The Bloodborne Pathogens Act.

In December 1991, the Occupational Safety and Health Administration (OSHA), U.S. Department of Labor, published the final rule regarding occupational exposure to bloodborne pathogens.(1) In essence, this legislation requires that employers provide for the safety of employees who, in the course of their official duties, may be exposed to blood. The legislation, written primarily for those in health care professions and those who handle medical wastes, also affects public safety employees, such as law enforcement officers, security officers, and fire and rescue personnel.

During the course of their duties, especially when they respond to crime scenes, police personnel can be exposed to blood or other body fluids. Exposure may occur when they provide first aid or CPR while responding to medical emergencies. It may also occur if they sustain cuts or puncture wounds while searching suspects or if they come into contact with blood and fluids while apprehending or arresting suspects.

Police managers must take action to implement the components of the act, not only to comply with the regulations, but more importantly, to ensure the safety of their officers. OSHA requires that agencies have an exposure control plan, that employees be properly trained, and that the hepatitis B vaccine be provided to employees. In fact, the act stipulates that all of these components be in place by July 6, 1992.

Exposure Control Plan

Police managers should write an exposure control plan that eliminates or minimizes employee exposure. This plan should include a schedule for implementing certain procedures necessary to evaluate exposure incidents. All employees must have access to the plan, which should be reviewed and updated periodically, and the plan must be available for inspection by OSHA representatives.

Control plans vary, based on the type of personnel being protected, but they must include universal precautions. All body fluids are assumed to be infectious, regardless of the source. The plans must also include engineering and work practice controls, personal protective equipment use, proper housekeeping procedures, and separate laundry facilities for contaminated clothing.

Plans designed specifically for law enforcement agencies should include personal protective equipment for officers, such as rubber gloves, CPR face shields, and any other protective clothing and equipment necessary to prevent contamination by bloodborne agents during the execution of their duties. In addition, law enforcement agencies must make available to their employees special laundering services to clean contaminated clothing or protective equipment.

Training

The Bloodborne Pathogens Act requires that police officers receive proper training in how to prevent contamination by bloodborne agents. The legislation sets forth specific topics that each agency must cover during these training periods. Once trained, employees must receive annual refresher courses.

In addition, each agency must establish and maintain training records for 3 years. These records must include dates of training, material covered, names of persons who conducted the training, and the names and job titles of all persons who attended the sessions. Agencies must make all training records available to OSHA representatives and to agency employees or their union representatives.

Hepatitis B Vaccine

All agencies must offer the hepatitis B vaccine free of charge to individuals who work in positions targeted by the act. If employees choose to decline the vaccination, they must sign a waiver, which is then maintained in their personnel files. If these employees decide later to receive the vaccine, employers must accommodate their request, again at no charge to the employee.

Because the cost of inoculating officers with the hepatitis B vaccine is approximately $130 per officer, this regulation may impact on agencies' budgets. Law enforcement managers should, therefore, consider this factor in their budget-planning sessions.

Labels and Signs

The Bloodborne Pathogens Act requires the use of international biohazard labels and signs to identify all containers of stored blood and other body fluids. In addition, agencies must ensure that labels are placed on all containers of contaminated items, including body fluids and contaminated clothing and equipment.

Medical Records

Agencies must maintain medical records for employees protected by this act. These records must include the employee's name and social security number, as well as the results of all examinations, medical tests and followups, and a professional's written opinion on the health status of the individual. Agencies must maintain these confidential records for 30 years and may not release them without the consent of the employee, with the exception of release to OSHA, which has access to all such documents.

Conclusion

Several States have their own Occupational Health and Safety Administrations that protect workers within the State. However, all States must comply with this Federal act, even though specific regulations may not exist at the State level.

The Bloodborne Pathogens Act provides a safer and healthier work environment for those individuals in danger of this type of exposure. Public safety agencies that have not already done so should familiarize themselves with the legislation and act immediately to institute its various mandates.

Endnote 

For further information on this legislation, contact the Occupational Safety and Health Administration, U.S. Department of Labor.

Daniel J. Benny is the Director of Public Safety at Elizabethtown College, Elizabethtown, Pennsylvania.

Subjects Covered During Training

* Review of the Bloodborne Pathogens Act

* Epidemiology and symptoms of bloodborne diseases

* Modes of transmission

* Explanation of Exposure Control Plan and how to obtain a copy of the plan

* Methods for recognizing tasks and procedures that may involve exposure

* Use and limitations that reduce or prevent exposure, including engineering controls, work practices, and protective equipment

* Types, selection, removal, proper use, handling, decontamination, and disposal of personal protective equipment

* Information on hepatitis B vaccine

* Emergency contacts and procedures

* Post-exposure procedures

* Biohazard labeling