Introduction

Bloodborne Pathogens Certification Class

Welcome to our Bloodborne Pathogens certification class.

As an employer, it is your responsibility to determine training based on the language, vocabulary, literary and educational barriers that your employees hold. It is also vital that your employees receive annual training to ensure the continued awareness of bloodborne pathogens within a full calendar year of their previous training session.

Medical symbolAn employer holds the full responsibility of educating their employees on risks associated with occupational exposure. This training must meet specified and appropriate requirements and be offered free of charge for every employee during their pre-existing working schedule. Employers must also provide additional training in the event of new responsibilities and roles and up-to-date training on the latest techniques and technology, including further changes within the field of occupational exposure overall.

Definitions

For complete definitions, please view the OSHA Bloodborne Pathogens Standard. This covers all the specific information needed to understand the terms and language used surrounding occupational exposure risks.

Click to view definitions

Assistant Secretary: This title is the shorter name for the Assistant Secretary of Labor for Occupational Safety and Health or a temporary representative taking on this role.

Blood: Blood from a human being, including any components or products created using the blood itself.

Bloodborne Pathogens: Microorganisms that can cause disease or sickness when exposed to human blood. Common bloodborne pathogens include Hepatitis B (HBV) and Human Immunodeficiency Virus (HIV), alongside many other diseases and illnesses.

Clinical Laboratory: A working lab or environment where blood and infectious materials are screened, tested, and examined for clinical reasons.

Contaminated: A situation in which infectious materials, including blood, is present on an item or surface, such as a worktop or article of clothing.

Contaminated Laundry: Any laundry items and linens that may have been contaminated with blood or other substances, or contain sharps, are considered contaminated laundry.

Contaminated Sharps: Any object with infectious material or substance that can break the skin is a contaminated sharp. This included anything from broken glass to dental wires, scalpels, and needles.

Decontamination: The process of removing or eradicating an infectious material by removing blood or sterilizing a surface to prevent the transmission of pathogens and render the area or item safe for use or handling. Chemical and physical methods may be used to decontaminate an object or surface completely.

Director: The shorter term for the Director of the National Institute for Occupational Safety and Health, US Department of Health and Human Services, or a temporary representative taking on this role.

Engineering Controls: A protocol process that is in place to reduce the risks and chances of contamination, such as a needle-less system, altered medical devices, and sharps containers. These controls reduce the chances of bloodborne pathogen transmission and may remove this risk altogether.

Exposure Incident: A situation in which an employee is exposed to infectious materials during their day-to-day tasks and duties. This could include contact with the eye, mouth, mucous membranes, or on intact skin.

Handwashing Facilities: This term refers to a dedicated space where potable, clean water, disinfectant, and cleaning materials are available for employees to thoroughly clean and dry their hands.

Licensed Healthcare Professional: An qualified medical professional with the legal requirements to carry out Hepatitis B vaccinations, post-exposure evaluations, and follow-up protocol for employees.

HBV: The abbreviated name for Hepatitis B, which is an HB virus that causes infection in the liver that can be life-threatening or lead to serious illness. A preventative vaccine is available for HBV, but no cure currently exists for this health condition.

HIV: The abbreviated name for Human Immunodeficiency Virus. This virus leads to the onset of Acquired Immune Deficiency Syndrome (AIDS) and causes direct damage to the immune system, which can result then in fatal illness. HIV has no current cure, though antiretroviral drugs can help those with HIV live longer and remain healthier.

Needle-less system: A system in which needles are not used for a range of medical tasks, including:

  1. The withdrawal or collection of bodily fluids via arterial or venous access
  2. Administration of medications and fluids
  3. Additional procedures with a potential risk of infection through bloodborne pathogens

Occupational Exposure: Exposure in the workplace to infectious materials or bloodborne pathogens is a standard part of duties or responsibilities.

Other Potentially Infectious Materials (OPIM): A selection of bodily materials that may be infectious and therefore a risk to employees, including:

  1. Any bodily fluids such as amniotic fluid, body fluid contaminated by blood, cerebrospinal fluid, pericardial fluid, peritoneal fluid, pleural fluid, saliva, semen, synovial fluid, and vaginal secretions. Undetermined or difficult-to-determine bodily fluids also count as OPIM.
  2. Tissues and organs are unfixed from the body and removed from a human who is either alive or dead
  3. Any cells or tissues known to contain organ cultures, HIV, or other mediums of a bloodborne pathogen, including organic materials from both humans and animals. This includes tissue used to experiment with bloodborne pathogens.

Parenteral: The process of using abrasions, needles, or biting to permeate and pierce a mucous membrane.

Personal Protective Equipment (PPE): Specially designed clothing and protective gear used to keep employees safe from workplace hazards. Regular work clothes do not meet this definition, as they do not offer protection for biomedical risks and pathogens in the workplace.

Production Facility: A lab or facility where HBV or HIV are produced on an industrial level.

Regulated Waste: Any and all waste containing contaminated items, blood, or any infectious fluids or materials.

Research Laboratory: A lab setting that produces or uses significant volumes of either HIV or HBV to a smaller scale than a production facility.

Sharps with engineered sharps injury protections: This term refers to devices with inbuilt safety mechanisms that protect the employee during the withdrawal of fluids and blood into a vein or artery.

Source Individual: The sole original source of an infection such as HIV or HBV, who is a direct risk to employees treating them or working with the body following death.

Sterilize: A practice used to remove and destroy resistant endospores and microbes from devices, items or surfaces, to reduce risk or harm or infection.

Universal Precautions: The standard protocol used to prevent and minimize the risks of infection where bloodborne pathogens for HBV and HIV are present.

Work Practice Controls: Any practice or protocol in place that is designed to reduce employee exposure and reduce risks in the workplace where bloodborne pathogens are present or used.

An OSHA guide is available at www.osha.gov.

Note: It is a legal requirement that any employee who handles blood, OPIMs and bodily fluids take a course in the safe handling of these materials. For many employees, some sort of certification or credentialing is also required. – Introduction Note: Bloodborne Pathogens Certification Class.

Precautions

Bloodborne Pathogens Certification Class

What is a Universal Precaution?

A universal precaution is one of a set of rules and regulations set out by the Occupational Safety and Health Administration (OSHA) to reduce the risk of transmission of bloodborne pathogens in any form in the workplace. These universal precautions are defined to improve the safety of any individual that needs to be in contact with infected individuals, which in turn increases their risk of exposure in the workplace due to OPIM or blood.

Univresal Precautions

Universal precautions must be considered and followed at all times to prevent direct contact with infectious materials from humans. Every type of bodily fluid and transmission method should be regarded as high-risk and a potential risk to the health of staff members because of the potential presence of bloodborne pathogens.

As a protection method, exposure control plans are used in the workplace to reduce risks and enhance safety.

The following is included as part of exposure control planning:

  • Well-designed engineering controls
  • Implementation of best work processes and practices
  • Use and suitability of personal protective equipment (PPE)
Controls

Bloodborne Pathogens Certification Class

What do engineering controls do?

Engineering controls are the methods and practices implemented to change the environment or process employees use. These controls reduce the risk of exposure to bloodborne pathogens and other potentially infectious materials. Engineering controls should be reviewed, checked, and regularly amended to ensure their full effectiveness.

Examples of engineering controls include:

  • Splashguards on benchtops
  • Safety devices on needles
  • Biological safety cabinets
  • Capillary and blood tubes
  • Use of PPE
  • Appropriate disposal for sharps
  • Biohazard signs, cleaning equipment, and safety barriers alongside other vital safety equipment

Containment equipment

Equipment that is used for containment in the workplace could include:

  • Suitable biological safety cabinets
  • Using animal cages or crates
  • Decontamination of labs
  • Survival systems for plants
  • Centrifugal containers for biological materials

Jars and Bottles Of Chemical In The Laboratory

Examples of engineering controls and containment equipment

Safety cabinets explicitly designed for use with biological equipment helps to improve safety and reduce risks when working with contaminated materials, defined as BSAT (Biological Select Agents and Toxins).

The use of pathological incinerators, cremators, or alkaline hydrolysis digesters on-site ensures the safe disposal of larger, infected animals quickly and effectively. In contrast, redundancy practices ensure that the removal method continues to be most suitable for the environment.

The use of an Effluent Decontamination System, or EDS, works to ensure all hazardous and contaminated liquid waste generated in laboratories and facilities to sterilized before disposal or discharge.

An HVAC or suitable ventilation system ensures the workplace is breathable, safe, and comfortable while minimizing airborne exposure for staff and the public. BSL-3 and BSL-4 level laboratories must have all exhaust air routed to the outside of the building safely due to potential contamination of the air from contaminants.

Utilizing HEPA filters in laboratory and workplace settings prevents exhaust air from being released with hazards and contaminants intact. The choice of HVAC should be tailored to the scale of operations and the size of the room. In combination with HEPA, the HVAC should supply clear air to ensure proper exhaust functionality and the comfort and safety of workers.

Additional containment of bloodborne pathogens

In laboratories or facilities where extra protection is required, you may use additional containment methods to reduce exposure to bloodborne pathogens and infectious materials. Additional containment refers to protection beyond the room or workshop to ensure the safety of other workers and the wider public.

Secondary containment could include:

  • Physical separation of work areas with potential exposure risk from any space with public accessibility.
  • Use of effective decontamination practices, including autoclaves, washing stations, dirty and clean corridors, and double-entry points.

Enclosing and isolating bloodborne pathogens

Using effective isolation techniques can aid in keeping areas contaminant-free in the workplace, particularly around workstations and equipment. The use of isolation ensures hazardous tasks and risky processes are separated from most workers, while enclosures separate the worker from the material directly.

Enclosed machinery and equipment are usually airtight and only opened for specific purposes such as sample removal, cleaning, or maintenance. Processes should be in place to ensure open enclosures are not a risk during these times, and regular maintenance should be carried out to prevent leaks or the risk of exposure further.

How are work practice controls used?

The tasks involved in work practice controls are explicitly designed to reduce the risk of exposure to bloodborne pathogens or OPIM. These rules generally include what employees shouldn’t do in the workplace to minimize risks greatly.

Examples of prohibited actions in work practice controls could include:

  • Application of cosmetics in workspaces
  • Inserting, removing, or handling contact lenses
  • Smoking, drinking or eating in inappropriate places
  • Drinks or food placed near or in direct contact with infectious materials
  • Bending, breaking, or recapping used needles
  • Pipetting into the mouth or eyes

A further example of work practice controls could be having restrictions on who can enter clinical spaces, workshops, or laboratories to those with specific permissions. For permitted employees, frequent handwashing with soap and water at suitable facilities is a requirement and the use of a ‘no hands’ procedure in the disposal of contaminated materials.

Note: When disposing of regulated waste, it must be placed in containers that are closable, labeled or color-coded, built to prevent leaking in storage or in transit, and sealed to prevent spills, leaks or other means of exposure. The actual disposal of this waste must meet all regulations that apply according to the United States. – Universal Precautions Note: Bloodborne Pathogens Certification Class.

Labeling

Bloodborne Pathogens Certification Class

Biohazard and color-coding label requirements

Disclosing potential hazards is carried out by using an appropriate labeling system that adheres to the Bloodborne Pathogens Standard. This system ensures clear communication of contamination and risks.

All of these containers must have appropriate labeling:

  • Reusable sharps containers
  • Regulated waste disposal
  • Fridges or freezers used in the containment of blood or OPIM
  • Containers or packages used to store, transport, or ship blood or OPIM OPIM
  • Contaminated laundry bags and containers
  • Contaminated equipment due to be shipped or serviced

Within facilities, a red bag or container system can be used as an alternative to labels. However, clear signage in HBV/HIV labs and facilities is a requirement where contaminated materials or infected animals are used. Employees should have complete knowledge and training in handling pathogens and tissue cultures before working with HIV or HBV.

Note: Biohazard symbols must be a contrasting color on a fluorescent red or orange background. – Labeling Note: Bloodborne Pathogens Certification Class.

Pathogens

Bloodborne Pathogens Certification Class

What is a bloodborne pathogen?

A bloodborne pathogen is defined as a microorganism that can infect others and cause harm and disease. These are typically transmitted by contact with the blood of an infected individual.

The three primary pathogens listed under BBP guidelines include:

  • Human immunodeficiency virus (HIV)
  • Hepatitis B (HBV)
  • Hepatitis C (HCV)

Alongside these primary pathogens, other bloodborne pathogens include:

  • Herpes
  • Impetigo
  • Molluscum Contagiosum
  • Ringworm
  • Scabies
  • Staphylococcus Aureus
  • Tuberculosis

What are the modes of transmission?

Bloodborne pathogens typically infect humans through the transmission of infected human blood. However, there is a range of Other Potentially Infectious Body Materials (OPIM) that may lead to the infection of a bloodborne pathogen.


These OPIM methods include:

  • Amniotic fluid
  • Cerebrospinal fluid
  • Contaminated blood
  • Peritoneal fluid
  • Pleural fluid
  • Semen
  • Synovial fluid
  • Vaginal secretions

Transmission modes of infectious materials can occur in any circumstance where human fluids have contact with broken skin or a mucous membrane. Typical areas of transmission or the genitals, rectum, and mouth, in addition to the eyes and nose. Any open sore can also allow for the transmission of fluids, such as in the case of cuts, acne, or abrasions.

Some of the most common transmission modes include:

  • Needles of all types
  • Items used for personal hygiene
  • Syringes
  • Body and face piercings
  • Fresh tattoos
  • Any form of contact
  • From mother to child during or following birth
  • Punctures or scratches from contaminated sharps or needles

Note: Hepatitis is an inflammation of the liver. The condition can progress to fibrosis (scarring), cirrhosis or liver cancer or can be self-limiting. Hepatitis viruses are the most common cause of hepatitis in the world. Other infections, toxic substances (alcohol, certain drugs), and autoimmune diseases can also cause hepatitis. – Hepatitis Note: Bloodborne Pathogens Certification Class.

Waste

Bloodborne Pathogens Certification Class

Disposing of biohazardous waste

Any employees working in a role with occupational exposure risk thanks to biohazard waste should receive immediate and yearly training on the safe disposal of materials.

Communicating biohazardous materials

Warning labels should be added to all containers or bags with regulated waste, and all waste must have appropriate disposal processes.

Cleaning home table sanitizing kitchen table surface with disinfectant spray bottle washing surfaces with towel and gloves. COVID-19 prevention sanitizing inside

All of the following is considered regulated waste:

  • Contaminated items or materials at risk of releasing liquid or semi-liquid blood or OPIM in compressed
  • Sharps that have been used
  • Blood and OPIM in liquid or semi-liquid form
  • Items with dried OPIM and blood that could be released through compression or damage
  • Pathological and microbiological waste with OPIM or blood

Containers should be dated, signed, and labeled once decontaminated to indicate they pose no risk. These bags should not be biohazard colors or include biohazard labels. Custodians and housekeepers cannot dispose of any regulated waste listed above unless labeled as non-hazardous, and they should be instructed as such unless marketing and labeling are present.

If waste has been autoclaved or decontaminated, it can then be disposed of in a regular dumpster using standard trash bags. For autoclaved items, unlabelled autoclave bags may be used. However, any bag labeled as a biohazard cannot be disposed of in the correct manner.

Regulated waste that cannot be autoclaved or decontaminated must be disposed of in labeled containers or red biohazard bags. Any sharps must be in a puncture-proof container. All items must to removed to a specific collection site for correct disposal, in line with your exposure control plan for bloodborne pathogens.

Plans

Bloodborne Pathogens Certification Class

Implementing an exposure control plan

An exposure control plan provides guidance and answers related to bloodborne pathogens, ensuring appropriate controls are in place. If there is a risk of exposure to hazardous substances, OPIM or blood, then the OSHA Bloodborne Pathogens Standard requires you to develop an exposure control plan. This plan should be easily accessible to all employees.

OSHA requirements for the exposure control plan are as follows:

  • The plan must be specific to individual facilities
  • Reviews and updates should be carried out yearly, with new changes and new technologies considered
  • Employees must have up to date knowledge of the plan
  • The plan must be accessible to all employees and easy to find
Click to view our example exposure control plan

Hepatitis B vaccine

Following formal bloodborne pathogens training, employees must offer employees the hepatitis B vaccination. This vaccine offer must be within ten days of acceptance of a job with occupational exposure risks. Should an employee refuse the vaccination, they must sign a statement in confirmation. Should boosters be needed, these should also be available at no cost to the employee.

As a way to protect against HBV, the hepatitis B vaccine is highly effective. HBV carriers or those immune to the virus will experience no harm from the vaccine. The HBV vaccine protects against infection and against complications such as liver damage, liver cancer, and death. It’s vital that you inform employees that the HBV vaccine also helps to protect those around them too.

Equipment

Bloodborne Pathogens Certification Class

What is PPE?

PPE, also known as personal protective equipment, is any wearable item that keeps an individual safe from hazardous materials, OPIM, and blood.

Examples of PPE include:

  • Face shields
  • CPR covers or shields
  • Suitable gloves
  • Goggles
  • Lab Coats and gowns
  • Face masks and respirators

Face shield

As required, employees should wear PPE to reduce the likelihood of exposure to bloodborne pathogens significantly. In circumstances where large-scale contamination is expected, the use of hoods, shoe covers, or caps should also be included as PPE.

All PPE works to create a solid barrier between an employee and the source of potential exposure or infection. Before arriving at the scene of an incident or accident, it’s vital to assess and consider which PPE is suitable for an individual situation.

For each purpose or task, PPE should be selected accordingly and should be immediately available to employees at all takes. In some extremely rare cases, such as emergencies, employees may not have the time or access to PPE necessary. If an incident of this type occurs, it’s vital to record the situation comprehensively to prevent reoccurrence.

If an employee is allergic to one or more types of PPE, employers should provide a readily available alternative. It is also the employer’s responsibility to ensure employees are familiar with using PPE and the situations in which PPE is required when working with OPIM, hazardous substances, or blood.

Examples of personal protective equipment include CPR covers or shields, which prevent exposure when an individual is performing CPR. Face shields are another example of PPE, working to avert high-impact splatter and splashing, while gloves avoid contact with infectious materials, heat, cutting, and chemicals. PPE gloves must be worn on the correct hands.

PPE googles are used to prevent infection via splatter, splashes, or debris and prevent laser radiation and chemical damage. Gowns and lab coats can be used to provide torso and leg protection against infectious blood, OPIM, and any other hazardous materials. Masks are used to protect against airborne materials and any liquid that may contact the face or mouth.

Cleaning and decontaminating PPE

As part of their duties, employees should be responsible for the cleaning, disposal, and sterilization of surfaces and materials that have had contact with bloodborne pathogens. Employers are required to protect their employees from this exposure and minimize the disinfection or cleaning process risks. PPE can be used to provide that protection.

What cleaning guidelines should be in place?

Any surface that has visible contamination of any material, from vomit to bodily fluids to blood or feces, should be immediately and appropriately disinfected and cleaned. For bulk materials or visible contamination, disinfectants should first be used before removal or clean-up is carried out. Following the disposal, the area of contamination should then be thoroughly cleaned and decontaminated with disinfectant. Any areas where contamination is suspected without visual confirmation should also be thoroughly decontaminated to reduce the risk of exposure.

For spills of any size, the use of absorbent material should be the first step to prevent spread. A disinfectant should then be used for full saturation of the area. This allows for the sterilization of infectious materials and viral contamination. Sufficient ventilation must be used, and staff must receive full training on using and protecting themselves against chemical disinfectants if these products are required.

Using disinfectants effectively

Following a bulk spill, it is a requirement that surfaces are effectively disinfected and decontaminated. This requires using an EPA-registered form of disinfectant, which is suitable for use on non-enveloped viruses. Should commercial products be unavailable, standard household bleach and similar products may be used as a replacement. A ratio of 1:10 bleach to water is effective in decontaminating an area. You mustn’t mix additional chemical combinations, as this can reduce effectiveness and result in harmful fumes in some instances.

Using respiratory protection and equipment

Workers exposed to airborne or aerosolized blood, hazardous material or OPIM should use proper respiratory protection to ensure their safety. If this is a regular occurrence or considered risk, the fitting of N95 NIOSH-approved respirators is a minimum requirement.

PPE for cleaning

The choice of on-site PPE that an employer has on-site must provide optimal safety for workers who risk exposure to bloodborne pathogens as part of their tasks. This includes all cleaning duties, where suitable PPE can consist of gloves, goggles, face masks, gowns, and face shields. In addition, supplying protective shoe, leg, and sleeve coverings can reduce the risks of exposure to infectious materials. In some cases, the use of face masks with respiratory protection may be suitable in environments where blood, OPIM, or hazardous substances are found.

Removing PPE

All PPE should be removed before an employee leaves the room and must be disposed of safely in designated storage for disposal, washing, storage or decontamination. Once the individual employee has completed all cleaning and disinfection required, their PPE should be removed before they wash their hands at a handwashing station with soap and water. If no station is available, hand gel with an alcohol base may be used for handwashing.

Properly disposing of cleaning waste

All PPE and cleaning materials used as part of decontamination should be completely soaked in a suitable disinfectant. Once this process is complete, these items can be double-bagged and placed in an appropriate, designated leak-proof container. In the case of sharps, a puncture-proof or sharps-specific container should be used. According to product guidelines, any porous items that cannot be decontaminated or disinfected effectively should be disposed of.

Correct handwashing procedures

Handwashing should be covered in your guidelines for employees. This should include a provision and process for employees to access handwashing equipment as soon as blood contacts the mucous membranes, eyes, or skin. Handwashing should be carried out following the removal of PPE and gloves.

If no running water is accessible, alternatives should be defined. These alternatives could include hand sanitizers or disinfectant towels. On remote sites, employees should be able to wash their hands in running water as soon as possible following an incident.

Flushing the eyes and mouth

If an employee’s eyes make contact with OPIM or blood, they should immediately flush with water or appropriate eyewash for 5-10 minutes. For contact with the mouth, rinsing for 5-10 minutes is recommended.

Decontaminating equipment

All equipment should be thoroughly decontaminated before transportation, repair, or handling. You should have a clear outline of the process to clean equipment before it is handled. This may include instructions for disassembly to clean internal parts if required.

If full decontamination is not possible, a biohazard label should be attached to the machine. You will also be required to list the parts of the equipment that may still be contaminated. Sheets of paper, self-adhesive labels, and string tags are all accepted labeling methods.

Handling specimens

Should your employees need to handle specimens, you will be required to outline the proper practice for handling. This process could include providing information on the appropriate way to package specimens. For workplaces where handling of samples is not required, this process is not necessary.

Handling needles

Unless necessary, no needle should ever be bent or recapped by hand. The procedures you put in place must require the correct disposal of sharps in a designated puncture-resistant bin that is readily available and identifiable. All containers should be close to areas where sharps are found or used.

Note: The decisions you make for sharps disposal much be based on professional insight and judgment. For example, you could choose to place sharps containers in every examining room where needles are used. Even sharps with inbuilt injury protection should be disposed of in this appropriate manner. – Equipment Note: Bloodborne Pathogens Certification Class.

Procedures

Bloodborne Pathogens Certification Class

Emergency procedures for infectious materials

Should an emergency occur with blood or OPIM, emergency procedures exist to minimize exposure and reduce the risks of contact.

What if an employee is exposed?

If exposure occurs, this should be reported to a supervisor as quickly as possible. An exposure report should also be filled out and stored as part of a personal file for 40 years. This allows employers to identify exposures and keep track over time. If the employee does not have an HBV vaccination, they will need to request one for HR. Blood testing can also be carried out to confirm whether an infection occurred.

Post-exposure procedures for employers

Unless there are specific legal and physical limitations, it’s crucial to identify the source individual following an exposure quickly. The route of exposure should be listed, as well as a full breakdown of the incident itself. The source individual should be tested for both HBV and HIV. If they are already a confirmed positive, this testing is not required.

Post-exposure prophylaxes should be provided as defined by the US Public Health Service, and counseling should be offered. Reported illness should be examined through a formal medical examination in addition.

If the employee consents to do so, blood testing should be carried out. If they refuse HIV screening, their blood sample can be stored following other tests. This storage allows further testing to be carried out at a later date if requested. All diagnoses found during blood testing will remain 100% confidential to the employee.

Written opinions from a healthcare professional

Once the initial evaluation is over, the employer is required to offer the employee a copy of a healthcare professional’s written opinion within 15 days of testing. This document will include the evaluation results and whether they have been informed of other medical conditions caused by exposure. Any opinion on the HBV vaccination will be limited to if the employee has received a vaccine and whether it is indicated for them to get it.

Any additional findings by a healthcare professional will remain confidential and cannot be listed in the formal written report.

Recordkeeping Requirements

Medical Records Patient Chart

You will need to meet specific methods of compliance in record keeping. These include:

  • Engineering and work practice controls, such as handwashing and sharps disposal
  • Universal Precautions
  • PPE
  • Housekeeping, such as regulated waste removal and decontamination
Click to view Recordkeeping Requirements

You will also need to keep complete documentation of the following:

  • Considerations and implementations of new commercial medical devices to minimize and reduce occupational exposure risks
  • Solicitation of any non-managerial healthcare professionals, with responsibility for patient care and direct work with sharps, for the evaluation, identification, and selection of controls in the workplace.

Beyond this, you must also ensure your exposure control plan is updated and reviewed at least once per year and whenever necessary to encompass new tasks, modified roles, and changes in procedure that affect the risk of occupational exposure.

Employees must also have access to relevant records and medical information for their designated representatives. In addition, they must offer access to the Assistant Secretary, as required by the Occupational Safety and Health Act.

Employee Access Regulations Exposure and Medical Records

Click to view Employee Access Regulations Exposure and Medical Records

The Hazard Communication Standard

All employees must have complete training and accessible information on the hazardous materials in their working environment and know the requirements of the hazard communication standard.

The information they should know includes:

  • How to use labels and material safety data sheets
  • Where the written hazard communication program is and the information included
  • The hazards of working with chemicals and the protections in place, such as PPE
  • Training in the use and suitability of PPE
  • How to choose, wear, and effectively dispose of PPE

OSHA expects all employers to document their training, ensuring they meet their legal requirements for every employee. This standard requires that all documentation include the employee’s name, the subject of training, and the date the training took place.