I'm putting together a bloodborne pathogens written safety plan and I'm a little confused about the definition of "exposure".  I don't believe the people in our office need to be considered job classifications that include "some" risk of exposure since it is unlikely that they will be exposed.  However we are in the construction industry (industrial insulation) so the people in the field are at a higher risk of being cut and exposed to blood, etc.  Would the people in the field be considered people who have "some" risk of exposure?  Does anyone have some input on this?

Thanks!

Jennifer

Jennifer,

 

I thought the same thing about our office personal and I did have one incident that changed my mind about exposure.

 

I noticed my office assistant helping someone that cut their hand and she was not wearing any protection. I did stop her and assisted in getting proper PPE to protect myself  and then proceeded cleaning up and putting on the right dressing for the injury person.

 

When all done I asked her if she had CPR / First Aid training and she replied “no”. I asked her about the risk she took and she replied “no but it was only putting on a band aid”. This is when I did a basic training for office, a scaled down training that the employees out in the field receive.

 

I think everyone should have a basic understing of Bloodborne Pathogens to protect themself.    

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Will
HR,SAFETY,ENVIRONMENTAL SUPERVISOR
Lake Union Drydock Co.

I agree with Will on this issue.  Our business is not required to have a full blown BBP plan since we are not in the health care business and do not have occupational exposure.  However, we deal with lots of glass plates and razor blades to clean epoxy off of the glass and so the chance of someone bleeding significantly does exist.  And even though thte office folks may not be using the razors or glass plates, they might find another employee that has been cut and needs help.  So, my training offers everyone an overview of the hazards of BBP.

I recently took the OSHA 10-hour general industry safety course administered by a federal OSHA compliance assistance specialist. The bloodborne pathogens requirements for a nonhealthcare-related facility came up. The specialist said every facility should have at least one employee trained in first aid, and more for places (workshops, warehouses, etc.) where people are likely to get cuts and bruises. If an employee has first-aid training, he/she is often the designated person to administer first aid. Therefore, first-aid provider(s) are considered to have "occupational exposure" to bloodborne pathogens, and the facility must have an Exposure Plan. Such a plan doesn't have to have all the stuff about needlestick and sharps logs, but it should include guidance for first-aid providers and how the organization will respond if someone is exposed to blood.

Anyone in the field who has first-aid training would be considered to have some risk of exposure. Ask your workers if they are first-aid certified. If they are, whether or not you had them certified, they should be on your list of people in your Exposure Plan who are technically at risk of exposure. This isn't a rule, just a good guideline for documenting that you were diligent if there is an accidental exposure and OSHA inspects.

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vc

Although I believe there are a few jobs at our facility which may never be faced with a BBP situation, I have deemed everyone at our workplace susceptible to exposure. After all you never know when an accident may occur and someone be exposed to blood or other potentially infectious material. An employee may recieve a gash or severe cut right next to another worker causing un-foreseen blood splatter & exposure. I would err on the side of caution and go a step beyond whatever you think is the worst case scenario in all situations.

Hope this helps.

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Tim Croley,
Safety Coordinator
CMCA

There is no OSHA reg on bloodborne pathogens for the construction industry (CFR section 1926), but OSHA could use the general duty clause to issue citations for not providing protection against bloodborne pathogens at a construction site where there is a high risk of exposure to blood. According to OSHA's enforcement manual CPL 02-02-069,  the general duty clause can't be used in construction to cite against the bloodborne pathogens rule, but may be used to "cite for failure to provide a workplace free from exposure to bloodborne pathogens." It would be wise to have an Exposure Control Plan.

I recently attended a 10-hour safety and health training course run by an OSHA Compliance Assistance Specialist. On the definition of "occupational exposure" she said there isn't a clear regulatory definition but if you have workers who are trained to administer first aid at a workplace and you have designated them to administer first aid, then those people are considered to have occupational exposure. It makes sense that you would have one or more workers trained/certified in first aid if you have a high risk for cuts and abrasions. Since construction sites are covered by the general duty clause, to furnish employees with a workplace “free from recognized hazards that are causing or are likely to cause death or serious physical harm.…” then it would be wise to have an Exposure Control Plan for the first-aid providers.

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vc

One very important aspect i didn't see in any of those posts in regard to this topic is:

OSHA regulation 1910.151(b) states, "In the absence of an infirmary, clinic, or hospital in near proximity  (see * below) to the workplace which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render First Aid.  Adequate First Aid supplies should be readily available."

 

Although it is not an OSHA requirement that employers provide Cardiopulmonary Resuscitation (CPR) Training, OSHA's "Guidelines for First Aid Training Programs" recommends that CPR Training be a general program element of a First Aid Program.

 

* Near Proximity - OSHA's regulation does not set specific response time requirements for the term "Near Proximity".  However, in areas where accidents resulting in suffocation, severe bleeding, or other life-threatening or permanently disabling injury or illness are likely, a 3 to 4 minute response time, from time of injury to time of administering First Aid, is required.  The rationale for requiring a 4 minute response time is Brain Death when the Heart or Breathing has stopped for that period of time.

 

 

 OSHA recommends, but does not require, that every workplace include one or more employees who are trained and certified in first aid, including CPR.

The other option for employers is to rely upon the reasonable proximity of an infirmary, clinic or hospital. OSHA has consistently taken the view that the reasonable availability of a trained emergency service provider, such as fire department paramedics or EMS responders, would be equivalent to the "infirmary, clinic, or hospital" specified by the literal wording of the standards. Emergency medical services can be provided either on-site or by evacuating the employee to an off-site facility in cases where that can be done safely.

However, the requirements that emergency medical services must be "reasonably accessible" or "in near proximity to the workplace" are stated only in general terms. An employer who contemplates relying on assistance from outside emergency responders as an alternative to providing a first-aid-trained employee must take a number of factors into account. The employer must take appropriate steps prior to any accident (such as making arrangements with the service provider) to ascertain that emergency medical assistance will be promptly available when an injury occurs. While the standards do not prescribe a number of minutes, OSHA has long interpreted the term "near proximity" to mean that emergency care must be available within no more than 3-4 minutes from the workplace, an interpretation that has been upheld by the Occupational Safety and Health Review Commission and by federal courts.

Medical literature establishes that, for serious injuries such as those involving stopped breathing, cardiac arrest, or uncontrolled bleeding, first aid treatment must be provided within the first few minutes to avoid permanent medical impairment or death. Accordingly, in workplaces where serious accidents such as those involving falls, suffocation, electrocution, or amputation are possible, emergency medical services must be available within 3-4 minutes, if there is no employee on the site who is trained to render first aid. OSHA exercises discretion in enforcing the first aid requirements in particular cases. OSHA recognizes that a somewhat longer response time of up to 15 minutes may be reasonable in workplaces, such as offices, where the possibility of such serious work-related injuries is more remote.

The first aid training standards at 29 CFR 1910.151 and 1926.50(c) generally apply throughout the industries that they cover. Other standards which apply to certain specific hazards or industries make employee first aid training mandatory, and reliance on outside emergency responders is not an allowable alternative. For example, see 29 CFR 1910. 266(i)(7) (mandatory first aid training for logging employees), and 29 CFR 1910.269(b) (requiring persons trained in first aid at work locations in the electric power industry).

The bloodborne pathogens standard at 29 CFR 1910.1030(g)(2) requires employers to provide training to any employees who have occupational exposure to blood or other potentially infectious materials, such as employees assigned medical or first aid duties by their employers. The standard at 29 CFR 1910.1030(b) defines "occupational exposure" as "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." If an employee is trained in first aid and identified by the employer as responsible for rendering medical assistance as part of his/her job duties, that employee is covered by the bloodborne pathogens standard.

 

 

(correction)

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"SAFETY FIRST, SAFETY ALWAYS"

As a point of clarification, OSHA does require training for first aid and CPR for permit required confined spaces in 1910.146.

(k)(2)(iii) Train affected employees in basic first-aid and cardiopulmonary resuscitation (CPR). The employer shall ensure that at least one member of the rescue team or service holding a current certification in first aid and CPR is available;

We have one or two people per shift who are trained annually for first aid and CPR. 

Leslie

Leslie,

you are 100% correct, OSHA does require training for first aid and CPR for permit required confined spaces in 1910.146.  Along with logging employees and the electric power industry only I believe. But other than those industries, OSHA only  recommendesfirst aid/cpr it is  NOT mandatory.  My customers are not in any of those industries, but i suggest to them all, to have a certified first aid / CPR person or persons on all shifts.

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"SAFETY FIRST, SAFETY ALWAYS"

Hey Jennifer,  There is one area that most companies have that was not mentioned.  The facilities maintenance team...  They may be required to work on toilets, clean up etc...  If this is the case, then everyone should be trainied in the general awareness of BBP and how to respond to your company policy.  For example:  If an employee discovers body fluids they shall control access to the area and request maintenance to come and clean it up etc...  Maintenance shall be trained to the full standard and understand the correct procedures for clean-up!  I hope this helps, Dana 

One very important aspect i didn't see in any of those posts in regard to this topic is:

OSHA regulation 1910.151(b) states, "In the absence of an infirmary, clinic, or hospital in near proximity  (see * below) to the workplace which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render First Aid.  Adequate First Aid supplies should be readily available."

 

Although it is not an OSHA requirement that employers provide Cardiopulmonary Resuscitation (CPR) Training, OSHA's "Guidelines for First Aid Training Programs" recommends that CPR Training be a general program element of a First Aid Program.

 

* Near Proximity - OSHA's regulation does not set specific response time requirements for the term "Near Proximity".  However, in areas where accidents resulting in suffocation, severe bleeding, or other life-threatening or permanently disabling injury or illness are likely, a 3 to 4 minute response time, from time of injury to time of administering First Aid, is required.  The rationale for requiring a 4 minute response time is Brain Death when the Heart or Breathing has stopped for that period of time.

 

 

 OSHA recommends, but does not require, that every workplace include one or more employees who are trained and certified in first aid, including CPR.

The other option for employers is to rely upon the reasonable proximity of an infirmary, clinic or hospital. OSHA has consistently taken the view that the reasonable availability of a trained emergency service provider, such as fire department paramedics or EMS responders, would be equivalent to the "infirmary, clinic, or hospital" specified by the literal wording of the standards. Emergency medical services can be provided either on-site or by evacuating the employee to an off-site facility in cases where that can be done safely.

However, the requirements that emergency medical services must be "reasonably accessible" or "in near proximity to the workplace" are stated only in general terms. An employer who contemplates relying on assistance from outside emergency responders as an alternative to providing a first-aid-trained employee must take a number of factors into account. The employer must take appropriate steps prior to any accident (such as making arrangements with the service provider) to ascertain that emergency medical assistance will be promptly available when an injury occurs. While the standards do not prescribe a number of minutes, OSHA has long interpreted the term "near proximity" to mean that emergency care must be available within no more than 3-4 minutes from the workplace, an interpretation that has been upheld by the Occupational Safety and Health Review Commission and by federal courts.

Medical literature establishes that, for serious injuries such as those involving stopped breathing, cardiac arrest, or uncontrolled bleeding, first aid treatment must be provided within the first few minutes to avoid permanent medical impairment or death. Accordingly, in workplaces where serious accidents such as those involving falls, suffocation, electrocution, or amputation are possible, emergency medical services must be available within 3-4 minutes, if there is no employee on the site who is trained to render first aid. OSHA exercises discretion in enforcing the first aid requirements in particular cases. OSHA recognizes that a somewhat longer response time of up to 15 minutes may be reasonable in workplaces, such as offices, where the possibility of such serious work-related injuries is more remote.

The first aid training standards at 29 CFR 1910.151 and 1926.50(c) generally apply throughout the industries that they cover. Other standards which apply to certain specific hazards or industries make employee first aid training mandatory, and reliance on outside emergency responders is not an allowable alternative. For example, see 29 CFR 1910. 266(i)(7) (mandatory first aid training for logging employees), and 29 CFR 1910.269(b) (requiring persons trained in first aid at work locations in the electric power industry).

The bloodborne pathogens standard at 29 CFR 1910.1030(g)(2) requires employers to provide training to any employees who have occupational exposure to blood or other potentially infectious materials, such as employees assigned medical or first aid duties by their employers. The standard at 29 CFR 1910.1030(b) defines "occupational exposure" as "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." If an employee is trained in first aid and identified by the employer as responsible for rendering medical assistance as part of his/her job duties, that employee is covered by the bloodborne pathogens standard.

 

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"Safety First, Safety Always"

Jennifer,

 as per the question since you are a construction company you should have a full blown BPP. Now since the office workers do work in the office it is smart to have all persons aware of the BPP program and atleast two persons in the office trained in standard first aid to deal with events that come up in the offices such as paper cuts and the proper way to deal with blood. you mentioned that one of your employees assisted another by placing a band aid over the wound without the proper PPE. at this point the office worker has been exposed to blood she or he could come back and state that they did not have the proper training to deal with such an event and it could be citable.train everyone to your safety manual so all have the same knowledge this way it minimizes your risk.

 

dave

Jennifer,

Bloodborne Pathogens and Exposure Control [29 CFR 1910.1030]

 

Employers are subject to the requirements of 29 CFR 1910.1030 if their employees are exposed to bloodborne pathogens in the workplace. The regulations define occupational exposure as a reasonably anticipated skin, eye, mucous membrane, or parenteral (piercing of the skin or mucous membrane) contact with blood or other potentially infectious material while on the job. OSHA requires employers of occupationally exposed employees to develop a written exposure control plan, detailing how exposures to bloodborne pathogens will be eliminated or minimized.

 

Your exposure control plan must include:

• A list of jobs in which some or all employees are exposed to bloodborne pathogens
• Methods for regulatory compliance, including universal precautions, engineering and work practice controls, personal protective equipment, and housekeeping
• Hepatitis B vaccinations and post-exposure evaluations and follow-up (vaccination must be made available to all employees who have occupational exposure)
• Hazard communication to employees
• Training (annual training is required for all exposed employees per 29 CFR 1910.1030(g)(2))
• Recordkeeping (see 29 CFR 1910.1030(h))

 

Additionally, 1910.1030(e) includes specific requirements employers must comply with for HIV and HBV research laboratories and production facilities.

 

Exposure control plans must be updated at least annually and as needed to reflect changes in any occupational job exposure, as well as the availability of new exposure control technology.

Hope this helps.

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Will
HR,SAFETY,ENVIRONMENTAL SUPERVISOR
Lake Union Drydock Co.