, within 10 working days of initial assignment.

Employees cannot be required to undergo pre-vaccination serologic screening. If an employee declines the vaccine, they must sign a mandatory, verbatim Hepatitis B Vaccine Declination Form found in Appendix A of the standard. If the employee initially declines but later decides to receive the vaccine while still covered, the employer must provide it at no cost.

Post-Exposure Evaluation and Follow-up

Following an exposure incident, the employer must immediately provide a confidential, no-cost medical evaluation and follow-up including:

1. Exposure Documentation: Documenting the route of exposure and circumstances of the incident.
2. Source Identification: Identifying and testing the source individual’s blood for HBV, HCV, and HIV, if consent is obtained. If consent is refused, the employer must document it.
3. Employee Blood Testing: Testing the employee’s blood for baseline status. If the employee declines HIV testing but consents to collection, the sample must be preserved for 90 days.
4. Prophylaxis: Administering post-exposure prophylaxis (PEP) according to U.S. Public Health Service recommendations.
5. Written Medical Opinion: Providing the employee with a copy of the healthcare provider's written opinion within 15 days of completion. The opinion is limited to whether HBV vaccination is indicated and received, and that the employee was informed of the results. Other findings remain confidential.

Biohazard Labeling and Communication

Warning labels must be affixed to containers of regulated waste, refrigerators/freezers containing blood or OPIM, and other shipping containers.

• Label Specifications: Labels must be fluorescent orange or orange-red, displaying the universal biohazard symbol and the word "BIOHAZARD" in a contrasting color.
• Red Bags/Containers: Red bags or containers can be used instead of labels.
• Exemptions: Regulated waste that has been decontaminated (e.g., through autoclaving) does not require labeling.