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OSHA blood test cost estimates yield confusion.

How can the average cost of complying with the bloodborne disease (HIV, Hepatitis B) regulations average $32 per police officer and $60 per fire fighter when cities are confronted with costs of $140 - $160 just for the cost of required inoculations for one individual?

The difference lies in OSHA's use of incremental costs of compliance, the discounting to present value of the costs of inoculation and capital costs and assumptions that high proportions of employees have already been protected by inoculation.


Cities in about half the states are busy preparing exposure control plans in order to comply with federal bloodborne disease protection requirements. Compliance is required on or before June 6, this year (based upon when their state level OSHA agencies adopt the federal minimum standards).

Cities should analyze their own situation rather than utilizing OSHA average costs for budgeting purposes. In preparing a plan the burden is on the employer to determine what employees are at risk to such exposure. While the discussion which follows concentrates on police officers and firefighters a city can only determine what employees should fall under its plan based upon individual analysis.

Only cities in the following states are required to comply with the regulation (since they have state OSHA plans): Alaska, Arizona, California, Conncecticut, Hawaii, Indiana, Iowa, Kentucky, Maryland, Michigan, Minnesota, Nevada, New Mexico, New York, North Carolina, Oregon, Puerto Rico, South Carolina, Tennessee, Utah, Vermont, Virginia, the Virgin islands, Washington and Wyoming. Cities in other states are not required to comply unless some other state agency decides to adopt similar rules.

OSHA Estimating Elements

The costs for each city of preparing and executing the plan will be different but what follows are some of the elements and assumptions that contributed to the OSHA estimates above.

First, OSHA in developing their estimates assumed that cities were already complying to a high degree with the required procedures and thus existing levels of expenditure were not included in their estimates. Second, in figuring out annual average cost OSHA amortized the cost of such items as inoculations over their expected periods of efficacy. What were some of the assumptions?

The cost of inoculations per person was figured at $128 (a three shot series) with some additional costs of employee time and charges if the vaccine was administered by a private medical practitioner. The estimate was based on the assumption that 66 percent of paramedics were already protected from such diseases and that only 68 percent of the remaining employees would elect to receive the inoculations. Seventeenth percent of police officers were believed already to be protected with less than 30 percent of those unprotected electing to receive the shots.

The OSHA estimate assumes that 8 hours will required to complete an exposure control plan. OSHA estimated that the average law enforcement officer will make use of six personal protective equipment kits during the course of the year at a cost of $4.00 per kit. For firefighter and paramedic personnel the use of gloves is estimated at between 2-4 per day at a cost of 18 cents per pair. In the fire and rescue services masks and gowns are estimated to be used at a rate of between one and two per day with masks costing 15 cents each and gowns running 50 cents each.

The costs of personnel training are among the largest costs for both police and fire personnel.
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Title Annotation:Occupational Safety and Health Administration
Author:Peterson, Doug
Publication:Nation's Cities Weekly
Date:May 4, 1992
Previous Article:City leaders testify on base closing needs.
Next Article:A statement from the NLC officers: 'Our nation must confront attitudes and issues.' (National League of Cities)

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