For medical care organizations and other high-risk occupations the
requirements are much more extensive. In 1991, OSHA issues its final rules on
“Occupational exposure to bloodborne pathogens.” These rules are based on
CDC recommendations that were issued earlier that year. The rules encompass
primary and secondary prevention in three categories of protection.
The primary prevention required is immunization for hepatitis B. In 1991, many
organizations required employees and volunteers to pay for their own
immunizations. For many, the expense was prohibitive. Under the OSHA rules,
the employer must now provide the immunization free of charge to all
employees who may be exposed to blood or body fluids. And, most employees
of a hospital, laboratory or nursing home would be considered at risk. Other
immunizations were not included in the requirement or were not available in
1991. However, given the legal and medical risks of disease transmission, the
immunization program should include Tetanus/diphtheria, measles/
mumps/rubella, hepatitis A, chicken pox, and rabies if animal exposure is a
The second and most expensive requirement is universal precautions. This
protection requires barriers to exposure in all situations where a worker is or
might be exposed to blood, body fluids or other tissue. As with any industrial
exposure, engineering controls such as vent hoods and administrative controls,
such as limiting the number of people exposed should take precedence over
personal protective equipment. However, there is very little that can be done
by engineering or administration. All employees who are at risk of exposure
must be given eye protection, disposable gloves, masks, and clothing as
needed. This must be appropriate for each individual and readily available.
The disposal of contaminated materials is also carefully regulated. Sharps
containers must be available wherever needles or cutting instruments are used.
Labeled containers for not-sharp trash and soiled laundry must also be
available. All of these containers must be changed regularly to prevent
overfilling and disposed of properly.
The third type of prevention included in the rules is care of the individual who
has been exposed to bloodborne pathogens. Needle stick is still the most
common type of exposure, but blood on a cut or mucous membrane exposure
is still a serious problem. Employees with exposure must be provided with an
evaluation by a physician and a written discussion of the medical
recommendations and options. This medical care should include testing,
immunization and/or antiviral drugs as appropriate. The system must be set up
in advance of the need. It is not possible in most medical care institutions, to
produce a knowledgeable physician and all the necessary immunizations and
drugs in the few hours of opportunity that are critical to preventing infection
with HIV or hepatitis.
The regulations also require that all employees be given training in prevention
of bloodborne pathogen exposure. This requirement can be quite easy to
meet. Several commercial training programs can provide all the necessary
training materials and forms for recordkeeping.