Bloodborne Pathogens—When Is a Program Required?
A Bloodborne Pathogens (BBP) program is a given for healthcare organizations, but what about other industries? Requirements may apply to more than just bloodborne pathogens. OSHA identifies a host of “other potentially infectious materials.” Taken directly from CFR1910.1030:
Other Potentially Infectious Materials means
(1) The following human body fluids: semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva in dental procedures, any body fluid that is visibly contaminated with blood, and all body fluids in situations where it is difficult or impossible to differentiate between body fluids;
Many of you may be thinking, “My employees don’t come into contact with that stuff!” Generally, if you work in a machine shop or a grocery store you would be correct, but there may be exceptions. For example, an employee, visitor, or customer cuts themselves. The injured person is unable to clean up their own blood as they were whisked off to the urgent care clinic. Who then is responsible for cleanup? How about your designated first responders or those providing first aid? If so, they are covered by the standard. Injuries like these are fairly common, and the business disruption while the cleanup takes place can be significant. Safe and expeditious cleanup comes from personnel thoroughly trained in proper cleaning methods and personal protection.
Housekeepers in the hospitality industry may also be covered by this standard. It’s likely that these workers will encounter human body fluids while cleaning hotel rooms, bathrooms, and other public spaces. OSHA’s letters of interpretation don’t dictate either way, but put the responsibility on the employer to make this determination. Providing awareness training is prudent in this case. You can find additional letters of interpretation here.
In closing, ask yourself this simple question: “Is there a reasonable expectation that employees will come into contact with blood or other potentially infectious materials?” If the answer is “no” then a program is likely not required. If the answer is “yes”, or even “maybe” then a program compliant with CFR 1910.1030 is required.
MEMIC customers have access to program templates and training located in the Safety Director along with additional training on our Workplace Safety page. Additional information is available from your MEMIC Safety Management consultant, your broker/agent, third party consultants, or OSHA/DOL Consultation Department.
