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Safety first: an OSHA Primer: exposure control is a growing concern for security personnel.

SECURITY is a contact sport. Security officers may serve as the front-line medical team in emergencies, or they may have to restrain or otherwise come in contact with potentially contagious individuals. In today's society, such contact can be life threatening if the proper precautions are not taken.

On March 6, 1992, the Occupational Safety and Health Administration's (OSHA) bloodborne pathogens standard (29 CFR 1910.1030) went into effect. It is OSHA's first regulation pertaining specifically to biohazards. The new standard is predicted to prevent more than 200 of the deaths and 9,200 of the infections that occur annually as a result of workplace exposure to the hepatitis B virus (HBV) and the human immunodeficiency virus (HIV). Since both of these viruses are carried in body fluids, businesses that employ workers who are exposed to blood or other potentially infectious materials (OPIM) are responsible for implementing these regulations.

The new standard applies to, but is not limited to, the following workers: medical and health providers, morticians, fire and rescue personnel, laboratory workers, housekeeping and laundry personnel, and first-aid responders. In many industries, security personnel perform on-scene first aid and CPR, and in some cases, off-duty police, paramedics, and fire fighters moonlight as security personnel. Employees who perform such activities are required to comply with the bloodborne pathogens standard.

The bloodborne pathogens standard is performance oriented. It outlines the level of performance required, rather than giving specifics on how certain duties are to be performed. This allows the employer some flexibility.

Employers of all first-aid responders are required to prepare and implement an exposure control plan (ECP) and train employees in that plan. The ECP is a written document outlining procedures and must include the following six elements to be complete:

* The exposure determination. The exposure determination is a list of all the job titles that include among their responsibilities exposure to blood or OPIM. This is called an occupational exposure. For certain workplaces, a list of all tasks and procedures to follow when the possibility of an occupational exposure exists may also need to be developed.

* Procedures for the use of engineering controls, personal protective equipment, and safe work practices. The standard also requires observance of universal precaution at all times. Universal precaution, an approach to infection control, mandates that all bodily fluids are treated as if contaminated with HIV or HBV. Some additional procedures that may need to be documented and observed include hand washing and specialized handling, storage, and disposal practices for biohazardous materials.

Personal protective equipment (PPE) must be provided at no cost to the employee. The appropriate protection depends on the exposure. For the security officer who is a first-aid responder, access to gloves, mouth pieces, pocket masks, and eye protection may be required. It is the employer's responsibility to ensure that PPE is accessible, maintained, and used.

A documented decontamination procedure for work surfaces, equipment, general areas, and laundry must be developed. All regulated (infectious) waste must be placed in containers that are closeable, constructed to prevent leakage, and labeled with color-coded biohazard labels.

* Procedures for providing the hepatitis B vaccination and conducting a post-exposure evaluation and follow-up. A hepatitis B vaccination is to be provided free of charge to all employees at risk of occupational exposure. Incidental first-aid responders are exempt from this requirement. For incidental responders, the employer is not required to pre-vaccinate; however, it must offer the HBV vaccine to the responder within twenty-four hours if an exposure occurs.

Whenever any exposure incident occurs, a post-exposure evaluation and follow-up must be provided. For first-aid responders, this may include the HBV vaccination, gamma globulin injection, and azidothymidine (AZT) prophylaxis. Post-exposure follow-up also includes a program of counseling and ongoing medical surveillance.

* Training on hazards and control measures. Training and information are required for all affected employees at the time of initial assignment and at least annually thereafter. Records of the training must be maintained, and additional training is required whenever changes are made in procedures.

* Recordkeeping requirements. Medical records of employee exposures are to include name, social security number, HBV vaccination status, record of examinations and medical tests, and the opinion of the health care provider. Records of training dates, times, and content should also be kept.

* Procedures for evaluation of an exposure. Following an exposure, a confidential medical evaluation should be conducted, including documentation of the circumstances, identification of the source individual, blood test of the source individual, blood test with consent of the exposed individual for HBV and HIV, post-exposure prophylaxis, counseling, and evaluation of reported illness.

Even for a security officer who provides on-scene first aid and has occupational exposure to blood or OPIM but does not provide first aid as a routine job assignment, the standard requires the following:

* Written ECP

* Personal protective equipment

* Training on the ECP and hazards associated with bloodborne pathogens

* Labeling of biohazardous materials and contaminated equipment

* Medical and training recordkeeping

* Post-exposure evaluation and follow-up

Complying with the OSHA bloodborne pathogens standard requires considerable effort by management. Industries not routinely inspected by OSHA may be tempted to overlook this new standard. However, even industries without routine, OSHA oversight may face negligence lawsuits filed by the families of affected employees, or in some states, by the employee, bypassing traditional workers' compensation protection. The bloodborne pathogens regulation should be taken seriously and adhered to by any organization in which workers' jobs expose them to pathogens transmitted via body fluids.

Robert L. Kohr, CPP, CSP (Certified Safety Professional), is a senior consultant with Arthur D. Little, Inc., in Arlington, Virginia. He is a member of the ASIS Standing Committee on Lodging Security. Kathryn Nobrega is also senior consultant with Arthur D. Little, Inc., in Los Angeles. She specializes in biosafely and laboratory safety and health for workers in the health care industries.
COPYRIGHT 1993 American Society for Industrial Security
No portion of this article can be reproduced without the express written permission from the copyright holder.
Copyright 1993 Gale, Cengage Learning. All rights reserved.

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Author:Kohr, Robert L.; Nobrega, Kathryn
Publication:Security Management
Date:Aug 1, 1993
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