Despite the fact that the Bloodborne Pathogens (BBP) standard has been around for nearly two decades, it remains one of the most confusing and violated OSHA regulations. In fact, 29 CFR 1910.1030 is cited over 1,000 times every year, putting it on the list of “top-violated” regulations for federal OSHA. Part of the confusion may be attributed to the very terminology that has been used in the standard since the beginning.
Think of it this way â€” just eight terms may be driving noncompliance or causing some to stretch needlessly beyond compliance, in a lot of cases. Those terms include blood, bloodborne pathogen, other potentially infectious materials, exposure incident, occupational exposure, contaminated, sharp, and regulated waste. By taking the time to fully understand these terms and OSHA’s intent, you may save time and money in your compliance efforts.
BloodAccording to OSHA, “blood” means human blood, human blood components like plasma or platelets and products made from human blood, including medications. The important thing to remember in this definition is the word “human.” Animal or insect blood is not blood by definition under the standard.
Bloodborne pathogenWhile §1910.1030 specifically identifies Hepatitis B virus (HBV) and human immunodeficiency virus (HIV) as “bloodborne pathogens,” the term actually includes any pathogenic microorganism present in blood that can cause disease in humans exposed to it. Hepatitis C virus, for example, is a common viral infection of the liver transmitted primarily by exposure to blood. Other bloodborne pathogens include, but are not limited to, malaria, syphilis, Creutzfeldt-Jakob disease and other pathogens.
Other potentially infectious materialsYou can also find pathogens in certain other body fluids and tissues called “other potentially infectious materials” (OPIM). OSHA provides a list of substances that qualify as OPIM in the standard, but ordinary urine, vomit and saliva are not listed. That’s because scientists do not consider these substances to be efficient modes of HBV or HIV transmission. However, these substances are considered OPIM if they are visibly contaminated with blood or when saliva is present in dental procedures. That means if your employee is handling urine samples or cleaning up vomit, the BBP standard would only apply if those substances were visibly contaminated with blood.
“Exposure incident” means a specific exposure to the eye, mouth, other mucous membrane, non-intact skin or parenteral (potential) exposure to blood or OPIM that results from the performance of an employee’s duties. Examples of an exposure incident include blood spattering into the eyes or mouth, or a puncture by a blood-contaminated needle. In this definition, “non-intact skin” includes skin with dermatitis, hangnails, cuts, abrasions, chafing, etc.
Although a small amount of blood on “intact skin” would not be considered an exposure incident under this definition, such an event should be a matter of concern to you. It may be an indication of inadequate personal protective clothing and equipment. The circumstances surrounding such events should be investigated to determine whether they can be prevented in the future.
The phrase “results from the performance of an employee’s duties” in the definition is also important. Good Samaritans voluntarily render first aid or medical assistance and don’t do so as an employee duty. It would appear then that their exposure would not qualify as an exposure incident under the standard. Although not required, OSHA recommends that you make post-exposure evaluation and follow-up available even to Good Samaritans who suffer an actual exposure.
Occupational exposureThe term “occupational exposure” has long been confused with the term “exposure incident.” For the purpose of the BBP standard, it is necessary to use “occupational exposure” for “reasonably anticipated contact.” This type of contact requires you to implement the standard and its protective measures. “Exposure incident” is used only for an exposure event and requires medical follow-up.
OSHA explains that reasonably anticipated contact includes the potential for skin, eye, mucous membrane or parenteral contact, as well as actual contact with blood or OPIM. A lack of history of exposure incidents among first-aid personnel at a facility, for instance, does not preclude coverage.
In addition, occupational exposure entails only contact that may result from the performance of an employee’s duties. In other words, employees that you’ve designated or otherwise expect to perform duties that are reasonably anticipated to involve contact with blood or OPIM are covered. However, this definition does not cover Good Samaritan acts that result in exposure to blood or OPIM from voluntarily assisting a co-worker.
OSHA does not list the jobs or tasks with occupational exposure. Employers must make this determination. However, you may wish to look closely at jobs involving housekeeping, laundry, waste handling, plumbing, maintenance, first aid, healthcare, dentistry, lab work, law enforcement, corrections, firefighting, etc., to determine if employees in these jobs have occupational exposure.
ContaminatedThe standard defines the term “contaminated” as the presence or the reasonably anticipated presence of blood or OPIM on an item or surface. Understanding this term is helpful when determining whether laundry or sharps are contaminated. If these items are free of blood or OPIM, or if they are properly decontaminated, they are not covered by the standard.
SharpThe term “sharp” includes not only needlesticks but any object that can penetrate the skin. Box cutter blades, razor blades, knives, wire ends and broken glass qualify. However, the §1910.1030 provisions are concerned only with sharps that are contaminated. There are no special requirements under the BBP standard for sharps that are not contaminated.
Regulated wasteNot all contaminated waste must be labeled or red bagged. Only “regulated waste” has special containment and disposal requirements under the BBP standard. Regulated waste means:
- Liquid or semi-liquid blood or OPIM;
- Contaminated items that would release blood or OPIM in a liquid or semi-liquid state if compressed;
- Items that are caked with dried blood or OPIM and are capable of releasing these materials during handling;
- Contaminated sharps; and
- Pathological and microbiological wastes containing blood or OPIM.