Q. My practice employs fewer than 10 people. Do I still have to comply with Occupational Safety and Hazard Administration's (OSHA's) Bloodborne Pathogens Standard? What are the basic requirements?
A. Yes. The OSHA Bloodborne Pathogens Standard applies to all employers with employees who have occupational exposure to blood or other potentially infectious materials, regardless of how many people you employ.
However, workplaces with 10 or fewer employees are exempt from OSHA recordkeeping requirements and are also exempt from recording and maintaining a sharps injury log. All other applicable provisions of the Bloodborne Pathogens Standard still apply.
Under the standard, your practice must maintain a written exposure control plan; provide safety needles and puncture-proof containers; make sure your staff follows "housekeeping" safety rules; provide gloves, masks, and other protective equipment; promptly evaluate and treat workers who have a needlestick or other exposure to blood; provide hepatitis B vaccinations to workers who are exposed to blood; and train workers each year on bloodborne diseases.
If you are not sure how to comply with the OSHA Bloodborne Pathogens Standard in your practice, TMA can help. An OSHA Compliance consultation is a review of the medical practice's observance and compliance with OSHA policies and procedures. The objective is to help the medical practice develop policies and procedures in order to achieve compliance with the major federal OSHA regulations. If you have any questions, contact TMA Practice Consulting at (800) 523-8776 or e-mail TMA Practice Consulting.