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OSHA Revises Bloodborne Pathogens Compliance Directive

On November 5, 1999, OSHA issued a new directive to address exposure to bloodborne pathogens. The directive guides OSHA's compliance officers in enforcing the standard that covers occupational exposure to bloodborne pathogens. (29 C.F.R. §1910.1030). It updates an earlier directive issued in 1992 and reflects the availability of improved devices, better treatment following exposure and OSHA policy interpretations. The revised directive emphasizes the importance of an annual review of the employer's bloodborne pathogens program and the use of safer medical devices to help reduce needlesticks and other sharps injuries. It emphasizes the use of engineering controls, such as safer medical devices, rather than administrative controls and personal protective equipment. The directive also highlights basic work practices, personal protective equipment and administrative controls. The emphasis on engineering controls results from OSHA's request last year for ideas and recommendations on ways to better protect workers from contaminated needles or other sharp objects.

The revised directive includes detailed instructions to compliance officers on inspections of multi-employer worksites, such as home health services, employment agencies, personnel services, physicians and health care professionals in independent practices, and independent contractors. Also included in the directive are decontamination requirements, guidelines on hepatitis vaccinations and post exposure treatments, and employee training. It adds the most recent guidelines from the Center for Disease Control on vaccinations against Hepatitis B virus and incorporates CDC's guidelines on post exposure evaluation and follow-up for HIV and the Hepatitis C virus. OSHA mandates effective training and education for employees whenever safer devices are implemented and stresses "interactive" training sessions rather than just the use of films or videos that do not provide the opportunity for discussion with a qualified trainer. In addition, the directive provides sample engineering control evaluation forms, an Internet resource list, a "fill-in-the-blanks" sample exposure control plan, and CDC guidelines pertaining to HIV exposure, control and prevention of hepatitis C, and hepatitis B vaccinations.

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