Does MIOSHA’s Bloodborne Infectious Diseases Standard, Part 554, apply to your operations? Do your employees fall into category A or B? Are you required to have an exposure control plan, and to provide training, PPE and Hepatitis B vaccinations to your employees?
Well, if your employees are asked to clean up blood stains (and more) in rental properties, then they fall into category A, which triggers the need for bloodborne infectious disease programming.
Let’s take a closer look at Part 554. Bloodborne Infectious Diseases1 to understand the programming requirements:
Each employer is required to determine if their employees fall into category A or B.
Category A consists of occupations that require procedures or other occupation-related tasks that involve exposure or “reasonably anticipated” exposure to blood or other potentially infectious material, regardless of frequency. This includes procedures or tasks conducted by employees in non-routine situations as a condition of employment. “Reasonably anticipated” is not defined by the standard and each employer must make their own exposure determination. However, as an example, employees cleaning up blood-stained carpet in an apartment are considered to have occupational exposure and fall into category A.
Category B consists of occupations that do not require tasks that involve exposure to blood or other potentially infectious material on a routine or non-routine basis as a condition of employment. Employees in this category do not perform or assist in emergency medical care or first aid and are not reasonably anticipated to be exposed in any other way. In general, “reasonably anticipated,” does not include janitorial or housekeeping staff employed in a non-health care facility who are handling lined, waste containers thereby preventing contact.
In any case, the employer is required to determine if occupational exposure (i.e., actual or reasonable anticipated) exists or not, and to maintain that documentation.
Exposure Control Plan
If employees fall into category A, then the employer is required to establish a written exposure control plan to minimize or eliminate employee exposure.
The exposure control plan needs to include all of the following:
- The exposure determination.
- The schedule and method of implementation for each applicable rule.
- The contents or a summary of the training program.
- The procedures for the evaluation of circumstances surrounding exposure incidents.
- Task-specific standard operating procedures (SOPs) that address all of the following areas:
- Employee recognition of reasonably anticipated exposure to blood and other potentially infectious material.
- Appropriate selection, use, maintenance, and disposal of personal protective equipment.
- Contingency plans for foreseeable circumstances that prevent following the recommended SOPs.
Additionally, the exposure control plan shall be reviewed at least annually and updated as necessary. A review shall consider changes in employees’ tasks and procedures and the latest information from the centers for disease control or the department.
A link to MIOSHA’s sample Exposure Control Plan2 for limited exposure workplaces is provided under the Resources section at the end of this article.
Under the “work practices,” your attention is directed to all the remaining requirements, which are explained in Part 554. Bloodborne Infectious Diseases and MIOSHA’s Factsheet GISHD #0043:
- universal precautions,
- engineering controls,
- work practices,
- protective work clothing and equipment,
- regulated waste disposal,
- vaccinations (and post-exposure follow-up),
- communications of hazards to employees,
- information and training,
Should you require assistance with bloodborne infectious diseases programming, please contact Gary Smith, CRM, at (517) 338-3367 or firstname.lastname@example.org.
- MIOSHA Occupational Health Standard Part 554. Bloodborne Infectious Diseases: http://www.michigan.gov/documents/CIS_WSH_part554_35632_7.pdf
- MIOSHA Bloodborne Infectious Diseases Sample Exposure Control Plan (Limited Exposure): http://www.michigan.gov/documents/cis_wsh_cet5230_ltd_90147_7.doc
- MIOSHA Fact Sheet on Bloodborne Infectious Diseases; GISHD #004: http://www.michigan.gov/documents/dleg/bid_292556_7.pdf