Portable Sanitation Association International

Association Insight August 9 2017

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W EEKLY EDITION AUG 9, 2017 Question of the Week: What is the portable sanitation industry standard as it pertains to bloodborne pathogens? ...continued By Karleen Kos, PSAI Executive Director Even though the standard may be known as the "bloodborne pathogens" standard, the rules encompass something known as "OPIM" or "other potentially infectious material." That's any type of bodily fluid besides blood (see a list of examples here ) that can cause exposure to bad pathogens. 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 cer tain there's no OPIM there. And who hasn't found a needle or some other suspect item in a portable restroom? So yes, 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." With that in mind, let's start with what is required of employers by l aw to protect your team from the ill - ef fects of bloodborne pathogens and OPIM. The requirements of OSHA's Bloodborne Pathogens standard can be found in Title 29 of the Code of Federal Regulations at 29 CFR 1910.1030. Your state may have its own standard that is more stringent – but in the US at least, the standard cannot be less stringent that the federal one which states what employers must do to protect workers. In general, the standard requires employers to: • Establish an exposure control plan. This is a written plan to eliminate or minimi ze 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 policies and procedures to eliminate or minimize risk. Check out item #14 on this list for more information about what your plan must contain. • Update the plan annually to reflect chan ges 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 plan that they have considered and begun using ap propriate, commercially - available effective safer devices (e.g., gloves, masks, face shields, waterproof clothing, etc.) designed to eliminate or minimize occupational exposure. Employers must also document that they have solicited input from frontline wor kers in identifying, evaluating, and selecting effective engineering and work practice controls. • Implement the use of universal precautions (treating all human blood and OPIM as if known to be infectious for bloodborne pathogens). This means using gloves, masks or face shields, and protective clothing if blood or OPIM exposure is anticipated. Generally speaking, that would be any time a worker is pumping a tank or handling waste. Use of engineering and work practice controls to limit exposure is also part of universal precautions. • Identify and use engineering controls. These are devices that i solate or remove the bloodborne pathogens hazard from the workplace. They include things like having tongs for removing sharps safely from the tank and disposal containers on the trucks. PAGE 2 CONTINUE D ON PAGE 3

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