Veterinary Compliance Assistance

OSHA Standards for Bloodborne Pathogens

Please read the following note concerning the information presented on this VetCA web page.

The information presented here is reprinted from the Healthcare Environmental Resource Center (HERC), which focuses on human healthcare facilities. As such, it is not directly applicable to veterinary healthcare facilities. The following are excerpts from a 2002 OSHA response to interpretation request for application of the bloodborne pathogens standard to veterinary clinics. Also, see full text.

The standard generally only applies to occupational exposures to human blood, blood components, and other potentially infectious materials (OPIM), unless the blood is known to be infected with the human immunodeficiency virus (HIV) or hepatitis B virus (HBV).

While there may be a potential risk of transmission of bloodborne diseases from animals to humans, it was decided during rulemaking that the general sections of the standard would apply only to human-human exposures, unless the animal blood is used for research and is known to be infected with HIV or HBV.

Because a potential risk exists for the transmission of diseases from animals to humans and because the OSHA standard does not cover all exposures to animal blood, it may be important to employers and employees working in facilities with animals to practice the principles of general industrial hygiene, including the institution of a hierarchy of controls. Standard precautions, good work practices, the implementation of engineering controls, and the use of personal protective equipment are means to prevent occupational exposures to animal blood and OPIM.

In 1991, the Occupational Safety and Health Administration (OSHA) promulgated the Occupational Exposure to Bloodborne Pathogens Standard. The Standard is designed to protect approximately 5.6 million workers in the healthcare and related occupations from the risk of exposure to bloodborne pathogens, such as the Human Immunodeficiency Virus (HIV) and the Hepatitis B Virus (HBV).

The Bloodborne Pathogens Standard has numerous requirements, including the development of an Exposure Control Plan.  The Standard also includes rules specific to certain types of wastes generated at healthcare facilities, termed "regulated waste."  Regulated waste includes blood and items contaminated with blood or other potentially infectious materials (OPIM).  This section of the VetCA Center contains a summary of OSHA Bloodborne Pathogens Standards relating to regulated waste.

  • Definitions
    • What is an Exposure Control Plan
    • What does OSHA mean by the term "regulated waste"?
  • Management of Sharps
    • How should sharps containers be handled?
    • Where should sharps containers be located?
    • What type of container should be purchased to dispose of sharps?
  • Disposal of Regulated Waste
    • How do I dispose of regulated waste?
  • Communication of Hazard to Employees
    • When are labels required?
    • What are the required colors for the labels?
    • Can there be substitutes for the labels?
    • What are the exceptions to the labeling requirement?
    • Does OSHA accept Department of Transportation's (DOT) labels for waste and specimens which will be shipped or transported?
  • Training
    • Which employees must be trained?
    • Should part-time and temporary employees be trained?
    • Who has the responsibility for training workers employed by agencies which provide personnel (e.g., nurses) to other employers?
    • What are the qualifications that a person must possess in order to conduct employee training regarding bloodborne pathogens?
    • Where can information be obtained for conducting training on the Bloodborne Pathogens Standard?
    • Who are some examples of persons who could conduct training on the bloodborne standard?
  • VetCA OSHA State Tool

Definitions

What is an Exposure Control Plan?
The Exposure Control Plan is the employer's written program that outlines the protective measures an employer will take to eliminate or minimize employee exposure to blood and OPIM.

The Exposure Control Plan must contain at a minimum:

  • An exposure determination which identifies job classifications and, in some cases, tasks and procedures where there is occupational exposure to blood and OPIM;
  • Procedures for evaluating the circumstances surrounding an exposure incident; and
  • A schedule of how and when other provisions of the standard will be implemented, including methods of compliance, communication of hazards to employees, and recordkeeping.

What does OSHA mean by the term "regulated waste"?
The Bloodborne Pathogens Standard uses the term, "regulated waste," to refer to the following categories of waste:

  • Blood means human blood, human blood components, and products made from human blood
  • Bloodborne Pathogens means pathogenic 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 immunodeficiency virus (HIV)
  • Liquid or semi-liquid blood or other potentially infectious materials (OPIM)
  • Items contaminated with blood or OPIM and which would release these substances in a liquid or semi-liquid state if compressed
  • Items that are caked with dried blood or OPIM and are capable of releasing these materials during handling
  • Contaminated sharps
  • Pathological and microbiological wastes containing blood or OPIM

It is the employer's responsibility to determine the existence of regulated waste. This determination should not be based on actual volume of blood, but rather on the potential to release blood, (e.g., when compacted in the waste container). If an OSHA inspector determines that sufficient evidence of regulated waste exists, either through observation, (e.g., a pool of liquid in the bottom of a container, dried blood flaking off during handling), or based on employee interviews, citations may be issued.

OSHA has provided some additional guidance for the determination of regulated waste.  OSHA stated that bandages which are not saturated to the point of releasing blood or OPIM if compressed would not be considered as regulated waste.  Similarly, discarded feminine hygiene products do not normally meet the criteria for regulated waste as defined by the standard.  Beyond these guidelines, it is the employer's responsibility to determine the existence of regulated waste.

An OSHA 2002 letter provides “Response to Interpretation Request for Application of the Bloodborne Pathogens Standard to Veterinary Clinics.”


Management of Sharps

How should sharps containers be handled?
Each sharps container must either be labeled with the universal biohazard symbol and the word "biohazard" or be color-coded red.  Sharps containers must be maintained upright throughout use, replaced routinely, and not be allowed to overfill.  Also, the containers must be:

  • Closed immediately prior to removal or replacement to prevent spillage or protrusion of contents during handling, storage, transport, or shipping
  • Placed in a secondary container if leakage is possible. The second container must be:
    • Closable
    • Constructed to contain all contents and prevent leakage during handling, storage, transport, or shipping
    • Labeled or color-coded according to the Standard
  • Reusable containers must not be opened, emptied, or cleaned manually or in any other manner that would expose employees to the risk of percutaneous injury.  
  • Upon closure, duct tape may be used to secure the lid of a sharps container, as long as the tape does not serve as the lid itself.

Where should sharps containers be located?
Sharps containers must be easily accessible to employees and located as close as feasible to the immediate area where sharps are used (e.g., patient care areas).

In areas, such as correctional facilities and psychiatric units, there may be difficulty placing sharps containers in the immediate use area.  If a mobile cart is used in these areas, an alternative would be to lock the sharps container in the cart.

What type of container should be purchased to dispose of sharps?
Sharps containers are made from a variety of products from cardboard to plastic.  As long as they meet the definition of a sharps container (i.e., containers must be closable, puncture resistant, leak proof on sides and bottom, and labeled or color-coded), OSHA would consider them to be of an acceptable composition.

How do I dispose of regulated waste?
Disposal of all regulated waste must be in accordance with applicable state regulations.  These rules are typically published by state environmental agencies and/or state departments of health (Go to VetCA Regulated Medical Waste Locator ).

In addition to state rules for disposing of regulated waste, there are basic OSHA requirements that protect workers.  The OSHA rules state that regulated waste must be placed in containers which are:

  • Closable
  • Constructed to contain all contents and prevent leakage of fluids during handling, storage, transport or shipping
  • Labeled or color-coded in accordance with the standard
  • Closed prior to removal to prevent spillage or protrusion of contents during handling, storage, transport, or shipping
  • If outside contamination of the regulated waste container occurs, it must be placed in a second container meeting the above standards

OSHA has no specific requirement for hospitals or other healthcare facilities to treat (e.g., autoclave) waste before disposal.  Such rules are usually published by state agencies ( Go to VetCA Regulated Medical Waste Locator ).


Communication of Hazard to Employees

When are labels required?
A warning label that includes the universal biohazard symbol, followed by the term "biohazard," must be included on bags/containers of regulated waste , on bags/containers of contaminated laundry, on refrigerators and freezers that are used to store blood or OPIM, and on bags/containers used to store, dispose of, transport, or ship blood or OPIM (e.g., specimen containers).  In addition, contaminated equipment which is to be serviced or shipped must have a readily observable label attached which contains the biohazard symbol and the word "biohazard" along with a statement relating which portions of the equipment remain contaminated

What are the required colors for the labels?
The background must be fluorescent orange or orange-red or predominantly so, with symbols and lettering in a contrasting color. The label must be either an integral part of the container or affixed as close as feasible to the container by a string, wire, adhesive, or other method to prevent its loss or unintentional removal.

Can there be substitutes for the labels?
Yes. Red bags or red containers may be substituted for the biohazard labels.
 
What are the exceptions to the labeling requirement?
Labeling is not required for:

  • Regulated waste that has been decontaminated.
  • Containers of blood, blood components, and blood products bearing an FDA required label that have been released for transfusion or other clinical uses.
  • Individual containers of blood or OPIM that are placed in secondary labeled containers during storage, transport, shipment, or disposal.
  • Specimen containers, if the facility uses Universal Precautions when handling all specimens, the containers are recognizable as containing specimens, and the containers remain within the facility. *(see note below concerning specimen bags)
  • Laundry bags or containers, containing contaminated laundry, may be marked with an alternative label or color-coded provided the facility uses Universal Precautions for handling all soiled laundry and the alternative marking permits all employees to recognize the containers as requiring compliance with Universal Precautions. If contaminated laundry is sent off-site for cleaning to a facility which does not use Universal Precautions in the handling of all soiled laundry, it must be placed in a bag or container which is red in color or labeled with the biohazard label described above.

*A note concerning Specimen Bags: Some healthcare facilities use plastic bags to transport specimen containers from patient care areas to in-house laboratories. The healthcare facilities label the plastic bag "biohazard" and dispose of the plastic bag as infectious waste.

If not contaminated, the plastic transport bags are not considered infectious waste and may be disposed of as solid waste. However, if the bags are labeled "biohazard," healthcare facilities run the risk that the solid waste hauler might refuse to transport the waste because of the belief that the bags are infectious.

Biohazard labeled plastic bags used as secondary containment for internal transport of specimens is not required by OSHA. The labeling exemption, listed in 29 CFR 1910.1030 (d)(2)(xii)(A) of the Occupational Exposure to Bloodborne Pathogens, applies to facilities that handle all specimens with Universal Precautions, provided the containers are recognizable as containing specimens. The exemption applies only while these specimens remain within the facility. If the specimens leave the facility, a label or red color-coding is required. In addition, secondary containers or bags are only required if the primary container is contaminated on the outside.

Does OSHA accept Department of Transportation's (DOT) labels for waste and specimens which will be shipped or transported?
The labeling requirements do not preempt either the U.S. Postal Service labeling requirements (39 CFR Part III) or the Department of Transportation's Hazardous Materials Regulations (49 CFR Parts 171-181).

DOT labeling is required on some transport containers (i.e., those containing "known infectious substances"). It is not required on all containers for which 29 CFR 1910.1030 requires the biohazard label. Where there is an overlap between the OSHA-mandated label and the DOT-required label, the DOT label will be considered acceptable on the outside of the transport container provided the OSHA-mandated label appears on any internal containers which may be present. Containers serving as collection receptacles within a facility must bear the OSHA label since these are not covered by the DOT requirements.


Training

Which employees must be trained?
All employees with occupational exposure must receive initial and annual training.

Should part-time and temporary employees be trained?
Part-time and temporary employees are covered and are also to be trained on company time.

Who has the responsibility for training workers employed by agencies which provide personnel (e.g., nurses) to other employers?
OSHA considers personnel providers, who send their own employees to work at other facilities, to be employers whose employees may be exposed to hazards. Since personnel providers maintain a continuing relationship with their employees, but another employer (your client) creates and controls the hazard, there is a shared responsibility for assuring that your employees are protected from workplace hazards. The client employer has the primary responsibility for such protection, but the "lessor employer" likewise has a responsibility under the Occupational Safety and Health Act.

In the context of OSHA's standard on Bloodborne Pathogens, the personnel provider would be required to provide the general training outlined in the standard, the client employer would be responsible for providing site-specific training.
 
The contract between the personnel provider and the client should clearly describe the training responsibilities of both parties in order to ensure that all training requirements of the standard are met.

What are the qualifications that a person must possess in order to conduct employee training regarding bloodborne pathogens?
The person conducting the training is required to be knowledgeable in the subject matter covered by the elements in the training program and be familiar with how the course topics apply to the workplace that the training will address. The trainer must demonstrate expertise in the area of occupational hazards of bloodborne pathogens.
 
Where can information be obtained for conducting training on the Bloodborne Pathogens Standard?
OSHA's Office of Information and Consumer Affairs (OICA) has developed brochures, factsheets, and a videotape on the standard. Single copies of the brochure and factsheets can be obtained by writing OSHA Publications, 200 Constitution Avenue, NW, Room N3101, Washington, DC 20210 or by calling (202) 219-8148 the videotape is available through the National Audio Visual Center, and the number is (800)-553-6847. All information available through OICA should be used as a supplement to the employer's training program. Other sources of information include local Area and Regional OSHA Offices. In addition, each Regional Office has a Bloodborne Pathogens Coordinator who answers compliance and related questions on the standard.

Who are some examples of persons who could conduct training on the bloodborne standard?
Examples of health care professionals include infection control practitioners, nurse practitioners, and registered nurses. Non-health care professionals include industrial hygienists, epidemiologists or professional trainers, provided that they can demonstrate evidence of specialized training in the area of bloodborne pathogens.


VetCA OSHA State Tool

Occupational safety and health rules in the U.S. are mostly standardized.

The federal Occupational Health and Safety Administration (OSHA) operate the primary job safety and health program in twenty-nine (29) of the fifty states. This includes conducting inspections and enforcing its standards.

Twenty-one states (21) operate their own job safety and health programs (three additional states cover only state and local government employees). States with approved programs must set job safety and health standards that are "at least as effective as" comparable federal standards. In most cases, states adopt standards identical to federal ones.

Consultation services are available in every state.  In most cases, these are free and are conducted at your healthcare facility.  These services help employers identify and correct workplace hazards and can help you avoid violations and penalties.

Use the VetCA OSHA State Tool for more information on OSHA regulations and consultation programs in your state.


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