OSHA Inspections and the Bloodborne Pathogens Standard in LTC Communities

OSHA; Regulations; Long Term Care

In this article, we will discuss reasons why OSHA may inspect a long term care (LTC) center. We also will cover some highlights of the OSHA Bloodborne Pathogens Standard and its application in LTC facilities/communities.  

Reasons for an OSHA Inspection 
The purpose of an OSHA inspection is to ensure compliance with safety standards and protect the well-being of both employees and residents. The top five most common reasons an inspection may be conducted in an LTC center include:  

  1. Complaints: OSHA may conduct inspections in response to complaints filed by employees, residents, or their families.  
  2. Incident Investigations: OSHA may investigate the facility/community following a workplace incident, particularly if it resulted in serious injury, illness, or death.  
  3. Random Inspections: While less common, OSHA may conduct random inspections under an emphasis program to ensure health care communities are complying with safety standards.  
  4. Follow-up Inspections: If a center has been previously cited for OSHA violations, especially serious violations, OSHA may conduct follow-up inspections to ensure that corrective actions have been taken to address the identified hazards.  
  5. Media Referrals: If OSHA learns of a potential safety violation through the media—TV broadcasts, newspaper, internet articles—OSHA may conduct targeted inspections focusing on the hazard or event shown in the media report. 

OSHA’s Bloodborne Pathogen Standard 
Once an inspection is opened in a health care center, OSHA frequently looks for violations of the Bloodborne Pathogens Standard (Bloodborne Pathogens - Standards | Occupational Safety and Health Administration (osha.gov). This standard protects against potential Blood or Other Potentially Infectious Materials (OPIM) health hazards, especially in LTC centers caring for vulnerable populations. 

Implementing an OSHA Bloodborne Pathogen Program 
Implementing an effective OSHA Bloodborne Pathogen Program in your LTC facility will include the following:

Establish a written Exposure Control Plan (ECP): 
An Exposure Control Plan is a comprehensive document developed by employers to minimize or eliminate occupational exposure to bloodborne pathogens in the workplace. It is the primary requirement of OSHA's Bloodborne Pathogens Standard (29 CFR 1910.1030) and is particularly important where employees may come into contact with blood or other potentially infectious materials. The Exposure Control Plan outlines the employer's strategy for protecting employees from exposure to bloodborne pathogens, including HIV, Hepatitis B, and Hepatitis C. 

Review and Update the Plan 
This segment outlines the plan's periodic assessment, typically conducted annually or more frequently if required. It designates a responsible individual or team for the review process. During this evaluation, the effectiveness of existing safety measures is analyzed, considering feedback from employees and any changes in regulations. Documentation of the review process, including modifications made to the plan, is recommended for compliance. Once updates are implemented, staff members should be trained on any changes.  

Universal Precautions 
Universal Precautions involve treating all human blood, certain body fluids, and other potentially infectious materials as if they are infectious for HIV, HBV, HCV, and other bloodborne pathogens, regardless of the perceived risk. Universal Precautions must be observed by all employees when dealing with blood or potentially infectious materials. This includes using appropriate personal protective equipment (PPE) such as gloves, masks, and eye protection. 

Standard Precautions
Standard Precautions expand on Universal Precautions and assume that every patient is potentially infectious. Standard Precautions integrate infection control practices used to prevent the transmission of diseases in healthcare settings when providing care to all patients, regardless of their diagnosis or presumed infection status.  

Engineering controls 
Engineering controls involve physical changes to the building or equipment and create a safer work environment by physically removing or isolating hazards. For instance, sharps disposal containers are puncture-resistant containers designed to safely dispose of needles and other sharp medical instruments, minimizing the risk of accidental needlesticks among healthcare workers. Other examples of engineering controls include self-sheathing needles, safer medical devices that reduce the risk of needlesticks, and biohazardous waste disposal systems. These controls are specifically designed to prevent or minimize contact with blood or other potentially infectious materials. 

Work practice controls  
Work practice controls refer to specific behaviors and practices designed to minimize the risk of occupational exposure to bloodborne pathogens. Unlike engineering controls (physical devices) and personal protective equipment (PPE), work practice controls focus on safe work habits and procedures. Examples include Hand Hygiene, Proper Sharps Handling, Labeling Systems, Emergency Procedures, Cleaning and Disinfection, and Training.  

Personal Protective Equipment (PPE)  
PPE, including gloves, masks, face shields, gowns, and eye protection, acts as a barrier between employees and potentially infectious materials. Its purpose is to prevent direct contact with blood or other body fluids, minimizing the risk of exposure to bloodborne pathogens. Exposure Control Plan outlines the specific types of PPE required for various tasks and exposure risks. PPE considerations include Device Selection, Use, Training, Availability, Maintenance and Replacement, and Disposal.  

Hepatitis B vaccinations   
Ensuring compliance with Hepatitis B vaccination requirements protects employees from the potentially severe consequences of HBV infection. It also demonstrates the employer's commitment to providing a safe and healthy work environment, in accordance with OSHA regulations. Key components of the Hepatitis Vaccination Requirement include Offer of Vaccination, Voluntary Employee Decision, Informed Decision, Vaccination Schedule, and Documentation. 

Post-exposure evaluation and follow-up 
When an employee experiences an exposure, the employer should respond, including Immediate Care, Reporting, Medical Evaluation, Post-Exposure Prophylaxis (PEP), Follow-Up Care, and Documentation.  

Training must cover the specifics of the Exposure Control Plan, including details about bloodborne pathogens, modes of transmission, the center's exposure control procedures, proper use of personal protective equipment (PPE), safe work practices, and emergency response protocols. Initial training is provided to employees at the time of their initial assignment to tasks where occupational exposure may occur. Annual training is also required to ensure that employees stay updated on best practices and any changes in procedures or regulations.  

The center should keep the following documents: Training Records, Hepatitis B Vaccination Records, Post-Exposure Incident Records, Written Exposure Determination Records, and Sharps Injury Logs.  

Overlap with Existing Infection Control Plans 
The good news is that most LTC centers will already have infection control and prevention plans in place that likely cover most of the OSHA Exposure Control Plan requirements. Careful attention should be paid, however, to Hepatitis B vaccination requirements and Sharps Log recordkeeping, which might not be covered by your existing Plan.  

In the scope of LTC, where compassion and medical expertise converge, the OSHA Bloodborne Pathogens Standard stands as a safeguard, protecting both those in care and those providing it. By embracing technology and fostering a culture of safety, LTC centers can navigate the complexities of the Bloodborne Pathogens Standard effectively, ensuring the safety and well-being of everyone involved. 

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