Exposures to blood-borne pathogens (BBP) in construction continue to happen and OSHA continues to site contractors for not training employees regarding BBP. According to the 29CFR 1910.1030 or OSHA’s Bloodborne Pathogens Standard, employers should develop an exposure control plan to eliminate or minimize occupational exposure to potentially infectious body fluids.
What is “occupational exposure” as defined by OSHA?
“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.”
You must provide training, even if you are a construction contractor with no staff members that could be exposed to BBP, such as company employed janitorial employees. Or even if you have no shop employees or office staff, think of how your other employees may be exposed to BBP. You will need to take into account all employees’ duties including your office employees. Most employees’ exposure to BBP could be from rendering assistance to sick or bleeding employees. Even if you do not require employees to perform first aid or CPR, it is still to the employer’s benefit to provide training and have a written exposure plan.
You can create a training program for BBP Exposure Control having minimum standards. OSHA has a great outline of an Exposure Control Plan created in partnership with the National Roofing Contractors Association. If you’re a contractor with no written plan this will help you get in to compliance. Visit the link to this outline here: https://www.osha.gov/dte/grant_materials/fy09/sh-18796-09/bloodbornepathogens.pdf
Your plan should be tailored specifically to your business. Exposure determination statements are very important in your written plan to identify potential exposure situations for your employees. An example of a potential exposure situation would be the fact that your supervisors are trained in First Aid and CPR and may be exposed in the event of an accident. You will also need to list in your written program “Universal Precautions” in use, appropriate engineering controls, required PPE, and appropriate housekeeping. Your trainer needs to be knowledgeable regarding BBP and training should be in a language familiar to employees and appropriate in content and vocabulary.
The following components are based on OSHA’s model:
Engineering and Work Practice Controls. Engineering and work practice controls are essentially universal measures that employees need to observe to prevent themselves from coming in contact with blood and other potentially infectious materials. This includes anything from sanitation and hygienic protocols to handling or storing food in the workplace.
Housekeeping. Housekeeping is a way to decontaminate surfaces and materials that have been used to handle, store or temporary place objects that may have come in contact with blood or PIMs. The housekeeping plan requires employees to apply disinfectants (e.g. chlorine bleach solution, Lysol and other EPA-recommended disinfectants) on tools and surfaces. Housekeeping also involves observing proper precautions when discarding regulated wastes, contaminated sharps and containers.
The Use of Personal Protective Equipment (PPE). The employer should provide personal protective equipment such as masks, shields, eye protection, gloves, and aprons and should replace or repair PPE as needed.
List of PPE chosen specifically to address potential exposure to blood and potentially infectious materials should be made available to employees. Proper donning, removal, and storage should be observed.
Vaccination. A Hepatitis B vaccination should be offered to all employees who are occupationally exposed to blood-borne pathogens. Employees can decline the vaccination or request their employer to schedule it on a later date.
Post Evaluation Check-Ups. Incidences of exposure should be well-documented and reported. An employee who accidentally gets exposed should be treated or evaluated as soon as possible. He should also receive counseling. All of the findings, diagnoses and treatment plan will be kept confidential.
Training. Any employee who is at risk from occupational exposure to blood-borne pathogens should participate in a training program. The training is given to the employee prior to his assignment. Should the employee’s task be modified during the course of his employment that may potentially increase his susceptibility to occupational exposure, then he would have to undergo up-training.
Training constitutes the following:
- A copy of 29 CFR 1910.1030 and a detailed explanation of its provisions.
- Potential exposure to blood-borne diseases and symptoms of these diseases.
- The employer’s exposure control plan and its components.
- An explanation of the selection process for the PPE.
- How to properly use PPE and dispose of contaminated PPE.
- How to recognize workplace tasks and activities that involve occupational exposure to blood-borne pathogens.