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 , 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 , 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
- Physicians, physician’s assistants, nurses, nurse practitioners, and other healthcare employees in clinics and physicians’ offices
- Employees of clinical and diagnostic laboratories
- Housekeepers in healthcare and other facilities
- Personnel in hospital laundries or commercial laundries that service healthcare or public safety institutions
- Tissue bank personnel
- Employees in blood banks and plasma centers who collect, transport, and test blood
- Freestanding clinic employees (e.g., hemodialysis clinics, urgent care clinics, health maintenance organization (HMO) clinics, and family planning clinics)
- Employees in clinics in industrial, educational, and correctional facilities (e.g., those who collect blood, and clean and dress wounds)
- Employees designated to provide emergency first aid
- Dentists, dental hygienists, dental assistants and dental laboratory technicians
- Staff of institutions for the developmentally disabled
- Hospice employees
- Home healthcare workers
- Staff of nursing homes and long-term care facilities
- Employees of funeral homes and mortuaries
- HIV and HBV research laboratory and production facility workers
- Employees handling regulated waste
- Custodial workers required to clean up contaminated sharps or spills of blood or OPIM
- Medical equipment service and repair personnel
- Emergency medical technicians, paramedics, and other emergency medical service providers
- Fire fighters, law enforcement personnel, and correctional officers (employees in the private sector, or the Federal Government, or a state or local Government in a state that has an OSHA-approved state plan)
- Maintenance workers, such as plumbers, in healthcare facilities and employees of substance abuse clinics