Bloodborne pathogen coverage and vaccinations

Date Posted: 09/09/2019
Bloodborne Pathogens

The bloodborne pathogens standard is not meant solely for employees in health care, although many provisions seem particular to that industry, such as handling used needles and contaminated laundry. Still, any employee who has occupational exposure to blood or other potentially infectious materials (OPIM) falls under the standard.

In layman's terms, occupational exposure means reasonably anticipated contact with blood or OPIM as a result of job duties. For example, employees who are designated to provide first aid or medical assistance as part of their job duties would be covered by the bloodborne standard. According to OSHA, it is reasonable to anticipate that such employees will have occupational exposure to blood or OPIM, so they must be trained as required in the standard.

Some exceptions

Some employees may have training in first aid, but not be covered by the standard. For example, a company might host a CPR class at no cost to employees as a benefit. Not all employees who take the course will be designated as first responders, and the employer won’t expect them to assist injured coworkers. Therefore, they do not have occupational exposure and are not covered by the standard.

Good Samaritan acts are not considered occupational exposures unless the employee is a member of a first aid team or is otherwise expected to provide medical assistance. Some employees may choose to help injured coworkers, but OSHA recognizes that employers cannot reasonably anticipate which individuals (not designated as responders) would choose to help.

Vaccination provisions

Employees with occupational exposure must be offered the hepatitis B vaccine and vaccination series. Some employees may decline, and in fact OSHA estimated that only about half of employees offered the vaccine would accept it. An employee who declines must sign a hepatitis B vaccine declination, which can be found in Appendix A to 1910.1030.

In some cases, a covered employee may decline because he or she already received the vaccination. If so, medical documentation of the vaccination should be included in the employee’s medical file if at all possible. If such documentation cannot be obtained, the employee must sign the declination form.

Note an employee could initially decline the vaccination, but later change his or her mind and request it. If the employee’s duties still involve occupational exposure, the employer must make the vaccination available.

Finally, if an employee has an exposure incident while acting as a Good Samaritan, the employer is not required to provide the vaccination series, nor offer the post-exposure evaluation other follow-up. However, OSHA encourages employers to do so.

How Safety Management Suite Can Help

If you have employees with occupational exposure, you need to identify them as part of your written exposure control plan. The standard lists a number of elements that must be included in the plan. Fortunately, these elements are included in a template found in the plans & policies tool in the J. J. Keller SAFETY MANAGEMENT SUITE, helping you quickly create the documentation you need.

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