Which first-aider types are covered by OSHA’s Bloodborne Pathogens Standard?
According to OSHA, any general industry or shipyard employer that has one or more employees with occupational exposure falls under 29 CFR 1910.1030, the Bloodborne Pathogens Standard. “Occupational exposure” is reasonably anticipated contact with blood or other potentially infectious materials that may result from the performance of an employee’s duties.
OSHA does not list in the regulation the jobs or tasks with occupational exposure, so you, the employer, must determine which ones are covered at your workplace. Often the question over first aiders comes up.
Three of four first-aider categories are covered
Applicability questions focus on four first-aider categories:
- Employees designated to perform first aid — According to OSHA, if an employee is trained in first aid and identified by the employer as responsible for rendering medical assistance as part of his or her job duties, that employee is covered.
- Employees who routinely provide first aid to co-workers with the knowledge of the employer — The agency explains that these first aiders may also fall, de facto, under the first-aider designation, even if the employer has not officially designated the employee as a first-aid provider. Therefore, this category is covered because the employer anticipates or expects the employee to render first-aid assistance as part of his or her job duties.
- Employees who render first aid as a collateral duty, responding only to workplace incidents — These employees too have occupational exposure, even though their primary job assignment is not the rendering of first aid or other medical assistance. Therefore, these first aiders are covered by all the provisions of §1910.1030. However, OSHA offers a de minimis policy (or loophole) regarding hepatitis B vaccination for this collateral-duty first-aider category, if four conditions are met. See section XIII.F.8. of OSHA directive CPL 02-02-069 to review the specific criteria.
- Good Samaritans — Because you cannot anticipate Good Samaritan acts, you cannot anticipate these types of exposures, so Good Samaritans do not have occupational exposure. These employees are not covered unless they otherwise meet the above category (1), (2), or (3) descriptions. If they don’t meet those descriptions, note that OSHA encourages (but does not require) employers to offer follow-up procedures to employees if they suffer an exposure incident while voluntarily assisting a fellow employee.
Final thoughts
Without proper protections and training, covered first aiders could put themselves at serious risk of disease or death from exposure to bloodborne pathogens. Providing bloodborne pathogens protections according to the standard does not just make compliance sense; it makes common sense.
