OSHA’s bloodborne pathogens standards: A school’s responsibility for compliance 

When you have large numbers of children in a school setting the potential exists for cuts, and scrapes and illnesses that expose employees to bodily fluids that can possibly cause illness. 

What are bloodborne pathogens and why did OSHA create a formal standard to deal with the hazards? Bloodborne pathogens are microorganisms such as viruses or bacteria that are carried in blood and can cause disease in people. Among the bloodborne pathogens are malaria, syphilis, and Brucellosis, but Hepatitis B (HBV) and the Human Immunodeficiency Virus (HIV) are the two diseases specifically addressed by the OSHA (Occupational Safety and Health Administration) Bloodborne Pathogen Standard. In response to the growing concern over HIV/AIDS in 1991 OSHA created the bloodborne pathogens standard. The standard, if adhered to correctly, provides for reasonable protection against illnesses including Hepatitis B & C, AIDS and other bloodborne illnesses. 

What is OSHA’s bloodborne pathogen standard?
OSHA's bloodborne pathogens standard 29 CFR Part 1910.1030, addresses the blood hazards in the workplace. This standard covers all employees who it can "reasonably be anticipated" to have contact with blood and other potentially infectious materials. Schoolteachers, administrators, athletic coaches, cafeteria workers and janitorial staff fall under this category and are therefore covered under the Bloodborne pathogens standard. 

Bloodborne pathogen standard mandated requirements for schools:
  • The standard requires employers to implement an exposure control plan detailing employee protection measures. The plan must identify or document, in writing: Tasks and procedures as well as job classifications where workers who could be “reasonably anticipated” to have occupational exposure to blood occurs regardless of whether or not they have protective gear available 
    • Tasks, procedures and job titles where occupational exposure to blood occurs 
    • The schedule for implementing other parts of the standard and the procedure for evaluating circumstances surrounding exposure incidents 
    • Post-exposure follow-up for employees who have reported an exposure incident, including providing immediate medical follow-up, testing employee’s blood, and counseling 
    • An annual review and update that reflect changes in technology that eliminate or reduce worker exposure AND employer consideration and implementation of appropriate, commercially available and effective engineering controls 
    • Non-managerial employee input regarding the identification, evaluation, and selection of effective engineering controls, including safer medical devices 
    • The plan must be accessible to employees and their unions and available to OSHA. 
  • The bloodborne pathogens standard further requires annual training, provided during work hours. Training must include access of the regulatory text, explanation of its contents, general discussion of bloodborne diseases, exposure control plan, engineering and work practice controls, personal protective equipment, Hepatitis B vaccine, response to emergencies involving blood, handling exposure incidents, post-exposure evaluation, and signage. A trainer knowledgeable in the subject matter must provide a question and answer opportunity. 
  • The standard also requires Implementation of engineering and work practice controls where possible. 

Controls include: 

Universal precautions:

“Universal precautions” is short-hand for an approach to infection control that requires people to treat all human blood and certain human body fluids as if they were infected with HIV, HBV and other bloodborne pathogens, The Standard says employees must follow universal precautions to prevent contact with blood or other potentially infectious materials. 

Some common and effective universal precautions are:
      • Use of personal protective equipment (PPE): gloves, masks and protective eyewear. The employer must provide PPE at no cost to employees. 
      • Placement of barriers such as tissues or a towel between a caregiver and a bleeding person or ask them, if they’re able, to do it themselves, i.e. wipe own nose or apply pressure to wounds. Hand washing with soap and water or use waterless sanitizing cleansers immediately following body fluid contact and glove removal 

Engineering controls:

Engineering controls include containers with hazard labels, antibacterial soaps or chemicals and places to wash after an exposure including an eye wash station. Schools are likely limited to soaps and disposal containers. 

Administrative controls:

Administrative controls include workplace rules such as procedures to clean up broken glass that may have blood or other body fluid on it. For higher hazard businesses administrative controls would include rules on working with needles etc. 

Rules to follow:

Always wear personal protective equipment (PPE) in exposure situations. 

      • Remove PPE that is torn or punctured 
      • Replace PPE that is torn or punctured
      • Remove PPE before leaving the work area 

Hands should be washed immediately (or as soon as feasible) after removal of gloves or other PPE. Because hand washing is so important, you should note the location of the hand washing facilities (with soap) nearest to you. If you are working in an area without access to such facilities, you may use an antiseptic cleanser in conjunction with clean cloth/paper towels or antiseptic wipes. If these alternative methods are used, wash hands with soap and running water as soon as possible. 

If you are cleaning up blood that has spilled or splattered, you should carefully cover the spill with paper towels or rags, then gently pour the 10% solution of bleach over the towels or rags, and leave it for at least 10 minutes. This will help ensure that any bloodborne pathogens are killed before you actually begin cleaning or wiping the material up. By covering the spill with paper towels or rags, you decrease the chances of splashing when you pour the bleach on it. 

Broken glassware should never be picked up directly with the hands. Sweep or brush the material into a dustpan. Uncontaminated broken glassware may be disposed of in a closable, puncture resistant container such as a cardboard box or coffee can. 

If you are exposed, however, you should: 

      • Wash the exposed area thoroughly with soap and running water. Use non-abrasive, antibacterial soap if possible. 
      • If blood is splashed in the eye or mucous membrane, flush the affected area with running water for at least 15 minutes. 
      • Report the exposure to your supervisor as soon as possible for further action.
  • The standard places the responsibility for enforcing the use of personal protective equipment on the employer. In the case of schools protective equipment usually includes rubber gloves, tissues, hand sanitizers, eye protection and in some cases aprons or gowns. 
  • For businesses that are at a high risk for infection, such as nursing homes, employers are required to offer vaccines against Hepatitis B. All employers, including schools, are required to evaluate exposures to bloodborne pathogens and offer follow up testing when concerns regarding an exposure exist. 
  • If a business is aware of a bloodborne pathogen exposure signs and labels are required to be used to warn of potential hazards and exposures. In a school setting it is most likely that any exposures will be unanticipated and as a result of an accidental injury causing bleeding or due to an illness of some other nature.

The information provided in this article is intended for general informational purposes only and should not be considered as all encompassing, or suitable for all situations, conditions, and environments. Please contact us or your attorney if you have any questions.

For safety or risk management questions or suggestions, please contact Markel.

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