Meeting OSHA's Bloodborne Pathogen Standard and protecting your employees

Date Published: 
January, 2006
Original Author: 
Shannon DeCamp
TechneTrain Inc., Cincinnati, Ohio
Original Publication: 
ICFM Magazine, January 2006

Of course embalmers need to be wary of bloodborne pathogens, but they're not the only ones in your funeral home, crematory or cemetery who might face exposure. Make sure your employees—and your company—are protected.

Exposure to bloodborne pathogens is a significant risk to employees of the cemetery, funeral and crematory professions. Violations of OSHA's Bloodborne Pathogens Standard were the most prevalent citation in the profession in 2004. While OSHA citations are infrequent relative to other industries, the last thing you want is this type of notoriety when your goal is to offer your clients competence, caring and peace of mind.

While staff who handle bodies for funeral or cremation are likely have expertise and extensive background in mortuary science, and hence a good understanding of the risks and methods of controlling exposure to bloodborne pathogens, you may have ancillary employees who don't have knowledge and training but may directly or inadvertently come into contact with body fluids at your facility.

Your custodial staff, florists, drivers and designated first aide responders might all fall into this category. Do you ever hire a beautician to do hair or ask a yard worker to help lift a body? Add them to the list.

OSHA's Bloodborne Pathogens Standard (general industry standard 29 CFR 1910.1030) details the specific requirements for your facility's exposure control program and your obligations to all employees with occupational exposure.

Let's start by reviewing the basics of the Bloodborne Pathogens Standard to ensure that your business is meeting OSHA requirements.

Bloodborne Pathogen Standard
Bloodborne pathogens are viruses and bacteria in human blood that can cause disease in humans, including the Hepatitis B and C viruses and the human immunodeficiency virus, or HIV.  Workers exposed to these pathogens risk serious illness. The HIV will survive for only a few days in a body; but Hepatitis B is a relatively common infectious disease that is potentially present in the body of any individual being prepared for burial or cremation and can survive for 30 days or more.

Since medical histories and examinations cannot accurately detect all patients infected with pathogenic agents, universal blood and body fluid precautions should always be used.

The Occupational Safety and Health Administration standard was established in 1991 to eliminate or minimize occupational exposure to Hepatitis B virus, HIV and other bloodborne pathogens. The agency concluded that exposure to these pathogens can be minimized or eliminated using a combination of engineering and work practice controls, personal protective clothing and equipment, training, medical surveillance, Hepatitis B vaccination, signs and labels and other provisions.

The key elements of the Bloodborne Pathogen Standard are:

• Exposure determination. Assess the risks of exposure to bloodborne pathogens (generally in the form of potential contact with body fluids) that employees may encounter at their work place. List the tasks and locations where this contact can occur (i.e., cleaning out the refrigerated storage area).

• Written exposure control plan. Establish written policies for protecting employees against exposure to bloodborne pathogens as they complete these tasks.

• Engineering and work practice controls. Establish and regularly update engineering and work practice controls that will control employee exposure.

• Labels and signs. Use required labels and signs to caution employees where exposure risks exist. This does not include public spaces such as crypts or viewing rooms.

• Personal protective equipment. Provide appropriate personal protective equipment to shield employees from exposure risks.

• Employee information and training. Inform employees about the risks identified. Train employees on your specific program to minimize or eliminate the risks associated with exposure to blood borne pathogens.

• Vaccinations. Provide Hepatitis B vaccinations at no cost to any employees who will potentially be exposed as a part of their job.

• Post-exposure follow-up. When an employee is exposed, the employer must provide a no-cost medical evaluation.

• Recordkeeping. Maintain records of employee training, as well as of injuries and accidents related to any bloodborne pathogen exposure in the workplace.

The standard stresses the need to use "universal precautions" in dealing with exposure to potential bloodborne pathogens in the work environment. This means operating under the assumption that any contact with blood or body fluids may result in a potential exposure to bloodborne pathogens—regardless of the diagnosed condition of the source of the blood or body fluids.

Now let's discuss what exactly is involved in meeting the OSHA standard.

1. Exposure determination
Each employer must prepare an exposure determination that lists any and all job classifications in which employees have occupational exposure, and lists all tasks and procedures where occupational exposure can occur. (The fact that your embalmers wear protective gear which protects them during exposure does not mean you can declare that your embalmers are not exposed to bloodborne pathogens.)

2. Written exposure control program
Whenever any employee's anticipated duties may result in occupational exposure to bloodborne pathogens, the employer must establish a written Exposure Control Plan to minimize or eliminate exposure.  The plan must be designed around the concept of universal blood and body fluid precautions. This written Exposure Control Plan must contain at least the following elements:

• An exposure determination (see # 1).
• The schedule and method of exposure control.
• The procedure for evaluating circumstances surrounding exposure incidents.

Employers must ensure that employees have access to a copy of the Exposure Control Plan. This plan must be reviewed and updated at least annually, or whenever new or modified tasks and procedures affect occupational exposure.

3. Engineering and work practice controls
Engineering and work practice controls must be used to eliminate or minimize employee exposure. Where occupational exposure remains after institution of these controls, personal protective equipment must also be used. Engineering controls must be examined, and maintained or replaced, on a regular schedule to ensure their effectiveness. Examples of engineering controls include:

• Establishing needle-handling and disposal procedures.
• Prohibiting eating, drinking, smoking, applying of cosmetics or lip balm and handling of contact lenses where there is a reasonable likelihood of occupational exposure.
• Performing procedures involving blood or other potentially infectious material in a way that minimizes splashing, spraying, spattering and generation of droplets of these substances.
• Placing appropriate labels and signs in the work area.
• Cleaning and straightening areas where bodies are stored or prepared for burial.
• Providing hand-washing facilities.

4. Labels and signs
Appropriate warning labels must be affixed to containers of regulated waste, refrigerators and freezers that contain blood or other potentially infectious material, and other containers used to store, transport or ship blood or other potentially infectious materials.

5. Personal protective equipment.
When there is occupational exposure, the employer must provide, at no cost to the employee, appropriate personal protective equipment. This could include:
• gloves,
• gowns,
• shoo covers,
• laboratory coats,
• face shields or masks and
• eye protection.

Some jobs may require only gloves and eye protection, while others may require a gown, face shield, shoe covers and gloves for full body protection. Personal protective equipment is considered "appropriate" only if it does not permit blond or other potentially infectious materials to pass through to or reach the employee's work clothes, street clothes, undergarments, skin, eyes, mouth or other mucous membranes under normal conditions of use for as long as the protective equipment will be used.

The employer must ensure that the proper personal protective equipment, in the appropriate sizes, is readily accessible at the work site, or is issued to employees. Hypoallergenic gloves, glove liners, powderless gloves or other similar alternatives must be readily accessible to employees who are allergic to the gloves normally provided. The employer must dean, launder, repair or replace all required personal protective equipment as needed to maintain its effectiveness, at no cost to employees.

6. Employee information and training
Employers must ensure that all employees with occupational exposure participate in a training program, which must be provided at no cost to employees and rake place during working hours. Training must be provided at the time of initial assignment to tasks where occupational exposure may rake place, and at least annually thereafter.

Employers must provide additional training when changes in tasks or procedures affect an employee's occupational exposure. Training must be appropriate to the education level, literacy and language of each employee.

The minimum training program requirements include:
• an accessible copy of the regulatory text of OSHA's Bloodborne Pathogens Standard, and an explanation of its contents;
• a general explanation of the epidemiology and symptoms of bloodborne diseases;
• an explanation of your Exposure Control Plan, and information on how employees can obtain a written copy of the plan;
• an explanation of the appropriate methods for recognizing tasks and other activities that may involve exposure to blood and other potentially infectious materials;
• an explanation of the various methods— and their limitations—that can be used to prevent or reduce exposure, including engineering controls, work practices and personal protective equipment;
• information on the types, proper use, location, removal, handling, decontamination and disposal of personal protective equipment;
• an explanation about how to select personal protective equipment;
• information on the Hepatitis B vaccine;
• information on the procedures to be followed when any exposure to blood or body fluids occurs;
• an explanation of the signs, labels and color-coding required to identify hazards; and
• an opportunity for employees to ask questions of the person conducting the training session.

The person conducting the training must be knowledgeable in the subject matter as it relates to the workplace, and be able to answer any employee questions.

7. Vaccinations
Hepatitis B vaccination. The employer must make the hepatitis B vaccine and vaccination series available to all employees who have potential occupational exposure within 10 working days of their initial assignment, at no cost to the employees and at a reasonable time and place. These vaccinations must be performed by or under the supervision of a licensed physician or another licensed health care professional according to the recommendations of the U.S. Public Health Service current at the time that these evaluations and procedures take place.

8. Post-exposure evaluation and follow-up
Following a report of an exposure incident, the employer must immediately make available a confidential medical evaluation and follow-up, at no cost to the employee.

This follow-up must include the identification and documentation of the individual who was the source of the material to which the employee was exposed, unless the employer can establish that identification is not feasible or prohibited by state or local law.

The employer must ensure that all laboratory tests are conducted by an accredited laboratory at no cost to the employee. The employer must obtain and provide the employee with a copy of the evaluating health care professional's written opinion within 15 days of the completion of the evaluation.

9. Recordkeeping
The employer must establish and maintain an accurate record for each employee with occupational exposure, in accordance with 29 CFR 1910.20. Training records must be maintained for three years from the date on which the training occurs.