vvEPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
Publication 9360.0-31/FS
August 1993
The Effect of OSHA's Bloodborne
Pathogens Standard on Hazardous Waste
Cleanup Activities
Office of Emergency and Remedial Response
Emergency Response Division MS-101
Quick Reference Fact Sheet
INTRODUCTION
On December 6, 1991, the
Occupational Safety and
Health Administration
(OSHA) promulgated the
Bloodborne Pathogens Stan-
dard at 29 CFR 1910.1030
(56 FR 64004), which is
designed to protect employees . (primarily
healthcare workers) whose jobs place them at
risk of exposure to blood and other potentially
infectious materials. Bloodborne pathogens
are microorganisms that are present in human
blood and can cause disease in humans. These
pathogens include, but are not limited to,
hepatitis B virus (HBV) and human immuno-
deficiency virus (HIV). In addition to
healthcare workers, the standard also may
affect workers who handle waste potentially
contaminated with blood or other potentially
infectious material during response actions at
uncontrolled hazardous waste sites.
The purpose of this Fact Sheet is to
describe the additional planning, training, and
friedical surveillance requirements that the new
OSHA standard on bloqdborne pathogens
imposes upon On-Scene Coordinators (OSCs)
;mil Remedial Project Managers (RPMs)
during a Superfund response action. The
requirements described.in this Fact.Sheet are
in addition to the requirements specified in 29
CFR 1910.120 (HAZWOPER). For a sum-
mary of applicable HAZWOPER requirements
for response actions at uncontrolled hazardous
waste sites, see Hazardous Waste Operations
and Emergency Response: Uncontrolled
Hazardous Waste Sites and RCRA Corrective
Actions, Publication 9285.2-08FS, available
from EPA/ERT, 2890 Woodbridge Ave.,
Building 18 (MS-101), Edison, NJ 08837-3679,
(908)321-6740.
Office of Solid Waste and Emergency
Response (OSWER) employees may be
covered by OSHA's Bloodborne Pathogens
Standard primarily during three field situations:
(1) Cleanup of a hazardous waste site
containing infectious waste, especially
those employees with collateral first-aid
responder duties (operations covered by
29 CFR 1910.120(b) - (o));
(2) Operation of a RCRA-permitted inciner-
ator that burns infectious waste (opera-
tions covered by 1910.120(p)); and
(3) Response to an infectious waste spill,
such as a transportation accident (opera-
tions covered by 1910.120(q)).
At times the requirements in
HAZWOPER conflict or- overlap with the
Bloodborne Pathogens Standard. In such
situations, a qualified health and safety
professional should determine which provision
is more appropriate. In most situations, the
provision that is more protective of employee
health and- safety would 'apply. Additional
assistance can be obtained from EPA's
Environmental Response Team in Edison,
New Jersey (see the section of this Fact Sheet
entitled "Contacts" for the address and
telephone number).
Recycled/Recyclable
Printed with Soy/Canola Ink on paper that
contains at toast 50% recycled fiber
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Both the HAZWOPER regulations and
the Bloodborne Pathogen Standard require
employers to provide written programs (e.g., a
health and safety plan or HASP, exposure
control, etc.), safety training, medical
surveillance, and protective clothing and equip-
ment. Each of these areas is discussed below.
HEALTH AND SAFETY PLANS
Under the Bloodborne
Pathogens Standard, EPA is
required to develop an
Exposure Control Plan that
is designed to minimize
occupational exposure to
bloodborne pathogens. The
Standard defines occupational exposure as
"reasonably anticipated skin, eye, mucous
membrane, or parenteral contact with blood or
other potentially infectious materials that may
result from the performance of an employee's
duties." Each Region also must develop an
Exposure Control Plan based on the more
general EPA plan developed by the Safety,
Health, and Environmental Management
Division (SHEMD), but reflecting any Region-
specific and site-specific hazards. The
Exposure Control Plan must contain the
following relevant elements:
• An exposure determination, which must
contain a list of all job classifications in
which some or all employees have
occupational exposure, and a list of all
tasks and procedures where
occupational exposure may occur within
these job classifications;
• Schedule and implementation methods
for: engineering and work practice
controls, personal protective
equipment, housekeeping, hepatitis B
vaccination and post-exposure
evaluation and follow-up,
communication of hazards to
employees, and recordkeeping; and
• Procedures for the evaluation ot
circumstances surrounding exposure
incidents.
The Exposure Control Plan may be
incorporated into existing programs or plans,
such as the site-specific HASP or an
emergency response plan, or treated as a
separate document. If it is incorporated into
existing documents, however, the additional
elements noted above must be explicitly
addressed in the parent document.
The OSHA Compliance Directive
reference for this standard may be found at
OSHA Instruction CPL 2-2.44B, which
contains information that may prove useful
when developing Exposure Control Plans. For
additional information, see the section of this
Fact Sheet entitled "References."
TRAINING
The Bloodborne Pathogens
Standard at 29 CFR
1910.1030(g)(2) requires
training for individuals who
have the potential to be
exposed to bloodborne
pathogens in the workplace.
Effective training is a critical element of any
overall exposure control program and will help
reduce the risk of occupational exposure,
consequently reducing exposure-related
infections. Many of the training requirements
are similar to those in HAZWOPER, although
a few additional requirements are specified in
the Bloodborne Pathogens Standard. Those
training elements that are not already covered
by HAZWOPER should be included in
training programs if employees are likely to be
exposed to bloodborne pathogens. The
Bloodborne Pathogens Standard requires
annual training for employees, just as the
HAZWOPER requires 8-hour refresher
training. The additional training elements
required under the Bloodborne Pathogens
Standard are shown in Figure 1.
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FIGURE 1
Additional Training Elements Covered
by the Bloodborne Pathogens Standard
29 CFR 1910.1030(g)(2)(vii) specifies
certain training elements not covered in
HAZWOPER:1
• An explanation of the epidemiology
and symptoms of bloodborne diseases;
• An explanation of the modes of
transmission of bloodborne pathogens;
• An explanation of the employer's
exposure control plan and the means by
which the employee can obtain a copy
of the written plan;
• An explanation of methods for
recognizing tasks and other activities
that may involve exposure to blood or
other potentially infectious materials;
• Information on the hepatitis B vaccine;
• Information on the appropriate actions
to take and persons to contact in an
emergency involving blood or other
potentially infectious materials;
• An explanation of the procedure to
follow if an exposure incident occurs,
including the method of reporting the
incident and the medical follow-up that
will be made available;
• Information on the post-exposure
evaluation and follow-up that the
employer is required to provide for the
employee following an exposure
incident;
• An explanation of the signs and labels
and/or color coding required to identify
bloodborne pathogen hazards; and
• An opportunity for interactive
questions and answers with the person
conducting the training session.
1 Training elements addressing PPE under 29
CFR 1910.1030(g)(2)(vii) are covered under 29
CFR 1910.120.
PERSONAL PROTECTIVE
EQUIPMENT (PPE)
The Bloodborne Pathogens
Standard at 29 CFR
I910.1030(d)(3) specifies
that masks, in combination
with eye protection devices,
such as goggles or glasses
with solid side shields, or
chin-length face shields,
must be worn whenever a
splash, spray, spatter, or
drops of blood or other
potentially infectious
materials may be generated
and eye, nose, or mouth contamination can be
reasonably anticipated.
In addition, appropriate protective
clothing (including, but not limited to, gowns,
aprons, lab coats, clinic jackets, or similar
outer garments) must be worn in occupational
exposure situations. The type of PPE that is
appropriate in a given situation will depend
upon the task and anticipated degree of
exposure potential to bloodborne pathogens.
HAZWOPER PPE Levels A through C
should be effective in protecting a worker
from exposure to bloodborne pathogens. In
instances where level C or higher is not being
worn, it may be prudent to use double gloves.
Gloves are an important element of PPE
when bloodborne pathogens may be present.
• Gloves must be worn when the
employee may have hand contact with
blood and other potentially infectious
materials.
• When contaminated or damaged,
disposable gloves must be replaced as
soon as possible and should not be
reused.
• Utility gloves may be decontaminated
for re-use if the gloves are not
damaged.
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In extremely rare instances, such as
unexpected medical emergencies, employees
may not be able to put on gloves, gowns, or
face masks. In these types of rare situations,
where some leeway must be allowed,
employees must still be cognizant of the
underlying concept of universal precautions
(i.e., all blood and body fluids should be
treated as if they are infectious). However, as
stated at 29 CFR 1910.1030(d), normal
operations would dictate that, "The employer
shall ensure that the employee uses
appropriate personal protective equipment
unless the employer shows that the employee
temporarily and briefly declined to use
personal protective equipment when, under
rare and extraordinary circumstances, it was
the employee's professional judgement that in
the specific instance its use would have
prevented the delivery of health care or public
safety services or would have posed an
increased hazard to the safety of the worker or
co-worker. When the employee makes this
judgement, the circumstances shall be
investigated and documented in order to
determine whether charges can be instituted to
prevent such occurrences in the future." It is
worth noting that should an exposure occur
while an employee is wearing a level of
protective clothing, decontamination may need
to be modified to include agents (e.g.,
disinfectant) other than the traditional soap
and water.
MEDICAL SURVEILLANCE
The Bloodborne Pathogens
Standard at 29 CFR
1910.1030(f)(l) provides
several additional require-
ments that are applicable
when employees are
exposed to bloodborne
pathogens. First, the hepatitis B vaccine and
vaccination series must be made available at
no cost to all employees who have
occupational exposure, or the potential for
exposure (e.g., first-aid responders as a
collateral duty on a hazardous waste site), and
there must be post-exposure evaluations and
follow-ups for all employees who have had an
exposure incident. The vaccine must be
available after training is complete and within
10 working days of the initial assignment to all
employees who have occupational exposure.
Declining the pre-exposure shot must be done
in writing, as required by the Bloodborne
Pathogens Standard at 29 CFR 1910.1030
(f)(2)(iv), with the understanding that it is still
available at a later date.
Second, there are specific reporting
requirements when there is an exposure
incident. An "exposure incident" is defined at
29 CFR 1910.1030(b) as "a specific eye,
mouth, other mucous membrane, non-intact
skin, or parenteral contact with blood or other
potentially infectious materials that results
from the performance of an employee's
duties." Following the report of an exposure
incident, the employer must make a con-
fidential medical evaluation and follow-up
immediately available to the exposed
employee. Evaluation and follow-up must
include:
• Identification of the route(s) of
exposure and the circumstances under
which the exposure incident occurred;
• Identification and documentation of the
source individual, unless identification
is infeasible or prohibited by state or
local law;
• Collection, documentation, and testing
of blood for HBV and HIV serological
status (source individual's blood must
be tested and results made available to
the exposed employee, even if source
individual cannot be identified).
Specifics can be found at 29 CFR
1910.1030 (f)(3)(ii) and (f)(3)(iii);
• Post-exposure prophylaxis;
• Counseling; and
• Evaluation of reported illnesses.
Finally, medical records must be kept for
each employee with occupational exposure.
These records should include a copy of: the
status and dates of the employee's hepatitis B
vaccination: all examination and medical test
results, and specifications of follow-up pro-
cedures; the healthcare professional's written
opinion; and a copy of the written information
provided by the employer to the healthcare
professional.
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CONCLUSION
The new OSHA standard on bloodborne
pathogens contains requirements for health
and safety planning, training, medical
surveillance, and personal protective equip-
ment. These requirements are in addition to
the HAZWOPER requirements whenever the
HAZWOPER and Bloodborne Pathogens
standard overlap. Blood and other potentially
infectious material should always be treated as
if they are infectious; the hepatitis B virus and
the HIV are extremely serious hazards. The
health and safety requirements specified in this
Fact Sheet are a summary of the minimum
standards that must be followed when there is
occupational exposure to bloodborne
pathogens. Anyone working with waste con-
taminated with blood or other potentially
infectious material should refer to the latest
EPA national and Regional policies, programs,
and Standard Operating Practices.
REFERENCES
Occupational Exposure to Bloodborne
Pathogens, OSHA 3127 (1992).
Occupational Exposure to Bloodborne
Pathogens: Precautions for Emergency
Responders, OSHA 3130 (1992).
CONTACTS
EPA/Environmental Response Team
2890 Woodbridge Avenue
Building 18, Mail Code MS 101
Edison, NJ 08837-3679
(908) 321-6740
EPA/Safety, Health, and Environmental
Management Division (SHEMD)
Mail Code PM 273
401 M Street, SW
Washington, DC 20460
(202) 260-1640 or (202) 260-1647
Occupational Safety and Health
Administration
200 Constitution Avenue, NW
Room N-3647
Washington, DC 20210
(202) 219-8036
OSHA Notification Service (Complaint
Hotline) for Emergency Situations
1-800-321-6742
OSHA Publications Office
200 Constitution Avenue, NW
Room N-3101
Washington, DC 20210
(202) 219-4667
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OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION
REGIONAL OFFICES
Region I (CT, MA, ME, NH, RI, VT)
133 Portland Street, 1st Floor
Boston, MA 12114
(617) 565-7164
Region II (NJ, NY, PR, VI)
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New York, NY 10014
(212) 337-2378
Region III
(DC, DE, MD, PA, VA, WV)
Gateway Building, Suite 2100
3535 Market Street
Philadelphia, PA 19104
(215) 596-1201
Region IV
(AL, FL, GA, KY, MS, NC, SC, TN)
1375 Peachtree Street, NE
Suite 587
Atlanta, GA 30367
(404) 347-3573
Region V (IL, IN, MI, MN, OH, WI)
230 South Dearborn Street,
Room 3244
Chicago, IL 60604
(312) 353-2220
Region VI (AR, LA, NM, OK, TX)
525 Griffin Street, Room 602
Dallas, TX 75202
(214) 767-4731
Region VII (IA KS, MO, NE)
911 Walnut Street, Room 406
Kansas City, MO 64106
(816) 426-5861
Region VIII
(CO, MT, ND, SD, UT, WY)
Federal Building, Room 1576
1961 Stout Street
Denver, CO 80294
(303) 844-3061
Region IX (American Samoa, AZ, CA,
Guam, HI, NV. Trust Territories of the
Pacific)
71 Stevenson Street, Room 415
San Francisco, CA 94105
(415) 744-6670
Region X (AK, ID, OR, WA)
1111 Third Avenue, Suite 715
Seattle, WA 98101-3212
(206) 553-5930
NOTE: Refer to the Regional Area Office first; call the National Office if your inquiry cannol he
idequately addressed.)
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