Bloodborne Pathogens Standard: Implementing Bloodborne Pathogen/Exposure Control Plan in LTC Centers, Part 2

OSHA; Safety; Regulations; Infection Prevention/Control

​​This article expands on the protection of staff and residents through the implementation of an OSHA-compliant Bloodborne Pathogen (BBP)/Exposure Control Plan (ECP). It also covers the significance of compliance with special emphasis on the prevention of infection and post-exposure process by identifying and discussion of 4 additional key requirements for establishing and implementing an effective ECP within long term care centers (LTCC).  

The OSHA Bloodborne Pathogens Standard:

The Bloodborne Pathogens Standard 1910.1030 provides the requirements to safeguard health care workers from the risks associated with exposure to bloodborne pathogens. As discussed in the previous article, here are the key requirements for an exposure control plan: 

Key Requirements for Implementing an ECP:

  1. Exposure Determination  
  2. Written ECP 
  3. Universal Precautions, Procedural Controls, and PPE 
  4. Employee Training 
  5. Hepatitis B Vaccination 
  6. Post-Exposure Procedures 
  7. Medical Surveillance 
  8. Recordkeeping 

This article covers the last four key requirements for Development and Implementation of an effective Exposure Control Plan: 

Hepatitis B Vaccination: 1910.1030(f)(1)&(f)(2) 

  • Requirements:
    • Mandatory Vaccination Offer: 
      • Ensure that all employees at LTCCs are offered the Hepatitis B vaccination series free of charge, within 10 days of initial assignment to a job involving potential exposure to blood or other infectious materials. 

    • Training and Information: 
      • Provide comprehensive training regarding the benefits, safety, efficacy, and methods of administration of the Hepatitis B vaccine. Employees should receive this training during regular working hours and at no cost to the employee.   
  • Implementation Recommendations:
    • Vaccination Protocols: 
      • Develop clear and documented protocols for the administration of the Hepatitis B vaccine, outlining the procedures for offering and documenting vaccinations. Ensure that these protocols align with OSHA guidelines and are easily accessible to all staff members. 
    • ​Integration with Orientation Programs: 
      • Integrate Hepatitis B vaccination procedures into the orientation programs for new employees, emphasizing the importance of compliance with OSHA regulations. This ensures that all new staff members are informed about and have access to the vaccination series. 

Post-Exposure Procedures: 1910.1030(f)(3)  

  • Requirements:
    • Immediate Reporting and Documentation: 
      • Employees must promptly report any exposure incidents to their supervisor or designated individual responsible for managing such incidents. 
      • Employers are required to maintain detailed records of all exposure incidents, including the circumstances surrounding the exposure, the affected employees, and the actions taken in response.

    • Medical Evaluation and Follow-Up 
      • Employers must ensure that employees who experience an exposure incident receive prompt medical evaluation by a qualified health care professional. 
      • Medical evaluation should include assessing the risk of infection, determining the need for post-exposure prophylaxis (PEP), and providing appropriate follow-up care as necessary. 

    • ​Provision of Post-Exposure Prophylaxis (PEP) 
      • Employers must make post-exposure prophylaxis (PEP) available to employees in accordance with current guidelines and recommendations. 
      • PEP may include the administration of the Hepatitis B vaccine series, antiretroviral medications for HIV prevention, or other interventions depending on the nature of the exposure and the pathogens involved.
  • Implementation Recommendations:
    • Training and Awareness: 
      • Conduct regular training sessions to educate employees on the importance of prompt reporting of exposure incidents.
      • Identify the specific steps to take following an exposure, including whom to report to, how to document the incident, and the availability of medical evaluation and follow-up.
    • Establish Clear Protocols and Communication Channels: 
      • Develop and communicate clear and concise written protocols for post-exposure procedures. 
      • Clearly outline the roles and responsibilities of both employees and supervisors, in the event of an exposure incident, and establish effective communication channels to facilitate quick reporting and response.

Medical Surveillance: 1910.1030(f)(3) 

  • Requirements:
    • Post-Exposure Follow-Up: 
      • Ensure that employees who experience an exposure incident receive a follow-up medical examination as soon as possible after the incident. 
      • The follow-up should include a determination of the employee's health status, any necessary medical interventions, and counseling regarding any potential implications of the exposure. 

    • ​Healthcare Professional’s Written Opinion: 1910.1030(f)(5) 
      • Obtain and provide the employee with a written opinion from the healthcare professional regarding the results of medical examinations and tests. 
      • The written opinion should include information about whether the Hepatitis B vaccination is indicated, confirm that the employee has been informed of the results, and be kept confidential.

  • Implementation Recommendations:  
    • Streamlined Reporting Process: 
      • Establish a clear and efficient reporting process for employees who experience exposure incidents. 
      • Implement a system that enables quick and straightforward reporting to supervisors or designated personnel, ensuring that post-exposure follow-up can be initiated promptly. 

    • Collaboration with Healthcare Professionals: 
      • Establish relationships with health care providers to ensure timely access to medical expertise, facilitate follow-up examinations, and coordinate any necessary post-exposure prophylaxis or treatment. 

Recordkeeping: 1910.1030(h) 

  • Requirements:
    • Hepatitis B Vaccination Records 1910.1030(h)(1)(ii)(B) 
      • Employers must maintain records documenting each employee's Hepatitis B vaccination status. 
      • These records should include dates of vaccination, any medical records related to the employee's ability to receive vaccination, and any declinations of the vaccination. 

    • ​Employee Exposure Records 1910.1030(h)(1)(ii)(C),(D),(E) 
      • Maintain records of all exposure incidents, including the route of exposure, circumstances, and the source individual's status, if known. 
      • These exposure records should be kept confidential and accessible only to authorized personnel involved in the evaluation and follow-up process. 

    • ​Training Records 1910.1030(h)(2) 
      • Maintain records of all annual and new hire training sessions related to Bloodborne Pathogens and the ECP. 
      • Records should include the date; summary of contents; name(s) of trainer(s); and names and job titles of all persons attending the training sessions. Maintain record at least 3 years from the date of the training.

    • ​Sharps Injury Log 1910.1030(h)(5) 
      • Document all injuries resulting from contaminated sharps. 
      • Track the type and brand of device, job department of the employee, and an explanation of how the event occurred. Ensure privacy of the individual(s) involved in the incident. 

  • Implementation Recommendations:
    • Secure Recordkeeping Systems: 
      • Implement a secure and efficient recordkeeping system to store and manage Hepatitis B vaccination records, exposure incident details, and related medical records. 
      • To the extent possible, utilize electronic databases or software solutions to ensure easy retrieval, update, and confidentiality of records while allowing authorized personnel to access the information as needed. 

Bloodborne Pathogen Exposure Control Plan is a central element of OSHA compliance and safety management. By meeting these requirements, long-term care centers create a safer environment, reinforcing their dedication to providing quality care while protecting the health and safety of both residents and staff. 

OSHA Model ECP:  

NOTE: While model plans provide a valuable foundation, health care centers must understand the importance of customizing these OSHA standards to the unique characteristics and operational context of their facility.