Most employers rarely (if ever) experience a bloodborne pathogen exposure incident. However, many employers designate some workers as first responders, and those workers have the potential for exposure incidents.
Employees should immediately report any exposure incidents to the employer. To do so, however, they need to understand what constitutes an exposure incident. Helping a bleeding coworker does not necessarily create an exposure incident, even if the responder does not wear gloves. Getting a drop of blood on bare skin is not an exposure incident.
An exposure incident involves things like blood or other potentially infectious materials (OPIM) coming in contact with the eye, mouth, or non-intact skin.
Examples of OPIM include any body fluid that is visibly contaminated with blood. However, OPIM does not normally include sweat, urine, vomit, or saliva.
The blood or OPIM also needs a route to transmit infection. For instance, examples of non-intact skin include cuts, abrasions, or chafing that could allow transmission of a bloodborne pathogen. Similarly, if a worker gets cut on broken glass, and another worker cleaning up the contaminated glass also gets cut, that would be an exposure incident.
Hopefully, no employee ever experiences an exposure incident, but employers should create a procedure for how to respond, just in case. Upon getting a report, the employer must make an immediate confidential medical evaluation and follow-up available at no cost to the worker. Employers must also perform a timely evaluation of the incident to prevent a situation from occurring again.
Employers have many other obligations, and OSHA outlines the steps to follow in the regulation. Documenting a process in advance prepares the employer for a prompt response.
Technically, OSHA only requires follow-up for workers with occupational exposure. That term means a reasonable anticipation that the employee could come into contact with blood or OPIM while performing work duties. The key is not whether employees received first aid training, but whether their expected duties (such as assisting injured coworkers) include the potential for exposure.
If a person renders first aid as a good Samaritan, he or she would not fall under the bloodborne pathogen standard, even if they respond to a work-related injury. If a good Samaritan employee has an exposure incident, 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 offer follow-up procedures to good Samaritans.
If you aren’t sure how to respond to an exposure incident (including a possible good Samaritan exposure), you should document the steps to follow before you get a report. In addition, consider training employees to protect themselves from exposure, even if they aren't expected to assist fellow employees. A little information about disease transmission could help employees protect themselves if they voluntarily provide assistance to an injured coworker.
When the need to follow a specific and multi-step procedure won’t arise often, having a documented process to follow is critical to ensuring all steps are taken. The Plans & Policies tool in the J. J. Keller® SAFETY MANAGEMENT SUITE offers numerous plan template that can be modified as needed, including a “Bloodborne pathogens exposure control plan” that can get you started.