Administration and Leadership, Columns, Patient Care

Pro Bono: Complying with OSHA’s Bloodborne Pathogen Standard

Issue 4 and Volume 40.

Exposure to bloodborne pathogens is a constant risk for EMS providers. Having proper policies and procedures in place is a legal imperative. For EMS agencies, the United States Occupational Safety and Health Administration (OSHA) bloodborne pathogens standard (29 C.F.R. § 1910.1030) applies to all personnel who may reasonably anticipate contact with blood or other potentially infectious materials in the course of providing services. Other potentially infectious materials can include contact with skin, eyes, mucous membranes or from piercing the skin.

To comply with OSHA’s bloodborne pathogens standard and other requirements, all EMS agencies must have an exposure control plan, which should contain an infectious disease prevention plan. They should also have a safety and infection control plan, an immunization/hepatitis B vaccination plan, a hazard communication program and a policy for post-exposure evaluation and follow-up.

As part of the exposure control plan, EMS agencies must appoint a health and safety officer (HSO) who’s in charge of ensuring compliance with OSHA policies. The HSO should work with management and company staff to develop and administer any additional company policies and practices that might be effective in implementing the exposure control plan and other OSHA policies, should act as the company liaison during OSHA inspections, should ensure that all staff are properly trained on the bloodborne pathogens standard and other OSHA requirements, and should conduct periodic audits to ensure the company is in compliance with respect to bloodborne pathogens and other OSHA requirements. The HSO should review and update the exposure control plan annually.

EMS agencies are required to hold annual training on the company’s exposure control plan and all other OSHA policies for staff that may reasonably anticipate contact with blood or other potentially infectious materials. Once personnel receive training, hepatitis B vaccinations should be made available.

EMS agencies should take universal precautions in dealing with bloodborne pathogens. All blood and body fluids should be treated as if they’re known to be infectious for hepatitis B, HIV and other bloodborne pathogens. In circumstances where it’s difficult or impossible to differentiate between body fluid types, it’s safest to assume that all body fluids are infectious.

EMS agencies should implement engineering controls to eliminate or minimize the risk of personnel exposure to bloodborne and airborne pathogens. Engineering controls reduce employee exposure by either removing or isolating the hazard or isolating the staff member from exposure. Examples are: handwashing facilities, containers for contaminated reusable sharps, specimen containers and secondary containers. If a staff member suffers an exposure, the agency must ensure that the staff member receives appropriate post-exposure evaluation and follow-up.

EMS agencies should implement work practice controls. Work practice controls help eliminate or minimize employee exposure to bloodborne and airborne pathogens. Work practice controls include policies such as specifying when personnel are to wash their hands, when appropriate waste disposal practices are implemented, and what’s to be done with contaminated backboards and contaminated needles.

EMS agencies should have procedures in place to ensure all company personnel who may reasonably anticipate contact with blood or other potentially infectious materials are provided with appropriate personal protective equipment (PPE) and that this PPE is cleaned or replaced, as appropriate, upon use.

EMS agencies should have procedures to ensure all company property is kept in clean and sanitary conditions. This means there should be policies dealing with: the cleaning and disinfection of equipment, laundry, surfaces and containers; disposal of regulated waste materials; and location of waste and contaminated laundry containers.

EMS agencies should also ensure either fluorescent orange or red-orange warning labels are attached to regulated waste or that red bags or red containers are used for disposal of regulated waste.

Finally, EMS agencies must maintain medical and training records for all personnel who may reasonably anticipate contact with blood or other potentially infectious materials, as well as a sharps injury log.

Ensuring that proper policies, procedures and training are in place is a legal imperative for EMS agencies to ensure the health and safety of their caregivers.