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Guide · Employers, HR, safety managers, facility managers

What OSHA requires after a workplace blood incident

An injury at work, an assault in a store, or a medical emergency in an office can leave blood on floors and equipment, and sometimes on employees. The OSHA bloodborne pathogens standard sets out what employers must do to protect workers who may be exposed. In Tennessee, it is enforced through TOSHA, the state plan run by the Department of Labor and Workforce Development. This guide summarizes the main requirements. It is not legal advice; check the standard itself and consult a safety professional for your workplace.

Who the standard covers

The standard applies to employers whose employees have reasonably anticipated occupational exposure to blood or other potentially infectious materials. Healthcare workers are the obvious example, but OSHA has said the standard can also cover employees in other industries, such as designated first aid providers and workers whose tasks include cleaning up blood. Employers must determine which job classifications and tasks involve exposure.

TOSHA covers most private employers in Tennessee and state and local government workers. Federal employers and certain other workplaces are covered by federal OSHA instead.

Good Samaritan acts

OSHA has explained that an employee who helps a coworker as a Good Samaritan, rather than as a designated first aid provider, is not covered by the standard for that act. OSHA nevertheless encourages employers to offer post-exposure evaluation and follow-up in those cases. Questions about payment and workers' compensation should go to the employer's carrier or the state program.

The exposure control plan

Covered employers must have a written exposure control plan. It identifies the job classifications and tasks with exposure, sets out the methods used to protect workers, and explains how exposure incidents are evaluated. It must be accessible to employees and reviewed and updated at least annually, and whenever tasks or positions change.

Cleaning up the spill

The standard requires contaminated work surfaces to be decontaminated with an appropriate disinfectant. OSHA has said that EPA-registered tuberculocidal disinfectants, diluted bleach, and certain other EPA-registered products with claims against HIV and hepatitis B are appropriate. Products should be used according to their label, including contact time.

Workers doing the cleanup need appropriate protective equipment, such as gloves and, where splashing is possible, eye and face protection. Broken glass that may be contaminated must not be picked up by hand; it must be cleaned up with tools such as a brush and dustpan, tongs or forceps. Contaminated laundry must be handled as little as possible and bagged where it is found.

Waste

Regulated waste, as OSHA defines it, includes liquid or semi-liquid blood, items that would release blood if compressed, items caked with dried blood that could release it during handling, and contaminated sharps. It must go into closable, leakproof containers that are labeled or color-coded, and be disposed of under federal, state and local rules. In Tennessee, landfill rules restrict disposal of bulk blood and require sharps to be packaged in puncture-proof containers. Larger spills are often handled by a remediation vendor that arranges disposal through a medical waste hauler.

When an employee is exposed

An exposure incident is contact with blood or other potentially infectious materials through the eyes, mouth, other mucous membranes, broken skin or a needlestick or cut. CDC first aid guidance is to wash needlesticks and cuts with soap and water, rinse splashes to the nose, mouth or skin with water, and flush eyes with clean water, saline or sterile irrigant. The employee should report the incident immediately and be evaluated by a health care professional promptly.

Post-exposure evaluation and follow-up

After an exposure incident, the employer must make a confidential medical evaluation and follow-up available to the employee. That includes documenting the route of exposure and the circumstances, identifying the source individual where feasible and legally permitted, testing the source individual's blood with consent where the law allows, making results available to the exposed employee, and offering testing, counseling and preventive treatment as recommended by the U.S. Public Health Service.

The employer must obtain the health care professional's written opinion and give a copy to the employee within 15 days of the evaluation's completion. The opinion is limited in what it can tell the employer; other findings stay confidential.

Hepatitis B vaccination

Employers must make hepatitis B vaccination available at no cost to employees with occupational exposure, within 10 working days of initial assignment and after training. Employees may decline and must sign a declination form; they can change their minds later. OSHA has explained that some collateral-duty first aid providers may be offered vaccination after an incident instead of in advance, but only if specific conditions are met.

Training

Employees with occupational exposure must be trained when they are first assigned to such tasks and at least once a year after that, during working hours and at no cost. Training covers the standard, how bloodborne diseases spread, the exposure control plan, protective equipment, what to do in an emergency, and the post-exposure process. Training should give employees a chance to ask questions.

Records

Employers must keep medical records for each employee with occupational exposure for the duration of employment plus 30 years, and keep them confidential. Training records must be kept for three years. Employers required to keep OSHA injury and illness logs must also keep a sharps injury log.

Customers and the public

Incidents in stores, restaurants, gyms and offices often involve customers or visitors. The standard protects employees, but the same cleanup and waste practices protect the public. Keep the area closed until it has been cleaned and disinfected, and do not let customers walk through it. If a customer or visitor was exposed, encourage them to seek medical advice. Document what happened for your insurer.

Practical steps after an incident

Care for the injured person first and call 911 if needed. Keep other employees away from the area. Have trained staff, or a remediation vendor, clean and disinfect the area. Arrange medical evaluation for any exposed employee and document the incident. Afterward, review what happened and update the exposure control plan if needed. Employee assistance programs can help staff who were shaken by what they saw.

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Call 615-914-0790 or email contact@newdawnbiorestoration.com. We serve Middle Tennessee.

This page is general information, not legal, medical, or insurance advice. Requirements change; verify with the agency listed before acting.

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