I have a client that was issued audit violations more on safety and I am a quality and environmental consultant. The client has asked me to help them resolve these issues. I will list them below as hope to gain from others wisdom. This client is a small company of 10 employees and the business is environamental related. They do liquid & solid industrial waste such as oils, antifreeze, contaminated water, etc. and sludge. The new business they want to take on means resolving the following:

1) Bloodbourne pathogens - they are required to have a program in place & training of employees for this. Can I learn about this and provide the training or does it need to be from a certified person.

2) Lockout/tagout - I am very familar with this but again do I need to be certified to provide training on this. It does not appear that they need this at all on their location.

3) Drug screening program - they have truck drivers and have a DOT type of drug testing program in place. I may need to find out more about this but does this meet the ASAP or DISA drug screening programs.

Thank you for any help.:thanx:

Try www.osha.gov look at the index and it will lead you to what you need and www.dot.gov use the search or look into the regs under Title 49.

Thanks for your help. Any other suggestions would be appreciated.

OSHA's BBP standard applies to employer's with one or more employees who can reasonably be expected to come into contact with blood and other specified body fluids in carrying out or in performing their duties. Once it is determined that the standard applies, determining occupational exposure and instituting control methods and work practices are the key requirements. The trainer does not have to be certified but should be knowledgeable in the subject matter.

I would be surprised if LOTO does not apply. If they have anyone performing service or maintenance on machines or equipment they must have LOTO procedures.

Just curious, what type of audit was this?

They really do not come into contact with blood. it is mostly wastewater, oils and sludges. Often it comes out of factory pits and who knows whats in there but not likely to have blood. They do not work on the vehicles or maintain them. All of there vehicles are serviced externally and no other equipment. I can write them a procedure for it but do not see much use for it there. Thanks for you posting.

This was called a PICS audit and BP uses it for supplier approval.

How do you determine if BBP applies or not. Is there a definition for application or do they define what industries it applies to. Thanks again.

Try this, remember if the training is applicable and I dont think you need to be certified to train just objective evidence that training has been done.

How do you determine if BBP applies or not. Is there a definition for application or do they define what industries it applies to. Thanks again.

Here is some info and training material.

10232
10233

It would appear that from the information that I was correct to some extent that they would be exempt from the bloodborne pathogen training. However, the audit findings also require them to have someone trained in first aid. This person will need the bloodborne training. Thanks for all your help.:thanks:

Not only BBP, but also a complete BBP program including the Hepatitis B program....This isn't like teaching people to use a fire extinguisher. Once an employee is required to perform 1st Aid a whole new world of regulatory compliance requirements is opened up

Not only BBP, but also a complete BBP program including the Hepatitis B program....This isn't like teaching people to use a fire extinguisher. Once an employee is required to perform 1st Aid a whole new world of regulatory compliance requirements is opened up

In the absence of an infirmary, clinic, or hospital in the near proximity to the workplace, OSHA requires the employer to have a person trained to render first aid and this requirement does indeed dovetail to several other OSHA standards.

In the absence of an infirmary, clinic, or hospital in the near proximity to the workplace, OSHA requires the employer to have a person trained to render first aid and this requirement does indeed dovetail to several other OSHA standards.



Regulations (Standards - 29 CFR) -

• Part Number: 1910
• Part Title: Occupational Safety and Health Standards
• Subpart: K
• Subpart Title: Medical and First Aid
• Standard Number: 1910.151
• Title: Medical services and first aid.

1910.151(a)

The employer shall ensure the ready availability of medical personnel for advice and consultation on matters of plant health.

1910.151(b)

In the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render first aid. Adequate first aid supplies shall be readily available.

1910.151(c)

Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.


Your interest with BBP is in the 2 links here

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10051

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10052

There willl also be a need for PPE training and a program, control of medical waste, and one or two other items

Do you mean here?

Thanks for the lesson, I'll just toss my degree in Occupational Health & Safety Management and 20 some odd years in the field. I didn't think you needed a long lecture so I didn't bother with a great deal of elaboration about all the wherefore's and thou shall's.........Here's the deal, if you get involved in the process without the appropriate background make sure your E&O is paid up. Next to environmental management, Health & Safety has the next greatest liability for the professional.