Duraclean Journal of Marketing, Management and Technical Topics

OSHA's BBP Standard: Your Questions Answered




The following article is a condensation from the "Safety News Alert" newsletter from BLR (http://www.blr.com). It provides information on OSHA’s bloodborne pathogen standard that applies to all “reasonably anticipated” contact with blood (or other potentially infectious materials) that may result from the performance of an employee’s duties.


Many OSHA standards raise compliance questions, and the bloodborne pathogen (BBP) standard is no exception. BLR selected a few of those questions that BLR® customers have asked the safety experts at our sister website Safety.BLR.com®.

Q. Does OSHA’s BBP standard apply to all personnel with first-aid training?
A. Employees who are designated to provide first aid as a primary or collateral duty are covered by the BBP standard. An employee who voluntarily performs a "good Samaritan act" is not covered, however, because that is not considered an occupational, or work-related, exposure.

Q. What OSHA regulations govern the disposal of biohazard -contaminated material once it has been placed in an approved biohazard plastic bag? How do we throw away a used biohazard bag?
A. OSHA’s BBP standard states: "Disposal of all regulated waste shall be in accordance with applicable regulations of the United States, States and Territories, and political subdivisions of States and Territories" [CFR 29 1910.1030(d)(4)(iii)(C)].

Biohazard disposal is usually regulated by state departments of environmental protection. You should check with your state DEP.

Q. Would individuals designated for cleanup of blood on the shop floor and equipment be covered by the BBP standard?
A. While OSHA does not generally consider maintenance personnel and janitorial staff employed in nonhealthcare facilities to have occupational exposure, it is the employer’s responsibility to determine which job classifications or specific tasks and procedures involve occupational exposure.

For example, OSHA expects products such as discarded sanitary napkins to be discarded into waste containers that are lined in such a way as to prevent contact with the contents. But at the same time, the employer must determine if employees can come into contact with blood during the normal handling of such products from initial pickup through disposal in the outgoing trash. If OSHA determines, on a case-by-case basis, that sufficient evidence of reasonably anticipated exposure exists, the employer will be held responsible for providing the protections of the BBP standard to the employees with occupational exposure.

Q. What are the requirements for disposal of rags soaked with blood?
A. Regulated waste such as rags soaked in blood must be placed in containers that are:

• Constructed to contain all contents and prevent leakage of fluids during handling, storage, transport, or shipping;
• Labeled or color-coded in accordance with paragraph 1910.1030(g)(1)(i) of the standard;
• Closed before removal to prevent spillage or protrusion of contents during handling, storage, transport, or shipping.

If outside contamination of the regulated waste container occurs, it must be placed in a second container that also meets these requirements.

Q. Are disposable razors considered sharps?
A. If the razor was contaminated with another person’s blood and an employee got cut on it, it would be covered under the BBP standard (29 CFR 1910.1030).

Q. Who must be trained under the BBP standard and what is the frequency of training?
A. Anyone who has the potential for occupational exposure as defined below needs to be trained. Assuming this is not a healthcare facility, this would include designated first responders to medical emergencies in the workplace.

“Occupational exposure” means reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee’s duties.

Training shall be provided as follows:

• 1910.1030(g)(2)(ii)(A)-(C): At the time of initial assignment to tasks where occupational exposure may take place and at least annually thereafter.
• 1910.1030(g)(2)(v): Employers shall provide additional training when changes such as modification of tasks or procedures or institution of new tasks or procedures affect the employee’s occupational exposure. The additional training may be limited to addressing the new exposures created.

Labels: Bloodborne Pathogens, Safety Compliance, Safety Management