3 Questions on the Bloodborne Pathogens Standard
Temporary Staffing Safety
OSHA’s bloodborne pathogens standard isn’t one of the main safety topics that comes to mind for most staffing companies, but if you’re placing employees in positions that may have exposure to blood or other potentially infectious materials (OPIM), it should be one you’re familiar with. Below is a simple breakdown of the bloodborne pathogens standard:
1. What’s the concern with bloodborne pathogens?
While the term “bloodborne pathogens” may seem harmless enough, it’s actually quite dangerous. The most prevalent bloodborne pathogens that are a concern include hepatitis B, hepatitis C and HIV. Each of these are very infectious and often lead to fatal results over time.
2. Who does the bloodborne pathogens standard apply to?
The most common positions affected by this standard are ones in healthcare settings, emergency responders (those expected to administer first aid) and even housekeeping in some settings.
OSHA has said they typically don’t consider maintenance and janitorial staff in non-healthcare settings to have occupational exposure, but it’s possible. For example, if products such as discarded sanitary napkins or used needles have protected disposal methods like lining or engineered containers that prevent contact, there would be no exposure. However, if protections aren’t in place and employees could reasonably come in contact with blood during the pick-up, handling or disposal, this standard could apply. Each position or task should be looked at individually to determine if there’s a reasonable anticipation of contact with blood or OPIM.
3. What’s required from temporary staffing companies who place workers in positions with this exposure?
Temporary staffing companies are required to provide general training including, but not limited to, common bloodborne pathogens, their transmission routes and potential exposures. You must also ensure temporary workers are provided a hepatitis B vaccination within 10 days of their assignment at no cost. If the employee has already received the vaccine, has medical records indicating they’re already immune or has medical documentation that the vaccine may cause them harm, the vaccine doesn’t have to be made available. However, if an employee chooses to decline the vaccination, they must sign Appendix A of the standard and this must be kept on file. If they change their mind at a later date, the vaccine must be provided at no cost.
A staffing company must also provide proper post-exposure evaluations and follow-up after an exposure incident, as well as retain medical and training records as required. For medical records, including the vaccination and any post-exposure evaluations, the required timeframe to keep these records is the duration of employment plus 30 years.
The host employer is responsible for the site-specific training and creation of a written exposure control plan. As always, since these responsibilities can be divided in different ways, it’s recommended the specific responsibilities of each party are clearly defined within the contract before employees are placed. If you have any questions about protecting your temporary employees from bloodborne pathogens, contact a member of the ‘A’ Team.
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