Health and Safety,Engineering Controls

Welcome to part two in our animal research model series on bloodborne pathogens. Although this standard is aimed at health care settings,we recommend using it as a model for any animal research involving potential human pathogens. The first article provided an overview of the OSHA standard and discussed the basics of universal precautions. In that missive we:

• Identified which fluids, tissues, cell cultures, or other materials present the most risk;
• Discussed how to recognize the potential exposure routes – mucous membranes of eyes, nose and mouth, skin (especially non-intact skin), and inhalation in certain instances;
• Touched on developing an Exposure Control Plan (ECP) and the elements it should address – exposure determination, communicating hazards to employees, record-keeping, among others.

The article ended by mentioning Universal Precautions and minimum personal protective equipment or PPE. In this, our second part of the series, we want to pick up where we left off and delve into the OSHA BBP standard a little further by examining the elements of an ECP a little closer.

Potential exposures present a risk to animal research scientists both in the animal housing areas and in the laboratory, especially surgical suites. Preventing exposures begins with knowing and following the Centers for Disease Control’s universal precautions,¹ the assumption that all fluids are infectious and preventing contact by use of appropriate personal protective equipment such as gloves, lab coats, and eye protection. Additional measures might entail face shields or respirators, depending on potential hazards or the activity.

Recently, Congress passed the Needlestick Safety and Prevention Act (NSPA)² that led OSHA to revise its BBP standard. Though most of these revisions are applied to health care settings, it is important to note the emphasis on engineering controls and improved equipment design such as needleless systems for the collection or withdrawal of body fluids. The NSPA mandated changes to the OSHA standard regarding the exposure control plan as well. It requires an annual review and update to reflect changes in technology that reduce exposure to bloodborne pathogens, and to consider use of effective safer medical devices to eliminate or minimize occupational exposure.

With the NSPA and its revisions in mind, let’s take a closer look at the Exposure Control Plan, where everything begins in implementation of OSHA’s BBP standard, 40 CFR 1910.1030.³ In the first article, we mentioned that the ECP must address 1) exposure determination, 2) communication of hazards to employees, 3) compliance methods, and 4) record keeping. We discussed the first two at length and said that the key of the BBP standard is in the methods of compliance section. So, let’s start here. Compliance methods begin with the application of Universal Precautions which by now we know by heart, right? Next we get to engineering and work practice controls. As with most OSHA standards and industry best practices, engineering controls and work practices take precedent. Controls to eliminate or minimize employee exposures are always the first means to protect workers. Where exposures remain following installing controls, personal protective equipment must be used. The OSHA standard requires these controls be regularly inspected and maintained to ensure their effectiveness.