Updated July 2003

Needlesticks, Bloodborne Pathogens, and OSHA

By Bob DelPrete

Former Southern Region Safety & Health Rep/Pompano Beach Steward

Recently, at a large USPS facility in one of the states of the Southern Region of the APWU, a worker who was attempting to dislodge mail that was jammed in a machine was accidentally stuck with a needle.  The needle was protruding from an envelope and it appeared to be similar to those used by health care providers that draw a small sample of blood from a patient’s finger.  Unfortunately, the envelope was not withheld from the mail flow, so the return address and the address of destination could not be ascertained.  Thus, the exact nature and use of the needle could not be verified.  Fortunately, an astute steward informed the worker (and the USPS!) of that worker’s rights with regard to medical care in such instances, and that employee eventually received the medical care he was legally entitled to.

Situations like these are not too uncommon for postal workers and they are cause for great concern and anxiety.  We all should be aware of the problems related to needlesticks, as well as our rights guaranteed by OSHA when such occurrences take place.  This information was provided by the Centers for Disease Control, (404) 371-5460, and the National Post Exposure Prophylaxis Hotline (1-888-448-4911):

·        BBP’s are microorganisms that are in human blood.  They can infect and cause disease in humans.

·        Through a BBP exposure, one can contract HIV (human immunodeficiency virus), HBV (hepatitis B virus), and HCV (hepatitis C).

·        Other than the normal means of transmission, medical professionals generally consider a needle stick to be the most serious means of exposure that could lead to contraction of any of these diseases.

·        An open would is another means of exposure; however, a scab is considered to be as effective a deterrent as uncompromised skin by the vast majority of medical professionals.

·        According to the National Post Exposure Prophylaxis Hotline, the chances of acquiring HIV through a needlestick are only 3 in 1000!

·        The chances are “further reduced significantly” when appropriate medication is administered orally (see below).  This medication should be ingested within a couple of hours or, at the very least, a couple of days after the exposure, and followed up with additional treatment for about one month.

·        The chances of acquiring HBV are 100X’s greater than the acquisition of HIR, or 3 in 10; they too are diminished if the appropriate medication is administered within 72hours.  This medication should be followed up with an additional inoculation shortly thereafter.

·        If a worker was vaccinated against Hepatitis B before the exposure, he can be considered protected.

·        There are no medications that can be taken before or after a possible exposure to prevent the acquisition of Hepatitis C.

OSHA’s bloodborne pathogen standard, as specified in 29CFR 1910.1030, contains specific information related to an employee’s rights when a bloodborne pathogen exposure has occurred.  Some of the important points specified in this standard are summarized below.

·        As per the standard, if there is any employee with occupational exposure, a written exposure control plan shall be developed to eliminate or minimize employee exposure.  Among other things, it must specify the procedure for evaluations and circumstances surrounding exposure incidents.  It must be made available to employees and be updated annually, or otherwise, as needed.  It will also tell who will get training and vaccinations.

·        This standard applies to all employers with employees who bear the risk of “occupational exposure” to BBP’s.  If applicable, the employer must take “actions” to reduce “exposure.”

·        “Exposure” is defined by the standard as a “reasonably anticipated skin, eye, mucous membrane, or parenteral contact with “blood” or “other potentially infectious materials” (OPIM) that may result from the employee’s duties.”

·        “Blood” is defined by the standard as human blood, human blood components, and products made from human blood.

·        “OPIM” is considered by the standard as that which could be any of an assortment of human body fluids, e.g. cerebrospinal fluid, semen, vaginal secretions, synovial fluid (fluid found in joints), pleural fluid (fluid found in lungs), saliva in dental procedures, etc.  It also could be tissues, organs, and cells containing HIR, HBV, including that from an animal.

·        “Actions” are defined by the standard as engineering and work practice controls, personal protective equipment (PPE); training; medical surveillance; HBV vaccinations; signs and labels; etc.

·        Employers MUST provide personal protective equipment at no cost to employees who could be exposed and must clean, repair, and replace them as soon as possible, as per the standard.

·        The HBV vaccine and vaccination series must be offered within 10 working days of initial assignment to those who have occupational exposure to blood or OPIM.  Exceptions are allowed if the employee has previously completed the HBV series, if immunity has been confirmed, or if it is not otherwise recommended for medical reasons.

·        Employers are required by the standard to make the HBV vaccine and vaccination series available to all employees who have had exposure, as well as post exposure evaluations and follow-ups.  This must be done at no cost by a licensed health care professional, according to the recommendations of the US Public Health Service. 

·        Employees may refuse these vaccinations, but must sign a declination form.  They may request and obtain the vaccinations at a later date at no cost.

·        Following an exposure, a confidential medical evaluation and follow-up must be made available to the employee.  This includes documenting the circumstances of the exposure, identifying and testing the source individual if possible, testing the exposed employee’s blood if he/she consents, post exposure prophylaxis (treatment), counseling, and evaluation of reported illnesses.

·        The employer must receive a written opinion by the health care professional, but it is limited to a statement whether the employee has been informed of the need for more evaluation and treatment, ONLY!  The employer must give this to the employee within 15 days of the evaluation.

·        If the blood is from another worker, that other worker shall have his blood tested for these diseases.  However, that worker can rightfully refuse to have his blood tested with NO recourse by the other employee.  If a sample of the other employee’s blood is available, that sample shall be tested and the results documented.  This need not be done if the source individual is known to have an infectious disease.  Results of all tests shall be made available to the exposed employee and he shall be informed of applicable laws and regulations concerning the identity and infectious status of the source individual.

·        Contaminated work surfaces resulting from spills of blood, OPIM, etc. must be decontaminated with a disinfectant and only trained personnel shall perform this function as per the standard.  HAZWOPER (Hazardous Waste Operations Emergency Response) team members who have received BBP clean up training shall perform this function as per the EL 812 Hazardous Materials and Spill Response Handbook.  NOTE:  A minimum water/bleach solution of at least one part bleach to ten parts of water is recommended.

·        Any medical expenses for an examination and treatment of a BBP exposure are paid for by the employer (USPS), and not by workmen’s compensation or by medical insurance.

·        The standard also specifies that the records pertaining to the exposure must be kept for the duration of the employee’s employment PLUS 30 years.

·        Specimens shall be placed in containers that prevent leakage during collection, handling, processing, storage, transport, or shipment, as per the standard.  The universal biohazard symbol followed by the term “BIOHAZARD” in fluorescent orange or orange/red color (with lettering or symbols in contrasting color) must be on all containers used to store, transport, or ship blood or OPIM.  NOTE: Module C of the DMM, Issue 55, Jan. 10, 2000, specifies how the USPS must package blood, urine specimens, etc. prior to acceptance.

Additionally, when such an occurrence takes place, those involved should try to save the envelope or package that the needle was wrapped in so that an exact determination of the use of the sharp can be attempted through the return and the destination addresses.  This was not done in the situation depicted above.  More often than not these hazardous items find their way back in the mail stream, endangering the health and welfare of other workers. . . try not to let this occur!  Also, if the situation involved a spill, again try to save the envelope or package that contained the material for determination purposes, if necessary.

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Last modified: July 13, 2007