The Occupational Health and Safety Administration (OSHA) has the responsibility to inspect long-term care communities to ensure the safety and well-being of patients and staff. Inspections can be random, based on a complaint, or as a follow-up after an incident or a violation. Once an inspection is opened, OSHA frequently looks for violations of the Bloodborne Pathogens Standard — a standard that, implemented correctly, minimizes or eliminates employee exposure to bloodborne diseases as well as other infectious materials. A recent article published by the American Health Care Association and the National Center for Assisted Living (AHCA/NCAL) examines key points within the Bloodborne Pathogens Standard and how LTC communities are addressing the standard. 

Key to successfully meeting  that standard is creating a written exposure control plan (ECP). This plan describes the approach to protecting individuals from pathogens such as Hepatitis B, Hepatitis C, and HIV in the facility. Once developed, it should be used consistently, and reviewed and updated regularly to consider incidents, check measurable safety standards, and obtain employee feedback. 

A comprehensive ECP includes standard and universal precautions, treating all blood and certain other bodily fluids as though they are infectious and establishing protocols under the assumption that every resident is infectious, regardless of diagnosis. Additional precautions range from engineering controls (building and equipment), such as the use of Sharps disposal containers and biohazardous waste disposal systems, to the use of personal protective equipment (PPE) and work practice controls such as handwashing. Training and record keeping are important components of a comprehensive plan as well.

In a separate article, AHCA/NCAL reminds operators of LTC communities that 29 states have currently developed their own Occupational Safety and Health (OSH) programs that must be addressed. These state-specific programs meet or exceed the federal OSHA requirements. 22 state plans cover both private- and public-sector employees. Seven additional state plans cover public employees only; there, privately owned facilities still follow federal requirements. A list of states with their own OSH plans is available here.