Frequently Asked Questions: Bloodborne Pathogens Standard (Part 3)
The purpose of this blog post is to provide answers to some of the more commonly asked questions related to the Bloodborne Pathogens standard. It is not intended to be used as a substitute for the standard’s requirements. Please refer to the standard for the complete text.
Methods of Control
Universal Precautions
Q1. What is meant by the term Universal Precautions?
A1. Universal Precautions is OSHA’s required method of control to protect employees from exposure to all human blood and OPIM. The term, “Universal Precautions,” refers to a concept of bloodborne disease control which requires that all human blood and certain human body fluids be treated as if known to be infectious for HIV, HBV or other bloodborne pathogens.
Q2. Can Body Substance Isolation (BSI) be adopted in place of Universal Precautions?
A2. Yes. Body Substance Isolation is a control method that defines all body fluids and substances as infectious. BSI incorporates not only the fluids and materials covered by the standard but expands coverage to include all body substances. BSI is an acceptable alternative to Universal Precautions, provided facilities utilizing BSI adhere to all other provisions of the standard.
Engineering Controls
Q3. What are engineering controls?
A3. The term, “engineering controls,” refers to controls (e.g., sharps disposal containers, self-sheathing needles, safer medical devices, such as sharps with engineered sharps injury protections and needleless systems) that isolate or remove the bloodborne pathogens hazard from the workplace.
Q4. What are some examples of safer devices or alternatives that could be used in lieu of exposed needles?
A4. Some examples of such devices or alternatives include needleless systems, needle-protected systems, and “self-sheathing” needles.
Q5. Are employers required to provide these safer devices?
A5. The standard requires that engineering and work practice controls be used to eliminate or minimize employee exposure. The Exposure Control Plan must document annual consideration and implementation of appropriate, commercially-available and effective engineering controls designed to eliminate or minimize exposure. The employer must solicit and document for this process input from non-managerial employees responsible for direct patient care who are potentially exposed to injuries from contaminated sharps.
Q6. Is recapping of needles allowed?
A6. Bending, recapping, or removing contaminated needles is prohibited, except under certain circumstances. When the employer can demonstrate that bending, removal or recapping is required by a specific medical or dental procedure or that no alternative is feasible, such actions are permitted. However, such actions must be accomplished by some method other than the traditional two-handed procedure (e.g., a mechanical device or a one hand scoop method). For example, these actions may be necessary when performing blood gas analyses; when inoculating a blood culture bottle; or when administering incremental doses of a medication to the same patient. Where no alternative to bending, recapping, or removing contaminated needles is feasible or such action is required by a specific medical or dental procedure there must be a written justification to that effect included as part of the exposure control plan. On the basis of reliable evidence, this justification must state the reason for the employer’s determination that no alternative is feasible or must specify that a particular medical or dental procedure requires, for example, the bending of the needle and the use of forceps to accomplish this task. Shearing or breaking contaminated needles is completely prohibited by the standard.
Q7. How should reusable sharps (e.g., large bore needles, scalpels, saws, etc.) be handled?
A7. Reusable sharps must be placed in containers which are puncture-resistant, leakproof on the sides and bottom, and properly labeled or color-coded until they are reprocessed. Contaminated reusable sharps must not be stored or reprocessed in a manner that would require the employee to reach by hand into containers.
Are you concerned that your facility does not have a kit designed for OSHA’s Bloodborne Pathogens Standard? This kit is designed to help in OSHA Standard Compliance (1910.1030) and combines personal protection and clean-up items mandated by OSHA, CDC, and State Health Departments to aid in the clean-up, transportation, and disposal of potentially infectious blood or body fluid spills.
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Disclaimer
The information contained is this document is not considered a substitute for any provisions of the Occupational Safety and Health Act of 1970 (OSH Act) or the requirements of 29 CFR 1910.1030, Occupational Exposure to Bloodborne Pathogens.