During the performance of their daily jobs, healthcare workers may be exposed to infectious agents that cause disease. Put another way, occupational exposure to infectious agents transmitted by contact, droplet, airborne, or bloodborne routes may lead to infections in workers in the healthcare industry. Because of these potential workplace hazards, OSHA is concerned about occupational exposure to numerous infectious agents that cause serious diseases like tuberculosis, pandemic influenza, COVID-19, sudden acute respiratory syndrome (SARS), Middle East respiratory syndrome (MERS), monkeypox, Ebola, smallpox, measles, hepatitis B, hepatitis C, HIV/AIDS, and others.
Scope
Currently, OSHA does not have a comprehensive standard that addresses all infectious diseases in the healthcare industry. The agency’s Bloodborne Pathogens Standard (at 29 CFR 1910.1030) only covers infectious agents transmitted by the bloodborne route. Note that OSHA is working on two new rules, both aimed at healthcare employers — a COVID-19 final rule and an Infectious Diseases proposed rule.
In addition, healthcare employers in private industry are covered by the Occupational Safety and Health Act (OSH Act), which requires employers to maintain a workplace free of serious safety and health hazards. That means healthcare employers have a duty to protect their workers from serious infectious agents. Likewise, public healthcare employers located in state-plan states also fall under state laws that are equivalent to or more stringent than the OSH Act.
The delivery of healthcare services requires a broad range of workers, such as physicians, nurses, technicians, clinical laboratory workers, first responders, building maintenance, security and administrative personnel, social workers, food service, housekeeping, and mortuary personnel. Moreover, these workers can be found in a variety of work settings, including hospitals, nursing care facilities, outpatient clinics (e.g., medical and dental offices and occupational health clinics), ambulatory care centers, and emergency response settings. The diversity among healthcare workers and their workplaces makes occupational exposure to infectious agents especially challenging to fight.
Key definitions
- Administrative control: A type of workplace hazard control that uses procedures, policies, supervision, scheduling, and training as a means of protecting workers.
- Bloodborne pathogens: Pathogenic microorganisms that are present in human blood and can cause disease in humans. These pathogens include, but are not limited to, hepatitis B virus (HBV), hepatitis C virus (HCV), and human immunodeficiency virus (HIV).
- Engineering control: A type of workplace hazard control that places barriers between the worker and the hazard, such as sharps containers, self-sheathing needles, and ventilation.
- Infectious disease: A disease caused by exposure to a contact, droplet, airborne, and/or bloodborne transmissible infectious agent.
- Other potentially infectious materials (OPIM): Under the Bloodborne Pathogens Standard at 29 CFR 1910.1030, this term means (1) The following human body fluids: 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; (2) Any unfixed tissue or organ (other than intact skin) from a human (living or dead); and (3) HIV-containing cell or tissue cultures, organ cultures, and HIV- or HBV-containing culture medium or other solutions, as well as blood, organs, or other tissues from experimental animals infected with HIV or HBV.
Summary of requirements
To protect healthcare workers from infectious agents that cause disease, employers must:
- Assess and monitor infectious agent hazards in the workplace;
- Furnish to each employee employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to workers;
- Provide and ensure the use of appropriate PPE and protective clothing that shield workers from exposure; and
- Meet the requirements of OSHA regulations, such as the ones listed above, if applicable.
Healthcare employers are recommended to also:
- Perform an infectious agent exposure determination of healthcare workers;
- Develop and implement a written exposure control plan;
- Implement feasible engineering controls such as sharps containment, self-sheathing needles, ventilation, etc.;
- Implement administrative controls such as patient-handling precautions;
- Implement work practice controls such as appropriate materials handling and disposal procedures, housekeeping protocols, and hand-hygiene practices;
- Perform medical screening, surveillance, and vaccination;
- Train employees in exposure routes, types of infectious agents, and proper protective measures;
- Implement a worker-illness-reporting policy;
- Conduct investigations of worker infection cases; and
- Maintain related records.