News & Information Blog

Hazards of Downloaded Programs for OSHA Compliance

By Susen Trail | 10/27/2021

Many downloadable programs have been written so broadly they could not represent a specific workplace.  This becomes a problem because, based upon my experience, Safety Managers many times often won't adapt the program to their workplace.  Often, they don't take out sentences or actions for conditions that aren't present in their workplace.  For example, the Bloodborne Pathogens standard requires:

1910.1030(d)(2)(xii) Mouth pipetting/suctioning of blood or other potentially infectious materials is prohibited.

The downloaded Exposure Control Plan dutifully includes these instructions in the safe work practices section. 


This can result in the following conversation:

Compliance Safety and Health Officer, CoSHO: "Why are employees here pipetting blood?"

Safety Manager: "What is pipetting?"

CoSHO: "It's using suction to pull up a measured amount of a liquid for transfer to another container."

Safety Manager: "We don't do that here." 

This tells the enforcement officer two things:

  1. The Exposure Control Plan was written, or downloaded and filled out, by someone who did not understand the standard.
  2. There is a good likelyhood that the plan does not cover exposure conditions that are found in the workplace.

The Bloodborne Pathogens standard’s scope covers all occupational exposure to human blood or other potentially infectious materials (OPIM).  It would be handy if they meant human or animal blood and OPIM but, it doesn't. The definition of OPIM 1910.1030(b) begins with "The following human body fluids...".

This standard, more than any other, requires a full understanding of its requirements and implications in order to create practical safe work practices and protocols.  For example, if you have a high school basketball team and a bloody nose is reasonably likely to occur.  Handling it will be the responsibility of the coach.  A practical response covers 3 task genres. 

  1. Control the source:
    • Give the bleeding player a towel, tell him or her to sit down.
    • Tell the other players not to step on the blood drops on the floor.
  2. Decontaminate:
    • Stored nearby is a bucket with two marks on the side, add water to here and top up with bleach to here. Store the bottle of bleach and rubber kitchen gloves in the bucket.
    • Wipe down surfaces with visible or potential blood spatter with a towel dipped in the bleach solution, allow to air dry.
    • When the player no longer needs the towel drop it in the bucket of bleach solution.
  3. Dispose of contaminated material:
    • Because the towels have been thoroughly saturated, and decontaminated, by bleach this step is not necessary.

A downloaded program contains the generalized information from 1910.1030 (d) Methods of Compliance:

"All procedures involving blood or other potentially infectious materials shall be performed in such a manner as to minimize splashing, spraying, spattering, and generation of droplets of these substances." 

It does not provide the specific engineering controls and safe work practices required to prevent employee exposure, because it can't. It was written by someone who does not know your workplace.  Writing a compliant program requires knowledge of the purpose behind the requirements of the standard.  Writing, or adapting, a program that can be implemented requires knowledge of your workplace, the potential exposures, and the tools available to the employees.

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