Health Care Organizations
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 consideration.
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.