Ebola Concerns Make Reviewing OSHA Bloodborne Pathogens Standard Worthwhile

All employers should take proactive steps to ensure compliance with OSHA’s Bloodborne Pathogens standard (29 C.F.R. 1910.1030) given it covers exposure to the Ebola virus.  The Ebola virus is among the subset of diseases to which this standard applies, as it is transmitted by blood or other potentially infectious materials.  In most states that have state-regulated OSHA plans, a similar standard applies.

Any employer with an employee with “occupational exposure,” defined as “reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee’s duties,” must have an Exposure Control Plan.  The plan must contain an “Exposure Determination,” which lists all job classifications where all employees within that classification have occupational exposure and those job classifications where only some employees have occupational exposure (even if the employees wear appropriate personal protective equipment).  The OSHA standard requires employers to institute appropriate engineering and work practice controls to eliminate or minimize their employees’ exposure, and to provide appropriate personal protective equipment at no cost to the employees.

The full standard, available here, imposes additional requirements on employers to mitigate exposure risks.