If your staff is not exposed to human blood or animal blood infected with Hepatitis B virus used for human research, then you do not need to comply with the Hepatitis B part of the bloodborne pathogen (BBP) standard. OSHA has clarified that the BBP standard generally only applies to occupational exposures to human blood, blood components, and other potentially infectious materials (OPIM) unless the animal blood is known to be infected with the Human Immunodeficiency Virus (HIV) or Hepatitis B Virus (HBV). However, in a February 1994 journal article (JAVMA, Vol. 204, No. 3), AVMA recommends voluntary compliance with OSHA’s bloodborne pathogens standard in order to best protect employees working in veterinary or other animal settings. Employees involved in lab research where animal blood is infected with human blood are mandated to comply with all aspects of BBP standard.

Bloodborne Pathogen Standard Provisions that Apply to Veterinary Professionals:

It should be reasonably anticipated that your employee could be potentially exposed to human blood or OPIM as well. Irrespective of whether the clients are injured or not, we recommend that you follow OSHA’s BBP standard’s guidelines such as universal precautions and the use of PPE. Ensuring that the employees wear PPE such as gloves, aprons, masks, etc. is a substantial step to prevent BBP transmissions in your workplace. ‘Reasonably anticipated’ in the context of OSHA regulations is referring to a situation where there is sufficient likelihood for a hazard to occur. For example, the employees in a commercial laundry facility with a contract to launder contaminated linen from medical/dental settings would be considered to have reasonably anticipated exposure to blood and Other Potentially Infectious Materials (OPIM) and would be covered by the BBP standard, while a commercial laundry cleaner without such contracts where reasonably anticipated exposure to blood or OPIM is less likely to occur may not be covered by BBP standard.

Veterinary employers are not mandated to provide the HBV vaccinations to their employees who are not exposed to human blood as dental and medical employees are. However, as AVMA stated in the JAVMA article above, veterinary employers are recommended to voluntarily comply with BBP guidelines and may include HBV vaccinations as well. A veterinary employer, in their professional judgment, makes a case for the need for HBV vaccinations due to potential exposure to human blood or OPIM, and they must provide them to protect their employees.

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At Gamma Compliance Solutions, we come to work every day because we want to solve the biggest problem in regulatory compliance: helping you make sure you have met all the requirements. Over the years, we have developed different compliance packages to suit practices at any stage in the OSHA and HIPAA compliance process. We have designated this area of our blog to post important updates and share key resources and guidelines you need to best protect your employees and yourselves. In addition to checking this area of our blog, follow us on social media to receive notifications when we share important information.