Oh My, OSHA

Last month, OSHA released a statement regarding their intended review of the Bloodborne Pathegon standard from 1991. The standard was developed to protect healthcare workers from exposure to infectious blood. Since that time, the standard has grown to cover other industries with the potential for exposure, such as the Solid Waste industry. The purpose of OSHA’s review is to determine if the standard causes financial hardship on small businesses and if there is critical data to support the program’s effectiveness of preventing exposure to infectious disease.

The timing of the standard review is rather interesting given OSHA’s increased audit and citation activity over the last year. I have heard of at least two non-healthcare companies that had been audited by OSHA for their Bloodborne Pathegeon program. Unfortunately the OSHA inspections resulted in heavy fines for non-compliance. In each instance, the companies were cited more specifically for non-compliance with the Hepatitis B requirement of the standard. Both organizations had a Bloodborne Pathegeon program and developed the required training material. The citations and fines came as a result of missing documentation and program execution. Because there are discrete date requirements associated with the Hepatitis B vaccinations, it becomes very easy fall out of compliance if you do not have an automated system for managing the vaccination schedule.

What are the Hepatitis B requirements in the Bloodborne Pathegeon standard? 29 CFR 1910.1030(f)

Section (f) of the OSHA standard outlines the requirements of the Hepatitis B Vaccination and Post-Exposure requirements. It should be noted that the following requirements are only a small piece of the overall OSHA standard requirements. This Blog is intended to point out the Hepatitis B requirements as it has been a focal point of recent citations.

Example:
29 CFR 1910.1030(f)(2)(i) states that the Hepatitis B vaccination must be made available to employees who have occupational exposure to blood or any other infectious materials, within 10 days of initial assignment.

In this instance, the employer shall give the employee the option to accept or decline the Hepatitis B vaccination. If the employee initially declines, but at a later date requests the vaccination, he/she is entitled to the vaccination. OSHA requires that the vaccination and all other requirements be completed at no cost to the employee.

The Hepatitis B vaccination is actually 3 doses that must be completed on a specific timeline. In addition to the 10-day window requirement for the initial vaccination dose, dose 2 must be completed in 1 month and dose 3 must be completed in 6 months. Many companies are seeing citations and fines not only for 29 CFR 1910.1030(f)(2)(i), but also for not overseeing employees through Doses 2-3. The Hepatitis vaccination becomes obsolete if all three doses are not completed.

Recent fines for none compliance with 29 CFR 1910.1030(f)(2)(i) and other sections of 29 CFR 1910.1030(f) have ranged from $25,000 to $85,000 in 2009/10.

DQ-it Hepatits B Module
In an effort to mitigate further OSHA citations, the two companies mentioned above turned to Concorde for assistance. Within our DQ-it system, Concorde has a Hepatitis B tracking module that enables clients to stay on top of the vaccination requirements. The module will store the vaccination request form (with a 10-day expiration), Dose 1 vaccination documentation (with a 1 month expiration), Dose 2 vaccination documentation (with a 6 month expiration), and finally Dose 3 vaccination documentation. The benefit of the system is that it meets the OSHA requirements for document storage and ensures the completion of the vaccination series. For more information contact Josh Rosenzweig josh@concorde2000.com