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Ask the expert: OSHA’s definition of healthcare worker

Q: There is a lot of confusion as to who are considered healthcare workers with regard to OSHA standards. Can you please clarify for us?

A: From a compliance standpoint, OSHA does not have standards specific to healthcare workers (HCW), nor does it have a definition of HCW that you can automatically apply to a particular standard.

I assume you are referencing worker exposure concerning the bloodborne pathogens standard, which applies if workers meet this definition of occupational exposure:

Occupational Exposure means reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee’s duties.

It does not matter what the job title is, or how you identify your business. It is the potential exposure to the hazard that matters.

Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens [1], provides a lengthy list of the type of workers are usually covered under the standard (see below), but it emphasizes that the scope of the “standard is not limited to employees in these jobs.”  It’s the employer’s responsibility to identify potential exposure among its workers or job classifications.

Using the definition above, you should be able to determine which of your employees are covered under the bloodborne pathogens standard, but there may be, and probably are, other OSHA standards that apply to your workforce.

This is a common situation facing staff members charged with administering their facility’s OSHA compliance program, and similar situations will certainly be addressed during the OSHA Healthcare Advisor’s “Q&A Roundtable: Solutions to Your Compliance Challenges” audioconference [2], Tuesday, May 19, 2009, 1:00-2:00 p.m. (Eastern).

Job classifications that may be associated with tasks that have occupational exposure to blood and other potentially infectious materials