Safety First: An OSHA Primer: Exposure Control Is a Growing Concern for Security Personnel

By Kohr, Robert L.; Nobrega, Kathryn | Security Management, August 1993 | Go to article overview

Safety First: An OSHA Primer: Exposure Control Is a Growing Concern for Security Personnel


Kohr, Robert L., Nobrega, Kathryn, Security Management


SECURITY is a contact sport. Security officers may serve as the front-line medical team in emergencies, or they may have to restrain or otherwise come in contact with potentially contagious individuals. In today's society, such contact can be life threatening if the proper precautions are not taken.

On March 6, 1992, the Occupational Safety and Health Administration's (OSHA) bloodborne pathogens standard (29 CFR 1910.1030) went into effect. It is OSHA's first regulation pertaining specifically to biohazards. The new standard is predicted to prevent more than 200 of the deaths and 9,200 of the infections that occur annually as a result of workplace exposure to the hepatitis B virus (HBV) and the human immunodeficiency virus (HIV). Since both of these viruses are carried in body fluids, businesses that employ workers who are exposed to blood or other potentially infectious materials (OPIM) are responsible for implementing these regulations.

The new standard applies to, but is not limited to, the following workers: medical and health providers, morticians, fire and rescue personnel, laboratory workers, housekeeping and laundry personnel, and first-aid responders. In many industries, security personnel perform on-scene first aid and CPR, and in some cases, off-duty police, paramedics, and fire fighters moonlight as security personnel. Employees who perform such activities are required to comply with the bloodborne pathogens standard.

The bloodborne pathogens standard is performance oriented. It outlines the level of performance required, rather than giving specifics on how certain duties are to be performed. This allows the employer some flexibility.

Employers of all first-aid responders are required to prepare and implement an exposure control plan (ECP) and train employees in that plan. The ECP is a written document outlining procedures and must include the following six elements to be complete:

* The exposure determination. The exposure determination is a list of all the job titles that include among their responsibilities exposure to blood or OPIM. This is called an occupational exposure. For certain workplaces, a list of all tasks and procedures to follow when the possibility of an occupational exposure exists may also need to be developed.

* Procedures for the use of engineering controls, personal protective equipment, and safe work practices. The standard also requires observance of universal precaution at all times. Universal precaution, an approach to infection control, mandates that all bodily fluids are treated as if contaminated with HIV or HBV. Some additional procedures that may need to be documented and observed include hand washing and specialized handling, storage, and disposal practices for biohazardous materials.

Personal protective equipment (PPE) must be provided at no cost to the employee. The appropriate protection depends on the exposure. For the security officer who is a first-aid responder, access to gloves, mouth pieces, pocket masks, and eye protection may be required. It is the employer's responsibility to ensure that PPE is accessible, maintained, and used.

A documented decontamination procedure for work surfaces, equipment, general areas, and laundry must be developed. All regulated (infectious) waste must be placed in containers that are closeable, constructed to prevent leakage, and labeled with color-coded biohazard labels. …

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