Skyline Environmental, Inc. is providing a summary of employee applicability and vaccination issues raised by the revised United States Department of Labor Occupational Safety and Health Administration (OSHA) Bloodborne Pathogens Standard. Please note that the New Jersey Public Employees Occupational Safety and Health (PEOSHA) agencies have adopted the OSHA regulations and have at least the same requirements as OSHA.

The association between poor hygiene, raw sewage and infectious disease is well established. However, in the United States, no work-related outbreaks of Hepatitis or Bloodborne Pathogens have been reported among sewage treatment plant workers. Data is sparse; thus this statistic may be modified as more data is developed. The threat of blood contamination is considered an improbable scenario by regulatory agencies such as the Center for Disease Control (CDC) in a group of workers who are expected to be wearing appropriate personal protective equipment to prevent exposure to blood and other body fluids. The risk of occupational exposure to a potentially infectious material increases if the sewage worker is not following accepted practices of good personal hygiene and/or wearing the appropriate personal protective equipment.

Initially, Bloodborne Pathogens hazards were primarily associated with Health Care Workers (HCW) and Public Safety employees. OSHA has since adopted the policy that the revised Bloodborne Pathogens Standard (Standard) applies to all occupational exposure to blood and other potentially infectious material (OPIM). OSHA’s conclusion is that employees who have reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or OPIM that may result from the performance of the employee’s duties (“occupational exposure”) are at risk of infection by Bloodborne Pathogens. Please note that parenteral refers to piercing the skin barrier (this mode of transmission presents the greatest hazard to the employee). The CDC and the National Institute for Occupational Safety and Health (NIOSH) have expressed support for this OSHA approach.

By relating the Standard coverage to all occupational exposures, OSHA hopes to protect all employees at risk regardless of their job title or place of employment. OSHA has not attempted to list all of the operations/worksites and name all job classifications where occupational exposure may occur. OSHA anticipates that when the Employer prepares the now required Exposure Determination Plan, it should identify job classifications with occupational exposure.

In accordance with PEOSHA/OSHA regulations, the Authority should discuss the following immunization issues with its Licensed Health Care Professional (LHCP). The United States Public Health Service Advisory Committee on Immunization Practices (ACIP) strongly recommends that all workers who may have an occupational exposure to Bloodborne Pathogens be vaccinated against (or have documented immunity to) Hepatitis B, Influenza, measles, mumps and rubella (MMR), and varicella. OSHA follows current ACIP recommendations for its immunization requirements (i.e. pre-exposure and post-exposure antibody testing).

The United States Environmental Protection Agency (USEPA) and the ACIP recommend that employees at risk of soil-contaminated injuries should be up-to-date on Tetanus and Diphtheria immunizations. Please note that the regulatory caution is that these immunizations must be up-to-date in frequency to be effective and many adults let them lapse.