June 1, 2015 – It happens more times than I care to admit. I’m teaching an OSHA 30 hour class or conducting a mock-OSHA inspection and we are covering the topic of OSHA’s Bloodborne Pathogens (BBP) standard. Someone participating in the audit or attending the class says “Everybody at our facility is covered by the OSHA Bloodborne Pathogens standard”. Or, conversely, someone will say “Not a single person at our facility is covered by this standard”. More times than not, neither statement is true.
Inclusion in an OSHA-compliant BBP program is based on one thing; an employee has “occupation exposure” to blood or some other potentially infectious material. The key is to understand the definition of the term “occupational exposure”. According to the OSHA Bloodborne Pathogens standard found at 1910.1030, “occupational exposure” means “reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee's duties.” The key to determining if an an employee has occupational exposure lies in the term “reasonably anticipated” exposure.
Some employers take it too far by thinking that every single worker at their facility has occupational exposure because “anyone could get cut and some unlucky bystander could get blood on them if they happen to be working nearby”. While this type of collateral exposure could certainly happen, that is not the type of “exposure” that falls within the scope of the OSHA BBP standard. What is covered are those tasks that an employee is expected to perform where it would be reasonable to think they will get blood or some other potentially infectious material (such as, but not limited to, semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva in dental procedures, any body fluid that is visibly contaminated with blood, and all body fluids in situations where it is difficult or impossible to differentiate between body fluids) on their skin, in their eyes, nose or mouth, on other mucous membranes, or get stuck with a needle or other contaminated sharp. So the fact that you happen to be standing next to Joe Six-pack when he cuts his finger in the shop and accidentally squirts some blood on you as he runs by screaming does not mean you have occupational exposure.
So, who does have occupational exposure? Based on the OSHA definition, a surgeon would most likely have occupational exposure, as would a designated first aid provider. But so would the person who transports an injured worker to the local clinic or emergency room when they are bleeding or throwing up their guts. And so would the janitor who has to go out and clean up the mess. And so would someone assigned to a confined space rescue team. And so would a hooker working in a brothel in Nevada. And so would a safety manager and/or supervisor assigned to perform a close-up inspection of a machine where the employee got through or around the guard while performing their accident investigation (if they do it right). In fact, the list of jobs and tasks that present occupational exposure can go on and on if you brain-storm the reasonable paths of exposure in your operations. And remember, it does not matter that you are wearing gloves when you perform the task, you still have occupational exposure!
Some of you might be saying to yourself “There goes Curtis again, telling employers NOT to go above and beyond the OSHA regulations to protect workers”. Nothing could be farther from the truth. The reasons I try and clarify who does, and does not, have occupational exposure are 1) those employers who think that only first-aid providers have occupational exposure are often times leaving other exposed workers unprotected; and, 2) those employers who grossly over-state the worker population with occupational exposure tend to underperform when it comes to implementing their BBP program.
By that, I mean that many of those employers who have designated a very large group (in some cases, hundreds of employees) as having occupational exposure tend to half-way implement the OSHA requirements for a BBP program. I have seen more than one employer who says “everyone” has occupational exposure, but their BBP program consists of only holding a training class telling all of their workers how BBP’s are transmitted and the importance of avoiding blood - yet they don’t cover all the mandatory information to the depth required by the OSHA BBP standard. And these same employers often do not provide workers the free HBV vaccination series required to be offered to covered employees within 10 days of assignment to a job with exposure because it would be cost prohibitive. But more concerning to me is these same employers who go overboard on designating workers as having occupational exposure often lump the workers who actually do have occupational exposure into their half-assed BBP program, and therefore leave them without the full benefit of the protections specified by OSHA standard.
Have you conducted an in-depth evaluation of your (or a client’s) operations and found an over-looked task where workers really do have occupational exposure to BBP’s? Or, perhaps you or an employer had gone overboard in the classification of workers with exposure? If you would like to comment on this topic (and I hope you do) or would like to read comments submitted by others, please click here and fill in the “Comments” box. And last but not least, I would like to encourage you to Share this Blog post with others in your Network who might enjoy reading this information.
ABOUT THE AUTHOR:Curtis Chambers is a Certified Safety Professional (CSP) and holds a Master of Science degree in Occupational Safety and Health. He has held numerous leadership positions managing and evaluating health and safety programs and providing training on workplace safety and health topics at various public organizations and private corporations. Mr. Chambers is currently the President of OSHA Training Services Inc. Visit their website at www.oshatraining.com.