Bloodborne Pathogens and the Hepatitis B Vaccine: Protecting Your Staff

The risk of infection from bloodborne pathogens may seem remote, but the consequences of such incidents are severe and require critical attention. Exposure to Human Immunodeficiency Virus (HIV) is just one of many incidents that can be life changing. Because the work you do involves constant contact with others, and exposure cannot be identified by sight alone, it’s important to follow structured steps in order to combat those risks.

The Occupational Safety and Health Administration’s (OSHA) Bloodborne Pathogens Standard was created to help protect employees from occupation-related contaminations. OSHA’s Bloodborne Pathogens Standard applies to all employers who have any employee who is reasonably anticipated to be at risk for occupational exposure to mucous membranes or Other Potentially Infectious Materials (OPIM).

Because the Hepatitis B Vaccine and OSHA-compliant training are such vital components of employee safety, we have created this guide to help you plan ways to protect your organization in the event that unexpected exposure occurs.

Vaccine Guidelines
All vaccines have procedures outlined to regulate when and how to administer them. The following guidelines apply to the Hepatitis B series:

  • Offer the Hepatitis B Vaccine within the first 10 days of employment.
  • Make the vaccine available to the employee at a reasonable time and place, and at no cost to them.
  • Administer all vaccines by or under the supervision of a licensed physician or other licensed healthcare professional.
  • Follow the recommendations of the U.S. Public Health Service (USPHS).
  • Ensure that administration of the vaccine adheres to policies that are most current at the time the vaccine is given.

Note: If an employee declines, the Youth Serving Organization must ensure that the employee signs a “declination” form to be kept on file. An employee who initially declines to receive the vaccine can decide to accept it at a later date. The employer would be required to continue to make the vaccine available (at no cost to the employee), provided that they continue to be occupationally exposed.

Exposure Control Plans
OSHA’s Bloodborne Pathogens Standard mandates that every organization develop an exposure control plan to be reviewed and updated annually. When designing your plan, review all job descriptions/tasks and identify employees who may be exposed to blood or OPIM at your organization. Employees that are most likely to be exposed include: lifeguards, childcare workers, maintenance and custodial staff, and first responders like camp nurses or EMT’s.

Your exposure control plan should reflect OSHA’s recommendations for safeguards, and should include a combination of engineering and workplace practice controls—for example, making sure that personal protective equipment is stored near potential exposure locations, and also mandating that this equipment is used. At minimum, this would include the following:

  • Universal precautions (treating all bodily fluids as potentially infectious)
  • Personal protective equipment
  • Appropriate decontamination/housekeeping
  • Trainings
  • Methods to communicate hazards
  • Medical surveillance (which includes the offering of the Hepatitis B Vaccine)
  • Post-exposure evaluation and follow-up
  • Proper record-keeping

Unforeseen Exposure
Your organization likely employs people that go above and beyond the requirements of the job for the patrons they serve. One employee may assist another with a nosebleed, for example, or a member may require first aid after a fall. Unfortunately, unanticipated “Good Samaritan” acts can lead to an increase in parenteral or mucus membrane exposure. These exposures are not considered to be an occupational exposure unless the employee providing aid is expected to render medical assistance as one of his/her job duties. Fortunately, the Hepatitis B Vaccine is still effective 24 hours after coming into contact with blood, and can be given after an exposure. In these circumstances, all first-aid providers must receive

Redwoods recommends that all staff take BBP training annually.

Exposure Control Plan Resources and Samples
OSHA Fact Sheet
Model Exposure Control Plan