How would your company respond to a good Samaritan exposure to blood, such as an employee voluntarily providing assistance to an injured coworker?
Only employees with occupational exposure require bloodborne pathogen training, but you can certainly provide key information on bloodborne pathogen issues to other workers. The training does not need to cover all of the topics required for employees who do have occupational exposure. However, a little information about potential disease transmission could go a long way to helping employees protect themselves if they voluntarily provide assistance to an injured coworker — and might even help them determine the extent to which they want to provide assistance.
OSHA has addressed a number of questions regarding coverage of the bloodborne pathogen standard and best practices for employers.
If a person renders first aid or CPR as a good Samaritan while on the job, he or she would not fall under the bloodborne pathogen standard. However, OSHA encourages employers to offer follow-up procedures to good Samaritans, even if the individual did not have occupational exposure.
OSHA has also said that good Samaritans are not covered even if they respond to a work-related injury. Coverage under the regulation is not based on the type of injury (whether a nose bleed or a work-related injury) but rather depends on whether an employee is expected to render assistance as part of his or her job duties.
The term "occupational exposure" means a reasonable anticipation that the employee will come into contact with blood or other potentially infectious material during the course of performing his or her work duties. The key issue is not whether employees have been trained in first aid, but whether they are also designated as responsible for rendering medical assistance.
For instance, many workers may be trained in first aid and CPR, but not all workers would necessarily be designated to render first aid. The standard does not apply to employees who are not expected or required by the employer to actually administer first aid.
If an exposure incident occurs due to employees providing first aid or CPR as good Samaritans, should the employer pay for testing and keep a record of the exposure?
OSHA says that if an employee has an exposure incident while acting as a good Samaritan, the employer is not required to provide the HBV vaccination series, post-exposure evaluation, follow-up procedures, or any other protections of the standard. However, OSHA encourages employers to do so. If you aren’t sure how your company would respond to a good Samaritan exposure, you may want to consider your response before a good Samaritan exposure occurs.
And while you're thinking about that, consider training employees to protect themselves from hazards, even if they aren't expected to provide assistance to fellow employees.
If you have employees covered by the bloodborne pathogen standard, you must create a written safety plan. In fact, quite a few OSHA regulations require written plans. Fortunately, creating and updating them is easier with the J. J. Keller® SAFETY MANAGEMENT SUITE. You'll find 120+ pre-written safety plan templates for OSHA, EPA and DOT. Just choose your topic, fill out the form and in minutes you’ll have a comprehensive written plan that’s built for your business.