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It happens more times than I care to admit. I’m teaching an OSHA 30 hour class or
conducting a mock-OSHA inspection and we are covering the topic of OSHA’s
Bloodborne Pathogens (BBP) standard. Someone participating in the audit or attending
the class says “Everybody at our facility is covered by the OSHA Bloodborne
Pathogens standard”. Or, conversely, someone will say “Not a single person at
our facility is covered by this standard”.
More times than not, neither statement is true.
Inclusion in an OSHA-compliant BBP program is
based on one thing; an employee has “occupation exposure” to blood or some other
potentially infectious material. The key is to understand the . . .
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Curtis, I think the number of people who truly have occupational exposure to BBP has been greatly overestimated by OSHA inspectors and by the regulated community. One reason I think this is the phrase "reasonably anticipated" used by OSHA when describing who is exposed occupationally and who's not. OSHA is famously wishy-washy about it, but I think the idea was supposed to be that low-exposure jobs were not supposed to be covered. For example, retail clothing store manager. In retail stores, the employees and customers may go for years between laceration injuries. If a customer cuts her hand on a chip in a display case, I think OSHA allows the store manager to clean it up, as long as that store manager is trained on how to clean up blood safely. However, the manager is outside the scope of the BBP rules as no reasonable person would anticipate blood in the store, or occupational exposure to it. No annual training, no exposure control plan, no Hep-B vaccinations, etc., would be needed.
ReplyDeleteThis agrees with what one of the OSHA National Office people told me, but if you look at enough OSHA BBP citations it is clear the inspectors think any exposure to any blood ever means the employer must comply with full BBP rules.
I'd love to see what you think of this.