How does the bloodborne pathogens standard affect employees who provide first aid?

If employees are trained and designated as responsible for rendering first aid or medical assistance as part of their job duties, they are covered by the protections of the standard. However, OSHA will consider it a de minimis violation-a technical violation carrying no penalties-if employees who administer first aid as a collateral duty to their routine work assignments are not offered the pre-exposure hepatitis B vaccination, provided that a number of conditions are met. In these circumstances, no citations will be issued.

The de minimis classification for failure to offer the hepatitis B vaccination in advance of exposure does not apply to personnel who provide first aid at a first aid station, clinic or dispensary, or to the healthcare, emergency response or public safety personnel expected to render first aid in the course of their work. Exceptions are limited to persons who render first aid only as a collateral duty, responding solely to injuries resulting from workplace incidents, generally at the location where the incident occurred. To merit the de minimis classification, the following conditions also must be met:

• Reporting procedures must be in place under the exposure control plan to ensure that all first aid incidents involving exposure are reported to the employer before the end of the work shift during which the incident occurs.

• Reports of first aid incidents must include the names of all first aid providers and a description of the circumstances of the accident, including the date and time, as well as a determination of whether an exposure incident, as defined in the standard, has occurred.

• Exposure reports must be included on a list of such first aid incidents that is readily available to all employees and provided to OSHA upon request.

• First aid providers must receive training under the bloodborne pathogens standard that covers the specifics of the reporting procedures.

• All first aid providers who render assistance in any situation involving the presence of blood or other potentially infectious materials, regardless of whether or not a specific exposure incident occurs, must have the hepatitis B vaccine made available to them as soon as possible but in no event later than 24 hours after the exposure incident. If an exposure incident as defined in the standard has taken place, other post-exposure follow-up procedures must be initiated immediately, per the requirements of the standard.