Implementing Osha's Biohazard Standards

by Bill Grieb

Many employees may be exposed to biohazards in their workplace. The Occupational Safety and Health Administration (OSHA) has developed standards related to blood-borne pathogens such as hepatitis and AIDS, but other hazards exist, including tuberculosis and the hanta virus. Any employee who risks coming in contact with infectious materials is covered by the blood-borne pathogens (BBP) standard (Federal Requirement CFR 1910.103). Professions at risk include housekeepers and janitors, groundskeepers and gardeners, nurses and dental assistants, firefighters, and even first-aid givers.

Infectious materials include semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva in dental procedures, any body fluid visibly contaminated with blood, and all liquids that are difficult to differentiate from body fluids.

BBPs may also be spread by contact with tissues or organs other than intact human skin; cell or tissue cultures containing human immunodeficiency virus (HIV, the virus that causes AIDS); culture medium or other solutions containing HIV or Hepatitis-B (HBV); and blood, organs, and other tissues from experimental animals infected with HIV or HBV.

Federal Requirement CFR 1910.103, the BBP standard, was established to protect the 5.6 million workers who are at risk of being exposed to BBPs. It aims to reduce the 200 deaths and 9,000 infections caused every year by these contaminants. The greatest risk is HBV, but the standards have been developed to protect against the HIV virus, too. The health of such professionals as funeral specialists, waste-removal workers, police, firefighters, and even dry cleaners depends largely on compliance with these standards.

So far, the new BBP standard has been an enormous success. In any given year, OSHA now issues approximately 1,000 citations for BBP standards violations, particularly in the health field. Today, more than half of the doctors and dentists inspected received citations for BBP violations.

Many of OSHA's BBP citations involve these key areas:

• training in needle recapping
• proper sharps containers
• regulated waste
• personal protective equipment
• vaccination
• employee training

The hanta virus is endemic in rodents such as deer mice (12% to 70% of them are infected), but it's is rare in humans-though deadly. It was first identified in the Four Corners region in the Southwest United States. The virus produces hanta virus pulmonary syndrome (HPS), a hemorrhagic fever.

This virus is easily killed by sunlight and disinfectants, and not many more than 100 cases have occurred in the last several years. However, seven of 11 California cases resulted in fatalities, and death still results in 50% of U.S. cases.

Utility company workers and vector-control technicians face occupational exposure. When the exposure cannot be eliminated, precautions should be taken such as HEPA respirators and hand, eye, and face protection.

Tuberculosis (TB) is increasing, especially among the homeless, migrant workers, and residents of correctional institutions. The most common sources of exposure are health-care facilities, prisons, elderly care facilities, homeless shelters, AIDS treatment facilities, and outpatient treatment facilities.

Exposure may occur by merely sharing the surrounding oxygen with people infected with TB. The National Institute of Occupational Safety and Health (NIOSH) recommends powered air-purifying respirators, but the health care industry considers them unfeasible.

TB is detected with a skin test. A positive result from the skin test was once a death sentence, but now most cases of TB can be treated with medication. However, protecting a region's workers against TB exposure can be expensive, as seen by these costs estimated by the Kaiser Foundation Health Plan: more than a million dollars in wage and benefit costs to develop exposure control plan and training; $1.5 million for skin tests in Southern California alone; and $500,000 to make a department's ventilation system pathogen-free.

A free fact sheet on tuberculosis is available from Hazard Evaluation System and Information Services (HESIS) at (510) 540-3138.

The federal standard pays special attention to the BBP risks faced by technicians dealing with HIV and HBV in laboratories and production facilities. The standard's microbiological practices and strict procedures are meant to minimize the vulnerability of employees who work with concentrated virus. The standard also helps facility workers who have less direct contact with these viruses.

These facilities must use the mandatory containment equipment and an autoclave to decontaminate regulated waste. All buildings must be constructed in a way that limits risks and permits easy cleanup after an accident. The workers themselves are required to perform their duties according to additional regulations.

The federal standard also details methods for disposing of contaminated sharps and specifies the containers to be used for these items and other regulated waste. Workers should also follow its provisions for handling contaminated laundry.

OSHA does not list all the occupations that must comply with the BBP standard; instead, it offers a broad definition that covers all professions that are 'reasonably anticipated' (as the result of performing their job duties) to have contact with blood or other potentially infectious materials. Good Samaritan acts such as assisting a co-worker with a nosebleed would not be considered occupational exposure.

Employers are required to identify, in writing, all tasks, procedures, and job classifications in which occupational exposure to blood occurs. The written plan must establish a schedule for implementing the BBP standard's provisions and the procedure for evaluating exposure incidents. It must be accessible to employees and available to OSHA.

NOTE: Employers must review and update their blood-borne pathogen plan at least annually-and more often to accommodate workplace changes.

The BBP standard treats all body fluids and materials as infectious and mandates universal precautions to prevent exposure. It stresses hand-washing and requires employers to make facilities available to all employees following exposure to body fluids. The standard's procedures minimize needlesticks and splashing and spraying of blood, ensures appropriate packaging of specimens, and regulates wastes. Decontaminated equipment must be labeled as such. All shipments of contaminated equipment, including equipment being sent to service facilities, must be labeled contaminated and potentially dangerous.

Employers must furnish employees with personal protective equipment at no cost and require their use. Some common forms of personal protective equipment are gloves, gowns, masks, mouthpieces, and resuscitation bags, all of which must be cleaned and repaired as necessary.

Gloves are not necessarily required for routine phlebotomies in volunteer blood donation centers, but must be made available to employees who want them.

The BBP standard requires employers to provide procedures for all employees who have been exposed to a pathogen. Any lab tests must be conducted by an accredited laboratory at no cost to the employee. All diagnoses must remain confidential.

Under the standard, follow-up appointments with exposure victims should include a confidential medical evaluation that documents the circumstances of the incident, identifies and tests the individual who introduced the contaminant if feasible, tests the exposed employees' blood with their consent, and provides post-exposure prophylaxis counseling and an evaluation of the reported illnesses.

To help determine the need to vaccinate a facility's workers against HBV, health-care professionals must collect special information outlined in the federal standard from the site of exposure.

The BBP standard requires that warning labels (with the orange or orange-red biohazard symbol) be affixed to containers, refrigerators and freezers, and other equipment used to store or transport blood or other potentially infectious materials. Red bags or containers may be used instead of labeling. Signs must be used to identify restricted areas in HIV and HBV research laboratories and production facilities.

Laundry need not be labeled. Employers are also not required to label blood that has been found free of HIV and HBV and released for clinical use.

A complete blood-borne pathogen kit includes biohazard warning labels, a label master for photocopying, a summary of key provisions, and a variety of OSHA fact sheets. Here's a list of recommended items to include in a workplace kit:

1. Orange biohazard warning sign
2. Definitions
3. Summary of key provisions of standard
4. 'Holding the line on contamination' fact sheet
5. 'Reporting exposure incidents' fact sheet
6. 'Personal protective equipment' fact sheet
7. 'Sharps protection' fact sheet
8. 'Hepatitis-B' fact sheet
9. Declination letter
10. Copy of the law

The BBP standard mandates the training of at-risk workers within 90 days of the effective date of employment, initially upon assignment, and annually thereafter. Employees who have received appropriate training in the past year need receive additional training only in areas not previously covered. Training must include a copy of the OSHA standard's regulations and general discussions on blood-borne diseases and their transmission, exposure control plan, engineering and work practice controls, personal protective equipment, the availability of the HBV, the proper response to emergencies involving blood, how to handle exposure incidents, post-exposure evaluation and follow-up programs, and signs/labels/color-coding.

The program must offer an opportunity for questions and answers, and the trainer must be knowledgeable in the subject matter. Laboratory and production facility workers must receive additional specialized initial training.

Medical records must be kept for each employee who has experienced occupational exposure for the duration of employment plus 30 years. The records must be confidential and include the patient's name and social security number; HBV vaccination status (including dates); results of any examinations, medical testing, and follow-up procedures; a copy of the health-care professional's written opinion; and a copy of information provided to the health-care professional.

Training records must be maintained for three years and must include dates, contents of the training program or a summary, trainer's name and qualifications, and names and job titles of all persons attending the sessions.

Medical records must be made available to the employee under treatment or evaluation. Any other parties, including an employer, may view the records only with the written consent of the employee, OSHA, and NIOSH. Disposal of records must abide by the access-to-records regulations outlined in the OSHA standard.