Compliance

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).

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