Public Health Law Map - Beta 5 - Medical and Public Health Law Site

9. Bloodborne Pathogens
All workplaces are required to have procedures for dealing with bloodborne
pathogens. These regulations were developed in response to the fears raised by the
HIV epidemic, but they serve to protect employees from a variety of illnesses,
particularly viral hepatitis.
A workplace that does not provide medical service and has no other significant
exposures to body fluids can make do with a very simple program for cleaning up
blood. Obviously, there is always a risk of blood exposure in a workplace. Any
employee can have a nose bleed or a cut that spreads blood in the environment.
There must be a written procedure for cleaning up the blood without coming into
contact with it and then sanitizing the environment with a cleaning solution that kills
bloodborne pathogens. Rubber gloves, paper towels, and a spray bottle of bleach
solution are the only equipment needed in most workplaces.
a) Health Care Organizations
For medical care organizations and other high-risk occupations the requirements
are much more extensive. In 1991, OSHA issues its final rules on “Occupational
exposure to bloodborne pathogens.” These rules are based on CDC
recommendations that were issued earlier that year. The rules encompass primary
and secondary prevention in three categories of protection.
The primary prevention required is immunization for hepatitis B. In 1991, many
organizations required employees and volunteers to pay for their own
immunizations. For many, the expense was prohibitive. Under the OSHA rules, the
employer must now provide the immunization free of charge to all employees who
may be exposed to blood or body fluids. And, most employees of a hospital,
laboratory or nursing home would be considered at risk. Other immunizations were
not included in the requirement or were not available in 1991. However, given the
legal and medical risks of disease transmission, the immunization program should
include Tetanus/diphtheria, measles/ mumps/rubella, hepatitis A, chicken pox, and
rabies if animal exposure is a consideration.
The second and most expensive requirement is universal precautions. This
protection requires barriers to exposure in all situations where a worker is or might
be exposed to blood, body fluids or other tissue. As with any industrial exposure,
engineering controls such as vent hoods and administrative controls, such as
limiting the number of people exposed should take precedence over personal
protective equipment. However, there is very little that can be done by engineering
or administration. All employees who are at risk of exposure must be given eye
protection, disposable gloves, masks, and clothing as needed. This must be
appropriate for each individual and readily available.
The disposal of contaminated materials is also carefully regulated. Sharps
containers must be available wherever needles or cutting instruments are used.
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