Occupational Safety and Health Administration's (OSHA) Bloodborne Pathogens​​​​​​​​​​​​​​​ Standard (29 CFR 1910.1030​) requires the RFUMS to provide a Bloodborne Pathogens Safety Program for employees who may incur occupational exposure to human blood and other potentially infectious materials (OPIM). Examples of OPIM include body fluids, unfixed human tissue, human cell cultures, and cells and/or experimental animals infected with known bloodborne pathogens. Bloodborne pathogens are microorganisms present in blood and OPIM that can infect and cause disease in people. Examples include Hepatitis B Virus (HBV); Hepatitis C virus (HCV) and Human Immunodeficiency virus (HIV) in people.

Training

Training will occur before assignment to a task where occupational exposure may occur and at least annually thereafter. Additional training will be provided if changes such as modifications or additions of procedures affect the employee's occupational exposure. Training is on-line and located on the University D2L web site. The online training provides an overview of: OSHA's Bloodborne Pathogens Standard, safe work practices, engineering controls, decontamination techniques, biohazard waste management, human cell lines and the Hepatitis B vaccine. Training will also review the principal of Universal Precautions as required by the Bloodborne Pathogen Standard. Universal Precautions is a safety approach in which all human blood and OPIM are treated as if they are infectious and should be handled accordingly. Contact EHS (X3422) for instructions on how to register for the Bloodborne Pathogens Training class.

Exposure Control Plan

Each Primary Investigator must complete and  print a copy of their lab specific  Exposur​e Control Plan ​(ECP) documenting job classifications and the tasks or procedures which may incur exposure to bloodborne pathogens. This document must be available in all lab rooms covered by the Bloodborne Pathogens standard. The ECP also includes a summary of the required engineering and work practice controls, personal protective equipment, housekeeping, labeling, training, and medical surveillance functions that will be used by the laboratory.  Primary Investigators are expected to review and update their lab specific ECP every time a researcher leaves the lab or when a new researcher joins. All lab workers are expected to review and acknowledge the updated ECP after a change in personnel as well.

Human Cell Lines

In 1994 OSHA issued an interpretation of the applicability of the Bloodborne Pathogen Standard towards human cell cultures. OSHA's policy is that human cell cultures (primary and characterized cell lines) are considered to be potentially infectious and covered by the Bloodborne Pathogen Standard. The interpretation does allows for exclusion from compliance if the cells have been extensively tested to prove they are free of bloodborne pathogens and are kept protected by the investigator from environmental contamination. However, since it would be difficult to have cells tested for all bloodborne pathogens and to rigorously ensure they continue to remain free of bloodborne pathogens during use, RFUMS has taken the position that work with ALL human cell cultures must meet the requirements of OSHA's Bloodborne Pathogen Standard.

Hepatitis B Vaccinations

The Hepatitis B vaccine is offered by RFUMS, at no cost, to all employees who may have potential exposure to bloodborne pathogens as part of their job duties. Vaccination involves a series of three intramuscular injections, the second and third administered 1 and 6 months after the first. Employees do have the right to refuse the vaccine.  Regardless of the individual's choice, the employee must complete a Hepatitis B Vaccination Form and submit it to the EHS Department through inter-department mail. If refusing the vaccination, the employee's signature on this form indicates that the employee understands the risk of contracting Hepatitis B, but is making a choice to not receive the vaccine.  An employee can decide at any time to receive the vaccine in the future.​

Further information is available in the following references:

• Exposure Control Plan Template
• OSHA Bloodborne Pathogens Standard ( 29CFR Part 1910.1030)
• OSHA interpretation of the applicability of the Bloodborne Pathogen Standard towards human cell cultures