Safety audit violations - bloodborne pathogens, LOTO & drug screening

[Sean Kelley]

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.

[Randy]

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.

[Sean Kelley]

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

[Doug Tropf]

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?

[Sean Kelley]

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.

[Sean Kelley]

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

[Sean Kelley]

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.

[pilchard]

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.