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Bloodborne Pathogen Safety Plan

Treating Injured Workers Safely

Even with a well-executed safety program, any task involving physical labor can cause injury. Work-related injuries ranging from minor cuts to full blown emergencies share a common element. At some point coworkers trying to help will be exposed to blood.

OSHA’s focus is on preventing exposure because pathogenic microorganisms can be present in human blood. They transmit diseases such as hepatitis, strep and tuberculosis between humans through unprotected contact with blood and other body fluids.

Knowing The Rules About Protection

A contractor’s legal responsibility to protect workers from bloodborne pathogens is not as clear-cut as other safety regulations. There is no direct standard on protection from bloodborne pathogens in 29 CFR Part 1926. But the lack of a direct regulation does not exempt contractors from protecting workers from sources of infectious diseases.

OSHA inspectors commonly reference a contractor’s responsibility to protect their workers from bloodborne pathogens by citing Section 29 CFR 1926.21(b)(2). This regulation of the construction safety code requires contractors to instruct each employee to recognize and avoid unsafe conditions that can potentially happen on the jobsite, and provide controls or eliminate any hazards or other exposure to illness or injury.

To comply with Section 29 CFR 1926.21(b)(2), contractors must follow the regulations outlined in OSHA’s Bloodborne Pathogens Standard (29 CFR 1910.1030) developed for the health industry.  This specific regulation requires employers to perform an Exposure Determination concerning which employees may incur occupational exposure to blood or other potentially infectious materials.

Section 29 CFR 1926.21(b)(2) also requires contractors to provide appropriate personal protective equipment when there is exposure to bloodborne pathogens. This includes the need to use gloves and resuscitation equipment designed to prevent contact with blood or other potentially infectious materials. Contractors are required by OSHA to train their workers to consider blood (and all other potentially contagious material) as infectious, even if the injured worker is considered healthy.

Preparing The Proper Protection Plan

Contractors are required to follow up with an exposure control plan (ECP) to comply with the OSHA requirement. The ECP outlines protective measures the contractor and employer will take to eliminate or minimize employee exposure to blood.

At a minimum, ECP’s must contain:

  • The Exposure Determination which identifies job classifications, tasks and procedures where there is occupational exposure to bloodborne pathogens. For most contractors, this exposure is very limited to the immediate aid from a coworker in response to an injury before emergency health care professionals arrive.
  • Procedures for evaluating the circumstances surrounding potential exposure incidents. Most contractors comply with this requirement by alerting workers on proper procedures if they are working in at-risk environments (such as a water treatment facility or healthcare offices). In these areas employees should not eat, drink, smoke or handle contact lenses.
  • The schedule of how additional provisions of the standard are implemented. The plan should include methods of post-exposure evaluation and follow-up, communication of hazards to employees and record-keeping. One aspect of this schedule could be the listing of qualified clean-up contractors to disinfect contaminated work surfaces after an accident. Most contractors comply with this requirement by providing the proper safety supplies to protect their workers and by keeping accessible safety-response records.

Kitting Up For Blood Safety

Contractors should complement their safety supplies with a special Bloodborne Pathogen safety kit.

A typical kit includes special items like absorbent powder, alcohol gel, mask, eye shield, antiseptic BZK towelettes and gloves. These compact kits are generally mounted next to the jobsite’s main safety cabinet.

Other important safety items for blood clean up on remote jobsites are antiseptic cleaners that workers can use for washing up, along with clean paper towels and antiseptic towelettes for minor spills.

If the workforce includes workers trained in CPR, be sure to provide a one-way resuscitation mask to protect the injured and aid the provider. These kits Include a CPR Micromask, eye shields, nitrile gloves, antiseptic wipes, towels, razors, scissors and a Bio-Hazard Bag.

Three Steps Workers Should Follow After Exposure To Blood

  • Remove immediately (or as soon as feasible) any garments contaminated by blood, avoiding contact with outer surfaces.
  • Wash hands immediately (or as soon as feasible) after removing gloves or other PPE.
  • Dispose of contaminated PPE in appropriate containers.

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