Checklist: Bloodborne Pathogens Standard (29 CFR 1910.1030)

This is the most applicable, most requested and most referenced OSHA standard in medical and dental offices. This standard aims to prevent the spread of bloodborne pathogens, which can result in serious diseases like AIDS and chronic hepatitis. Medical and dental offices often have to deal with situations where splashes of blood-tainted substances may occur, which is inevitable. The Bloodborne Pathogens Standard was established to reduce or prevent harm to workers while they perform their jobs. Here is a sample checklist to help you comply with the Bloodborne Pathogens Standard:

Exposure Control Plan Checklist

• • Have an exposure control plan for each of the following:

List of job classifications in which all employees have occupational exposure. List of job classification in which some employees have occupational exposure. List of all tasks and procedures in which occupational exposure occurs.

• • Identify the following in your exposure control plan:

All universal precautions, plus body substance isolation. Engineering and work practice controls for the following: Hand washing facilities. Sharps handling and disposal

• • Have an exposure control plan for the following situations:

Exposure due to eating, drinking, or applying cosmetics or contact lenses. Exposure within or on refrigerators, freezers and shelves, cabinets, countertops and benches where potentially infectious materials are present. Reducing or preventing splashes, spattering or generation of droplets. Exposure to specimens/evidence with potentially infectious material during collection, handling, processing, storage, transport or shipping.

Elements Checklist

• Personal Protective Equipment (PPE)

Use PPE properly. Have appropriate sizes of PPE readily available and accessible. Have plans for replacement, repair, cleaning and disposal of PPE Have a designated and appropriate container for storing PPE Use PPE that is impervious to fluids and sized appropriately, including, but not limited to, the following: Nitrile or latex gloves Gown or apron for body protection Face shields Masks Eye protection Resuscitation bags Pocket masks with one-way valves Head coverings Shoe coverings

• Housekeeping

Schedule for cleaning and appropriate decontamination of equipment and work surfaces, as well as sharps not disposable as regulated waste (e.g. uncontaminated broken glass or plastics)

• Regulated Waste with Sharps

Have sharps disposal containers that are sealable, puncture resistant, leak-proof and color-coded or labeled Proper placement, handling and installation of sharps disposal containers should be: In easily accessible places Installed to remain upright Replaced routinely and not overfilled Closed prior to moving Placed in a secondary waste container if leakage is likely

• Other Regulated Waste Containment

Place waste in containers that are closable, leak-proof, properly labeled, and closed before removal Place leaking containers into a secondary container.

• Regulated Waste Without Contaminated Sharps

Proper containment of the waste. Disposal of waste in accordance to the state’s environmental enforcement department.

Contaminated Laundry for Offsite Treatment Checklist

Containerize laundry on-scene, in a leak-proof container to minimize handling Appropriate worn PPE, especially gloves Place laundry in labeled bags or containers for sending to offsite facility Train employees in handling bloodborne pathogens contamination Have site-specific decontamination procedures Proper use of tuberculocidal products Worn face masks and gowns (if splashing is anticipated) Worn shoe coverings, whenever a large amount of blood or infectious materials are present Use of EPA-approved tuberculocidal, or 10% bleach in water Washing of linens, laundry and uniforms according to manufacturer’s instructions

Hepatitis B Vaccination Checklist

Provided at no cost to employees Given at a reasonable time or place, and performed by a licensed health professional Lab tests provided at no cost to employees Made available after employees have finished training Vaccination provided within 10 days of assignment Follow OSHA algorithm for hepatitis B vaccination If the employee declines hepatitis B vaccination: Remind the employee that they can receive vaccination at a later time at no cost File a mandatory form for employees who refuses hepatitis B vaccination

• Post-exposure Evaluation and Follow-up

Employers assisted workers in completing an occupational exposure report Followed OSHA algorithm for post-exposure procedures Made all records and forms for post-exposure evaluation confidential

Communication of Hazards Checklist

Properly used and fixed labels on all containers of regulated waste Made sure that the labels are securely attached to containers Used red bags or red containers if labels are not available Placed regulated waste in labeled containers for containment, shipping and disposal Did not use labels or color-coded containers for regulated waste that has been decontaminated

Information and Training of Workers Checklist

Provided training at no cost and during working hours Provided training at the time of initial assignment Made changes to information and training yearly or when appropriate Provided training appropriate for worker’s vocabulary, literacy level and language A training program must contain the following: Regulatory text explaining the Bloodborne Pathogens Standard and its contents Epidemiology and symptoms of bloodborne diseases Explanation of modes of transmission of bloodborne pathogens Explanation of employer’s exposure control plan and where employees can obtain a clear copy Appropriate methods for recognizing tasks or activities that involve exposure to blood or infectious substances Lessons on use and the limitations of PPE, work practices, and engineering controls Information about the hepatitis B vaccine Information regarding steps and actions to take or persons to alert in case of emergency involving infectious materials Procedure for incident reporting and follow-up for exposure incidents Lessons on signs and labeling

• Medical Recordkeeping

Recordkeeping in compliance with 29 CFR 1910.20 Recorded the following information: Name Social Security number Copy of employee’s hepatitis B vaccination status Copy of results of employee’s medical examinations, testing and follow-ups Copy of healthcare professional’s written opinion Copies of all information provided to healthcare professional Records must be maintained for duration of employment plus 30 years

• Exposure and Record Confidentiality

 Employee records made confidential  Employee records not disclosed without employee’s expressed written consent

• Training Records

Included the following information in training records: Dates of training Contents or summary of training session Names and qualification levels of trainers Names and job titles of all persons attending the training Maintain training records for 3 years According to OSHA, this guide only provides the minimum set of standards that address frequently found hazards in medical and dental offices. Many other standards still apply, and it is the employer’s responsibility to follow up and obtain full texts of OSHA standards. All workplaces must display the OSHA poster in places where workers will see it. All standards are available on the OSHA website (www.osha.gov) or by calling toll-free number (800) 321-OSHA (6472).