In retail stores, warehouses, and distribution centers, there are hidden hazards most people don’t expect: bloodborne pathogens.
OSHA’s Bloodborne Pathogen Standard 29 CFR 1910.1030 prescribes safeguards to protect workers against the health hazards caused by bloodborne pathogens. The determination of potential exposure is easier in a healthcare or laboratory setting than in a non-healthcare setting. In retail settings, splashes or exposures to blood or bodily fluids are not generally expected in day-to-day operations.
Recently, Roberta Smith, RN, MSPH, CIC, CIH, spoke at the Retail Industry Leaders Association meeting and discussed how the standard may (or may not) apply to retail organizations. Read on to discover her insights on bloodborne pathogens, how they impact retail workers, and what companies can do to keep people safe.
What Are Bloodborne Pathogens?
Bloodborne pathogens are microorganisms that are present in human blood and can cause disease in humans. The organisms that are medically crucial within health and safety are those that are transmitted person-to-person, such as Hepatitis B (HBV), Hepatitis C (HCV), and Human Immunodeficiency Virus (HIV). OSHA’s standard also covers Other Potentially Infectious Materials (OPIM) like saliva, any bodily fluid that is visibly contaminated with blood, and amniotic fluid, among others.
Defining Exposure Risk for Retail Employees
When thinking about this standard and how it might apply in a non-healthcare setting, organizations should understand their employees’ potential for occupational exposure to bloodborne pathogens and/or OPIM.
According to OSHA, an exposure incident is a when blood or OPIM comes in contact with the eye, mouth, other mucous membrane, or non-intact skin that results from the performance of a worker’s duties.
When might your employees come into contact with blood or OPIM as a result of their duties? If they have first aid responsibilities that are written into their job duties or if they are to act as a first responder to an incident, then they potentially could have exposure to blood or OPIM and would be covered under the standard. If they are a nurse at the company’s on-site clinic, they could potentially be exposed and would be covered under the standard.
While OSHA does not generally consider all maintenance personnel and janitorial staff employed in non-healthcare facilities to have occupational exposure, it is the employer’s responsibility to determine if exposure is possible. If there is sufficient evidence of reasonable anticipated exposure, the employer will be held responsible for providing the protections in the Bloodborne Pathogens Standard.
One important tip to keep in mind: When conducting your exposure determination, do not base it on whether or not the employee will be wearing personal protective equipment (PPE). Depending on the situation, they could have an exposure even if they are wearing PPE.
Recently, some retail establishments have been cited by OSHA for not having a bloodborne pathogen (BBP) plan in place and workers were stuck with syringes found in their public restrooms. If recognized as an ongoing hazard, the employer should take measures to establish a BBP plan and create engineering, administrative, and PPE controls to reduce or eliminate this risk.
The use of tagging guns is another potential exposure-causing activity. This can happen if a worker punctures their skin with a tagging gun and another worker uses the same gun and punctures themselves as well. Creating a policy that assigns a tagging gun to each employee would eliminate the risk of bloodborne pathogen exposure.
First aid is always a question that comes up when discussing the need to develop a BBP plan. As stated previously, if an employee is trained and designated in their job description as responsible for rendering first aid as part of their job duties, they are covered by the protections of the standard. Employees who perform unanticipated “Good Samaritan acts” are not covered by the standard. However, if an employee does assist in first aid outside of their job duties and has an exposure, although not required, it is in the best interest of the company to follow-up with the employee as they would under a bloodborne pathogen standard.
Hepatitis B Vaccination
The Centers for Disease Control and Prevention has an informative document discussing occupational exposures to blood and the risks of HBV, HBC, and HIV with needlesticks and splashes. It outlines that most exposures do not result in infection, since there are so many variables at play, including the type of exposure and the amount of blood involved in the exposure. It is important to keep in mind that blood splashes to intact skin would not constitute an exposure requiring medical evaluation. For one of the hardiest bloodborne pathogens, HBV, there is an available vaccine that can be administered as a part of prevention.
Industries outside healthcare may be confused with the hepatitis B vaccination and its role in protecting employees. In the standard, employees who have determined to be at risk for bloodborne pathogen exposure must have the hepatitis B vaccination made available to them within 10 days of starting the job that puts them at risk. The employer does not have to make hepatitis B vaccination available to employees who have previously received the vaccination series, who are already immune via antibody testing, or for whom receiving the vaccine is contraindicated for medical reasons.
For certain retail companies, the vaccine can be a good resource to make sure employees are protected on the job.
Don’t Wait Until “What If?” Becomes “What Now?”
If your employees don’t have the potential to be exposed to bloodborne pathogens as a part of their work duties, then you are not required to develop your own BBP plan.
However, you might have a “what if” scenario already brewing in your mind. If that is the case, the best course of action would be to develop awareness training, put it in writing, train employees on it, and have it accessible to them. The plan should address who will respond to an incident and how it will be reported. It can also be helpful to identify engineering controls (such as picking up any found syringes with a tool and putting them in a puncture-proof container) and administrative controls (such as the use of specific PPE and vaccination measures).
As we all know, situations and work environments can change over time. When protecting employees and identifying potential risks, it’s key to keep an eye on any increase of incidents that may expose employees to bloodborne pathogens or OPIM—as with all hazards, you may want to revisit your exposure determinations.
Most of all—being proactive, understanding the current risks employees face, and developing plans to mitigate those risks will foster a safe and supportive workplace.
Need help understanding your workplace risks? Contact us today.
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