OSHA Regulations: Overview of Workplace Injuries Involving Blood and Bodily Fluids

The Occupational Safety and Health Administration is a part of the U.S. Department of Labor and was established in 1971 by President Richard Nixon. The primary purpose of OSHA is to create and enforce certain safety regulations in specific workplaces in the United States. These regulations include how jobsite injuries that result in the presence of blood and bodily fluids are to be addressed.

Definition of Hazardous Waste

OSHA regulations dealing with workplace injuries involving blood and bodily fluids fall within the broader agency-created regulatory category of hazardous waste. OSHA defines hazardous waste as “any biological substance of disease-causing material that can cause harm if ingested, inhaled, or assimilated by an employee.” OSHA goes further and defines more fully what is meant by “harm.” Harm, for the purposes of these types of workplace regulations, includes:

  • Death
  • Disease
  • Cancer
  • Genetic mutations
  • Physiological malfunctions
  • Physiological deformities

When it comes to workplace place accidents involving blood and bodily fluids, other materials are included within the regulation established by the agency as well. In other words, OSHA requirements associated with workplace injuries involving blood and bodily fluids extend to materials and items than have been contaminated by those substances as well.

There are a number of bloodborne pathogens that can be found at work injury scenes in the United States. These are not the only type of dangerous pathogens that can be found in blood. The more common pathogens are:

  • HIV
  • Hepatitis B
  • Hepatis C
  • MRSA

Proactive Development of a Safety Plan

OSHA Regulation Standard 1910.120 requires all employers to create a safety plan for employees who end up in a situation in which a workplace injury occurs that results in the presence of blood and bodily fluids at the scene. The plan must be comprehensive.

The safety plan must set forth basic information about biohazards and dangerous pathogens, in manner not unlike what has been done previously in this article. Employers must make certain that workers have a reasonable understanding of the dangers presented by bloodborne pathogens, particular those viruses and bacterium listed a moment ago.

The safety plan for this type of situation must set forth how employees are to respond to the scene of workplace injury involving blood and other bodily fluids. The primary directive to employees is to avoid any contact with the blood and other bodily fluids found at the scene of a workplace injury.

The safety plan designates a specific employee or employees who are responsible for securing the scene of the accident to ensure that other workers do not have contact with the blood and bodily fluids. In addition, the plan sets forth how the scene will be remediated and who specifically bears responsibility for the injury scene cleanup.

Pre-selected employees must be trained in the proper way to cleanup blood and bodily fluids at the scene of a workplace injury, according to OSHA guidelines. These pre-selected employees are provided ready access to the equipment, tools, and supplies needed to safely and thoroughly remediate an injury scene that resulted in blood and bodily fluid contamination.

The safety plan needs to include directives on how to properly, safely cleanup blood, depending on the type of surface on which it is found. The reality is that a workplace accident can result in blood contaminating any number of surfaces from fairly easy to remediate concrete to much more challenging fabric or porous surfaces.

Ultimately, the remediation protocol must include directives on how to initial cleanup blood depending on the surface. The protocol must also include directives on how to sanitize any surface that was contaminated by blood, bodily fluids, or other biological matter as the result of an accident at a workplace.

Finally, the OSHA mandated comprehensive safety plan delineates how employees who may have been exposed to a biohazardous situation are to be medically tested for infection. Testing procedures must be as recommended by the U.S. Centers for Disease Control and Prevention. These recommendations typically require blood tests at different intervals depending on the periods of time each of the most common types of infectious pathogens can be detected in an exposed individual’s body.

New hires are to be provided access to a copy of the safety plan. This can be accomplished by providing them a “hard copy” of the safety plan, which oftentimes is included in an employee handbook. In the alternative, digital copy of the safety play can be made available to new hires.

If the safety plan is updated or revised, employees must be made aware of the changes and provided an updated copy of it. In addition, employers are advised to have recurring refresher sessions with existing employees about this safety plan and other workplace safety protocols and procedures. A refresher should occur at least annually. Many employers elect to have this type of safety plan refresher every six months.

Personal Protective Equipment

OSHA has established standards for the type of personal protective gear that must be worn by a worker who will have contact with blood, bodily fluids, and other biological materials in the aftermath of an employee sustaining an injury. This personal protective equipment is required if an employee will have contact with the injured worker. It is also required to be worn by anyone involved in the inspection, assessment, and evaluation process associated with the accident. Finally, this personal protective equipment must be worn by anyone tasked with the cleanup and remediation of the workplace accident scene.

The personal protective equipment that must be worn by anyone having contact with blood, bodily fluids, and other biological matter includes:

  • Mask or respirator
  • Goggles
  • Gloves
  • Smock, apron, or uniform

Depending on the situation, required personal protective gear may also need to include:

  • Disposable shoe coverings
  • Hair or head covering

Disposal of Biohazardous Material

The blood, bodily fluids, or other biological material collected at the scene of a workplace injury must be disposed of properly. In addition, any items that were contaminated by these potential biohazards that are not capable to being cleaned and sanitized must also be disposed of in a proper manner.

The fluids and contaminated items must be placed on an approved biohazard waste container.  Such a container must be available at the workplace.

Unless the business is such that it routinely disposes of biological or medical waste, a professional contractor must be retained to collect, transport, and ultimately dispose of the biohazardous waste collected in the process of cleaning up the worksite accident scene.

Reporting Requirements

Finally, when it comes to a workplace injury that involves blood of bodily fluids, there may be an additional OSHA reporting requirement. If the injury was minor and the worker did not need to seek medical assistance, no report to OSHA is likely to be necessary.

If an employee was transported to the emergency department or transported to the ER and admitted to the hospital, a report is likely necessary. OSHA reports can be filed either through local or regional officers. In addition, they can be filed online via the OSHA website. Management must be well-versed on OSHA reporting requirements in their industry.