Portable Sanitation Association International

Page 8 ASSOCIATIONINSIGHT Portable Sanitation Association International News BIWEEKLY EDITION FEBRUARY 5, 2020 Continued on page 9 Dealing with Bloodborne Pathogens By Karleen Kos, PSAI Executive Director The term "bloodborne pathogens" includes bacteria and viruses that are carried in the blood that can make someone—like you or an employee of your company— sick. Some pathogens carried in blood or bodily fluid (like HIV) sound scary but aren't likely to be transmitted via the domestic septage that is found in portable restrooms because the virus simply doesn't live long enough outside the human body to infect someone new. Other pathogens are quite transmittable and can cause long-term, chronic health conditions. The various types of hepatitis generally fall into this category. Although workers in the portable sanitation industry rarely deal with blood, the rules of government agencies such as OSHA extend to OPIM, or "other potentially infectious material." That's any type of bodily fluid besides blood that can cause exposure to bad pathogens. 1 Included on the OPIM list is, "All body fluids where it is difficult or impossible to differentiate between body fluids." So while urine and feces are not specifically listed as OPIM, it is difficult to argue that you can safely differentiate what is in the tank to be absolutely certain there's no OPIM there. And who hasn't found a needle or some other suspect item in a portable restroom? On this basis we conclude the standards pertaining to bloodborne pathogens and OPIM do apply to our industry insofar as worker safety is concerned. That is because the standard protects workers who can "reasonably be anticipated to come into contact with blood or OPIM as a result of doing their job duties." The requirements of OSHA's Bloodborne Pathogens standard can be found in Title 29 of the Code of Federal Regulations (29 CFR 1910.1030). Your state may have its own standard that is more stringent—but in the US at least, the local standard cannot be less stringent than the federal one, which states what employers must do to protect workers. In general, the standard requires employers to: • Establish an exposure control plan (ECP). This is a written plan to eliminate or minimize occupational exposures. Within it you need a list of all the jobs in your company where exposure to blood or OPIM can be reasonably anticipated—along with a list of the tasks and procedures performed by those workers that result in their exposure. You must also document how you determined this and describe your company's procedures to eliminate or minimize the risk. See the box on page x for more on what must be included in your ECP. • Update the plan annually to reflect changes in tasks, procedures, and positions that affect occupational exposure, and also technological changes that eliminate or reduce occupational exposure. In addition, employers must annually document in the ECP that they have considered and begun using. 1 OSHA lists these as semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva in dental procedures, any body fluid that is visibly contaminated with blood, and all body fluids in situations where it is difficult or impossible to differentiate between body fluids; any unfixed tissue or organ (other than intact skin) from a human (living or dead); and HIV- containing cell or tissue cultures, organ cultures, and HIV- or HBV-containing culture medium or other solutions; and blood, organs, or other tissues from experimental animals infected with HIV or HBV.

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