Members have asked what type of training they should provide employees concerning bloodborne diseases, such as Hepatitis-B and AIDS, which can be transmitted through blood or bodily fluids.
OSHA Standard
The Occupational Health and Safety Administration ("OSHA") published a standard in December of 1991 requiring employers to comply with the standard and develop Exposure Control Plans if it is "reasonably anticipated" that employees will likely contact blood or other potentially infectious bodily fluids in the course of their work. 29 CFR 1910.1030(b), (c). The standard is called the "Bloodborne Pathogens Standard". Hospitals, physicians' and dentists' offices, ambulance services, medical labs, and the like are workplaces for which it is reasonably anticipated that employees will likely come into contact with blood and other bodily fluids. Typical office environments are not, and so are not covered by OSHA's Bloodborne Pathogen Standard.
Although there is always the possibility of an accident or other exposure that would result in an employee's exposure to blood, the OSHA requirements only apply if such an exposure can be reasonably anticipated as likely in the normal performance of job duties. Theoretical possibilities will not trigger the OSHA requirements for an employer. Additionally, "Good Samaritan" acts, such as one employee helping another employee who is having a nosebleed is not considered an "occupational exposure" and so such an event would not require the employer to comply with the OSHA Standard. OHSA Fact Sheet, "Bloodborne Pathogens Final Standard", 1/1/92, page 1.
Even though most office environments, such as those in which financial institutions operate, do not have activities for which it could be "reasonably anticipated" that employees would have contact with blood in the course of performing their duties, employers should be aware of what to do in case employees do contact blood or fluids during the course of their work. The OSHA standard, while not applicable to banks, does discuss the "universal precautions" to be used by employers which are subject to the standard. Universal precautions apply to blood, and only apply to other bodily fluids -- such as tears, saliva, sweat, urine, etc. -- if those fluids contain visible blood.
Universal Precautions
While Members are not covered by OSHA's Bloodborne Pathogens Standard, it is advisable to use "universal precautions" when there is any blood spilled, regardless of whether there is any reason to suspect that it is infectious or not. This is because OSHA and MIOSHA require that all blood must be treated as if it were infectious. General guidelines for universal precautions are:
- Take care to prevent injuries when using sharp instruments or devices.
- Use gloves or other protective barriers to clean up any blood which has been spilled. Gloves should be made of vinyl or latex and of reasonable thickness and without tears or punctures. Use paper towels to clean up any spill. Dispose of the gloves and paper towels in a separate sealed plastic trash bag.
- If any blood has touched an employee's hands or other skin surfaces, immediately and thoroughly wash the area.
- Immediately clean any blood-soiled surfaces with a fresh solution of one part bleach to nine parts water.
- If any clothing has been blood-stained, put the clothing in a sealed plastic bag and arrange for the clothing to be machine washed separately in hot, soapy water.
Training
The American Red Cross has a general first aid training program which includes training concerning universal precautions and the Bloodborne Pathogens Standard. This program lasts five hours and typically costs $350 for a group of up to 12 people. If a Member wished, it could have the Red Cross present this first aid training for several employees at each of its locations. Local hospitals and local district public health departments sometimes offer first aid training which encompasses universal precautions.