Hep-B Vaccine for first aid Responders
Do you offer the hep-B vaccination to your first aid trained employees at non-medical facilities? I had always offered the vaccine or had a declination form when trained employees on BBP/ first aid and CPR. The expectation to a certain degree is that nobody will bleed all over the place or need CPR so, based on that, it's not required by OSHA right but, does it make sense to even offer it to employees? the reason I ask, is that I been challenged on this safety best practice. what's your opinion?
Comments (9)
If they are trained and authorized to respond to medical emergencies within your workplace, then they will have a reasonable anticipation of occupational exposure to blood or other potentially infectious materials (OPIMs). Because of this, yes, they will be required to be offered the Hep. B vaccine.
Kentucky has an approved state plan, but they come out with a court ruling several years ago confirming this, stating that if you trained people in first aid/CPR and they have the potential to respond to a medical emergency, then you are required to create an exposure control plan and follow all other applicable bloodborne pathogens requirements. I know we're a state plan, but I've always interpreted federal OSHA to be the same way. How can you treat someone during first aid scenarios and not have a potential for exposure to their blood or OPIMs?
The only way I've seen companies get out of this is they just train employees in CPR/First Aid for personal benefit and say that all first aid is to be self-administered, meaning if they can't treat themselves, then they wait on Fire/EMS or transport them to the hospital/clinic/etc. However, then you run a risk of violating 1910.151.
You can't plan that nobody will ever need CPR, nobody will ever get cut and require someone else to help bandage them, etc. OSHA doesn't look at the likelihood of being actually exposed to blood or OPIMs as much as they look at whether or not there is a risk at all. Sure, your employees may never have to perform CPR on a co-worker, help someone control bleeding, or any other type of medical emergency. However, if the situation does occur and that responder was not offered the Hep. B virus (HBV) vaccine and subsequently gets the HBV, then an OSHA citation and penalty will be the least of your worries!
Amen Drew!
I always tell my industrial customers that there are "Costs of Doing Business". Full compliance to 1910.151 and 1910.1030 (which has the requirement of Hep Shots in it for those so needing them) is but one of those many costs!
When I was a Facility Manager I was lucky to have visiting Occ Health Nurses. I put them in charge if maintaining our Hep B Shot compliance, unless someone chose the declination option, then I took over. Of course I had overall management responsibility as the employer rep. It was convenient as when someone needed the vaccine the RN could just start the routine of three shots.
Understanding the danger of Bloodborne Pathogens it is just the ethical thing to do for an employer to do for someone that is risking their own safety for the benefit of other injured employees. It is the least you can do!
Drew is spot on in his last statement. Should one of your First Aid or First Responders pick up Hep B on the job and you have not followed 1910.1030 the resulting OHSA Serious or Willful citation is the least of your worries. If some smart employee's lawyer can prove negligence ("N") the WC laws of your state are likely negated and you are going to circuit court for a Liability Case. If this "N" word is proven you are talking MILLIONS$
Fully agree with Tom and Drew. If you're training them in first aid, you're acknowledging a risk of occupational exposure to blood/OPIM.