Most all health care practitioners are aware of the Occupational Safety and Health Administration’s (OSHA) role in promoting workplace safety through its Bloodborne Pathogen Standard. This standard, established in 1991, is detailed in 29 CFR 1910.1030 and contains the specific guidelines which outline compliance requirements for any business where some potential exposure to bloodborne pathogens may exist.
Specifically, OSHA’s Bloodborne Pathogen Standard has been designed to provided a level of protection for all employees who have a reasonable probability of some level of contact with blood or other potentially infectious materials through their job duties. The Standard is comprehensive and requires employers to:
- Provide a safe and healthy work environment
- Establish an exposure control plan and update the plan annually
- Implement the use of universal precautions
- Identify and use engineering controls
- Identify and ensure the use of workplace controls
- Provide Personal Protective Equipment including gloves, gowns, eye protection, etc.
- Make hepatitis vaccinations available to all employees with potential for exposure
- Provide post-exposure evaluations and follow-up evaluations as incidents are incurred
- Use labels and signs to communicate specific hazards
- Provide information and training for staff
- Maintain employee training and medical records
While most understand the requirements for annual training that must be completed by all employees with potential exposure, this same standard also communicates requirements for the organization to maintain a specific Exposure Control Plan. OSHA defines requirements for this plan, but at a very high level:
- It must be written specifically for your facility
- It must be reviewed and updated at least yearly (to reflect changes such as new employees positions or technology used to reduce exposures to blood or body fluids)
- It must be be readily available to all workers
This document is also to be separate (or a component of) a larger safety plan for the facility, but must meet these requirements among numerous others which define specific content. Failure for a facility with any level of potential exposure to blood borne pathogens to be able to produce a complete Exposure Control Plan will subject the office to costly fines (up to $12,600) if your are ever audited.
OSHA makes their requirements for Exposure Control Plans readily accessible and even offers examples that can be utilized as templates here.
In addition to Exposure Control Plans, OSHA also requires that facilities maintain a complaint and regularly updated Communication Hazard Program which is outlined in separate statute (29 CFR 1910.1200). The Communication Hazard Program documents how hazards will be identified and communicated among your staff. As is the case with the Exposure Control Plan, failure to maintain this information at your practice could result in fines if your facility is ever inspected by OSHA.
While practitioners have the ability to scour the internet to piece together these required documents, Entech makes it easy for our customers to maintain all required OSHA training and safety plans. We make this resource available through our compliance training platform which, in addition to OSHA specific requirements, offers all required DOT and HIPAA training that is mandated through statue for companies and individuals that have some level of involvement with medical waste.
Entech is the only service provider in Alaska to offer such a resource and, as a service to our customers, we make this system available to free of charge. More information about our compliance solutions can be found here or linked through through the thumbnails below.