(This was the first article I wrote for CTR, and I didn't even really write it, I adapted and restructured it from a much longer piece. I'm not sure which is more difficult. Have you ever seen the Calvin and Hobbes strip where Calvin is thinking up a new slogan for safety. Hobbes mentions that Calvin's mom suggested (reasonably, his expression says), "Look both ways and you'll be safe each day" or something like that. Calvin makes a face and says, "I like mine better: 'Be careful or be roadkill.'" He shows the poster to Hobbes, who makes a gagging face, and Calvin asks, "I ran out of cadmium red." I thought we should scare the shit out of people with this and include really gross graphics. All we did was stick a Biohazard sign in the article. Oh well.)
The Unseen Danger of Bloodborne Pathogens
by Chris Winters
A large part of community transportation's mission is getting people to and from medical care. Dialysis patients are a significant section of these important clients. However, transporting a dialysis patient can be tricky: a tube can work loose and the patient can bleed on other passengers and the driver before a professional can get it under control.
But what happens if the blood is infectious? Accidents will happen and nobody can prevent them. But with strong foresight and a prevention strategy, transit managers and employees can eliminate some of the unfortunate consequences from such an accident.
Danger: Infected Blood
Bloodborne pathogens are viruses or other infectious agents carried by the blood. Two particularly harmful examples are the Human Immunodeficiency Virus (HIV) and the virus for Hepatitis B. Deadly as they are, infections from these bloodborne agents can be prevented. It takes a well thought-out plan for training, constant attention to detail and a mind set among employees and managers geared toward eliminating risk.
The consequences of poor planning can be disastrous. An employee who becomes infected from a bloodborne pathogen can sue the transit operator for huge amounts, charging insufficient equipment and training. Even if the employee settles and the system has insurance, the legal costs can cripple a small system. And if the system doesn't have insurance, such a lawsuit spells the end.
Help does exist. The Occupational Safety and Health Administration (OSHA) has written a regulation to help organizations protect their employees from on-the-job exposure to blood or other bodily fluids. Following the regulations' guidelines can provide a formal defense should an infection occur and the inevitable lawsuit follow. (Managers should, of course, obtain specific advice from legal counsel.)
The OSHA regulation's plan for safety can be divided into four parts:
- Vaccinate employees who might be exposed
- Train employees who might be exposed
- Supply employees with necessary materials
- Implement exposure procedures
Vaccination Key to Prevention
First, a manager needs to determine which employees need vaccinations. A key question is: in which jobs could people be exposed to infectious disease? This group of jobs includes not only drivers whose potential exposure is daily but also those employees who face occasional exposure.
The manager must ensure that all medical evaluations and procedures involving the vaccination and follow-up are free to all employees, available at a reasonable time and accessible place and performed by a licensed health care professional.
Ensuring that employees are vaccinated can be a difficult process. For example, the vaccine for Hepatitis B is actually a series of three injections: the second shot is given 30 days after the first and the third shot five months after that. A manager needs to keep track of when the employees have their shots to confirm they follow through the entire procedure.
Once the vaccination is complete, a manager must keep a record of the time and place of the vaccination series. If an employee declines the vaccination for Hepatitis B, a manager must keep on file a written statement signed by the employee, the language for which is specified in the OSHA regulation.
Continuous Training is Critical
Training is an integral part of eliminating the risks of bloodborne pathogens. The OSHA regulation specifies a number of characteristics the training must fulfill:
- Frequency: Training should take place as soon as an employee is hired or shifted to a position where exposure may occur. Training should be refreshed at least annually thereafter.
- Content: The content and vocabulary of the training should be understandable to employees. The program should include a copy of the OSHA regulation, explanation of bloodborne diseases and symptoms, explanation of how diseases can be transmitted, information on emergency procedures to follow and information on incident reporting and medical follow-up procedures.
OSHA specifies that a manager must keep for three years detailed records about the content of the training and the dates the training sessions were given.
In Case of Incident
The OSHA regulation requires that employees be provided with appropriate protective equipment and materials. Having a comprehensive biohazard kit aboard all vehicles can help prevent infection from bloodborne pathogens. Items appropriate for a biohazard kit include disposable latex or vinyl gloves, paper towels, disinfectant spray effective on HIV and the tuberculosis virus, orange plastic trash bags for disposing biohazardous material at a medical disposal facility, face masks, eye protectors such as goggles, antiseptic hand wipes and a leakproof sealable container for any needles found.
If the biohazard bags are used to clean up a spill or other incident, it is imperative that they be disposed of properly. Managers or employees should let a local hospital or health clinic handle the disposal since they already have a system in place for it.
Handling an Incident
Even with every precaution in place, an employee may still be exposed to bloodborne pathogens. In that case, the manager is required to:
- Document how the employee was exposed.
- Identify the patient who bled and document any history of disease. This includes testing his/her blood as soon as feasible. If the patient refuses to provide blood for testing, the manager must document the refusal.
- Inform the employee of the patient's test results. While the employee has a legal right to know the patient's test status, the results must remain strictly confidential.
- Test the exposed employee for HIV and Hepatitis B and provide counseling to the employee if necessary.
- Enlist the services of a health care professional to recommend appropriate actions to protect the employee's health. The professional's report must be provided to the employee within 15 days, and the manager must retain a copy of the report for 30 years.
Other Sources of Information
This is a formidable laundry list of what needs to be done to protect both employees and clients. While it will take some time to accomplish, meeting the OSHA regulations does not have to be as daunting a task as it first seems. Help is available. The Community Transportation Hotline -- (800) 527-8279 -- has information on bloodborne pathogens.
For more guidance, you can purchase a copy of the publication Managing Bloodborne Pathogens: Guidelines For Transit Managers from Walther Consultancy. OSHA can provide a sample Exposure Control Plan, but it will be one developed for a medical facility and thus not transit-specific.
Developing a proper and complete program for preventing biohazard exposure is essential to protect the health of employees and riders. But there is no need to do it alone or from scratch. Take advantage of the available assistance options and the task will be much easier.
CTAA member Erskine Walther provided the research for this story.