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OSHA's Bloodborne Pathogens Standard and AT Reuse

OSHA and Bloodborne Pathogens Standard

In 1992, the Occupational Safety and Health Administration (OSHA) issued the Bloodborne Pathogen Standard (29 CFR 1910.1030), which applies to all occupational exposures to blood and other potentially infectious material and the occupational handling of regulated waste.  The danger from regulated waste is not limited to the healthcare industry as it could affect employees in many different occupations.  OSHA has tied the regulation to potential occupational exposures in order to protect all employees at risk in their work environment, regardless of their job title or place of employment.  In doing so, OSHA has placed the responsibility to determine the existence of occupational exposures to regulated waste within a work environment squarely on the employers.  Employers must assess this threat and comply with the OSHA standards to the extent that the workplace falls under the scope of the regulations. 

For AT Reutilization programs, the type and nature of equipment that passes through the program for reutilization *might* place employees at a risk for occupational exposures to blood and other potentially infectious material.  There are several relevant definitions AT Programs should use to assess the applicability of the standard to a work environment.  The key definitions are:

·         Regulated Waste means liquid or semi-liquid blood or other potentially infectious materials; contaminated items that would release blood or other potentially infectious materials in a liquid or semi-liquid state if compressed; items that are caked with dried blood or other potentially infectious materials and are capable of releasing these materials during handling; contaminated sharps; and pathological and microbiological wastes containing blood or other potentially infectious materials.

 

·         Blood means human blood, human blood components, and products made from human blood.

 

·         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; (2) Any unfixed tissue or organ (other than intact skin) from a human (living or dead); and (3) HIV-containing cell or tissue cultures, organ cultures, and HIV- or HBV-containing culture medium or other solutions; and blood, organs, or other tissues from experimental animals infected with HIV or HBV.

 

·         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.

The full standard (and some helpful resources) may be found online at:  http://www.envcap.org/rmw/osha-bps.cfm#defs.  Each AT Reuse Program should determine if the products they handle contain regulated waste.  It is important to note that the determination is not based on actual volume of blood, but rather the potential to release blood or other potentially infectious materials.  OSHA does provide some guidelines to help assess whether the materials handled in a workplace are deemed “blood or other potentially infectious materials.”  Body waste products such as urine and feces without blood are not considered regulated waste.  Similarly, discarded dressings, gauze and cotton balls with a small amount of dried blood or other body fluids (not saturated), and feminine hygiene products would not be considered regulated waste.  Beyond these guidelines, however, each employer must make an assessment that is specific to their work environment. 

 

AT Reuse programs should consider whether any of the parts and materials they accept (particularly from DME that interacts with blood and other potentially infectious materials), pose an occupational exposure risk to employees.  Based on the OSHA guidance, items such as hospital beds, wheelchairs, canes and walkers are unlikely to be deemed regulated waste.  These items, while possibly containing some degree of blood or other potentially infectious materials, seem to contain such trace amounts of these materials that they could likely be compared to bandages and discarded feminine hygiene products.  A trickier evaluation could apply to commodes, as these devices do come into direct contact with bodily fluids.  In most cases, commodes are only exposed to urine and feces without blood; however it is possible that some commode users could have blood in their urine or feces.   Each facility should assess whether they feel there is a potential occupational exposure in the absence of any direct or obvious evidence of the presence of blood.

If an AT Reuse program determines that they do handle regulated waste, then that program would be required to develop and follow a plan, along with proper storage, handling, washing, sanitization and disposal guidelines for the regulated waste.  Here is a link to an excellent resource outlining the basics for proper handling of regulated waste:  http://schools.nyc.gov/NR/rdonlyres/DC34406A-9CF5-4696-9920-5ED581B371C4/0/OOSHBULLETINHANDLINGOFREGULATEDWASTEANDCLEANUPPROTOCOL.pdf . There are also several tips contained in this bulletin that qualify as generally good sanitization practices (such as storage and handwashing and cleanup procedures).

 

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DISCLAIMER

This work is supported under a five-year cooperative agreement # H235V060016 awarded by the U.S. Department of Education, Office of Special Education and Rehabilitative Services, and is administered by the Pass It On Center of the Georgia Department of Labor – Tools for Life.  However, the contents of this publication do not necessarily represent the policy or opinions of the Department of Education, or the Georgia Department of Labor, and the reader should not assume endorsements of this document by the Federal government or the Georgia Department of Labor.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Title: OSHA's Bloodborne Pathogens Standard and AT Reuse
Module: Program Operations
Author: Jessica Brodey
Audience: Administrator
Sub Title: Application of regulations to AT Reuse programs
Procedure: Cleaning used AT devices
Organization Source: Pass It On Center
Last Reviewed: 05-20-2010 2:09 PM