New York State Hepatitis C Testing Program - Program Requirements: Occupational Safety

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What are bloodborne pathogens?

Bloodborne pathogens are infectious microorganisms present in the blood that can cause infection and disease in humans.  These include, but are not limited to, hepatitis B virus (HBV), hepatitis C virus (HCV) and human immunodeficiency virus (HIV), the virus that causes AIDS.

How Do Programs Comply with Occupational Safety and Health Administration (OSHA) Precautions for Bloodborne Pathogens?

Individuals that administer the OraQuick® HCV Rapid Antibody Test should follow universal precautions and all regulations for disposal of bio-hazardous materials.  Facilities should keep a log of all occupational exposure injuries.  In addition, facilities should review their current liability insurance and obtain advice from their legal counsel for specific questions relating to bloodborne pathogen exposure control and response.  State laws and regulations related to liability for bloodborne pathogen exposure and occupational safety should be carefully reviewed.

All specimens, and materials containing specimens, must be handled as if they are capable of transmitting an infectious organism.  Programs must ensure that the OSHA precautions for bloodborne pathogens are met and maintained.

Implementing and maintaining the following OSHA standards will help assure the health and safety of program staff:

  • Have a written exposure control plan that is reviewed annually to minimize or eliminate occupational exposure. For more information on exposure control plans, see the What is an Exposure Control Plan (ECP) below.
  • Implement universal precautions—treating all human blood and other potentially infectious materials as if known to be infectious for bloodborne pathogens.
  • Ensure use of engineering controls—devices to isolate or remove bloodborne pathogens hazards from the environment (e.g., sharps containers).
  • Identify and implement work practice controls—reduce the possibility of exposure by changing the way a task is performed.
  • Ensure access to personal protective equipment (e.g., gloves, gowns, eye protection, and masks).
  • Make Hepatitis B vaccine and vaccination series available to all employees who have an occupational exposure.
  • Provide post-exposure evaluation and follow-up for all employees who have had an occupational exposure incident.
  • Use labels and signs to communicate hazards.
  • Provide information and training to workers.
  • Maintain worker medical and training records.
  • Contain and dispose of bio-hazardous waste (including blood and items contaminated with blood or other potentially infectious materials) in compliance with all federal, state and local regulations.
  • Additional Steps to Ensure a Safe Testing Environment
    • No eating, drinking, or applying makeup in areas where samples are collected and where testing is being performed;
    • Do not store food in refrigerators where testing supplies or samples are stored; (If water bottles are stored in the refrigerator for temperature regulation purposes, they should be clearly labeled “Do Not Drink”);
    • Have sinks for hand-washing or antiseptic hand washing solution available; and,
    • Post safety information for staff and patients.

Occupational Safety and Health Administration (OSHA) Resources

What is an Exposure Control Plan (ECP) and what information should it contain?

The Exposure Control Plan (ECP) is a written program that outlines the protective measures an employer will take to eliminate or minimize employee exposure to blood and other potentially infectious materials.  See the following Occupational Safety and Health Administration (OSHA) website for additional details on ECPs.

Exposure Control Plans (ECP) must contain, at a minimum, the following:

  • The exposure determination which identifies job classifications with occupational exposure and tasks and procedures where there is occupational exposure and that are performed by employees in job classifications in which some employees have occupational exposure;
  • The procedures for evaluating the circumstances surrounding exposure incidents;
  • A schedule of how other provisions of the standard are implemented, including methods of compliance, HIV and HBV research laboratories and production facilities requirements, hepatitis B vaccination and post-exposure evaluation and follow-up, communication of hazards to employees, and recordkeeping;
  • Methods of compliance include:
    • Universal/Standard Precautions;
    • Engineering and work practice controls (e.g., safer medical devices, sharps disposal containers, hand hygiene);
    • Personal protective equipment; and,
    • Housekeeping, including decontamination procedures and removal of regulated waste.       
  • Documentation of:
    • the annual consideration and implementation of appropriate commercially available and effective safer medical devices designed to eliminate or minimize occupational exposure, and,
    • the solicitation of non-managerial healthcare workers (who are responsible for direct patient care and are potentially exposed to injuries from contaminated sharps) in the identification, evaluation, and selection of effective engineering and work practice controls.
  • Sample Control Plan  (PDF)

Additional Resources