Article Date: 11/1/2001

How to comply with federal standards to protect your employees and patients.

Today's optometric practices are involved in medical care of ocular conditions. The diagnostic and treatment procedures have increased our own, our staffs' and our patients' risk of exposure to blood-borne pathogens. But we can reduce these risks by following appropriate procedures. In fact, federal standards require that we make all workplaces safe from blood-borne contamination for our employees. What do these standards mean and how can you meet them? Here's how.

What you need to do

To safeguard your employees, you as an employer must:

You also must provide a "biosafety manual. "It should include both the Exposure Control Plan and Work Practice Controls, and identify office areas at particular risk of biohazard. Review it at least once a year to ensure that it's up-to-date. It must advise employees of potential health hazards and include instructions on practices and procedures that they must follow.

How to do it

We've addressed these requirements by including the biosafety manual as a section of our office manual. It covers the possibility of exposure to blood-borne pathogens (Exposure Control Plan) and preventive steps to take (Work Practice Controls).

Whether as part of your office manual or a separate document, you must also include the following in the biosafety manual to comply with the standards.

  1. an accessible copy of the standards. They're in the Federal Register under: Part II, Department of Labor, Occupational Safety and Health Administration, 29 CFR Part 1910.1030, Occupational Exposure to Blood-borne Pathogens; Final Rule (

  2. a general explanation of the epidemiology and symptoms of blood-borne diseases

  3. an explanation of modes of transmission of such diseases

  4. an explanation of your Exposure Control Plan -- a copy must be available if requested

  5. an explanation of how to recognize tasks that may involve exposure to blood and other potentially infectious material

  6. an explanation of the use and limitations of methods that prevent or reduce exposure, including decontamination and disposal of personal protective equipment

  7. an explanation of how to select personal protective equipment (which must be on hand for staff members, free of charge)

  8. information about the Hepatitis B vaccine and explanation that it will be offered for free

  9. information about actions to take and persons to contact in an emergency involving blood or potentially infectious materials

  10. an explanation of the procedure to follow if the employee is exposed, including how to report the incident and what medical follow-up will be available

  11. information about the post-exposure evaluation and follow-up. You must give the employee a physician evaluation as well as a copy of the physician's report and a plan of action or prognosis developed at the visit

  12. an explanation of the signs, labels and/or color-coding required on biohazard areas and/or equipment (such as the red "sharps" containers and trash bags specific to biohazard materials disposal). See sidebar.

  13. an opportunity for interactive questions and answers with the person conducting the training session. Provide this training in-office or through outside personnel in a "continuing education" environment.

Use these recommendations as the basis of your own training program to protect your staff and patients.

Dr. Ryan is vice-chair of the Washington State Board of Optometry and A.R.B.O. Judicial Committee.


What to Include in Your Exposure Control Plan and Work Practice Controls

The following guidelines are based on the Centers for Disease Control and Prevention, Occupational Safety and Health Administration, Veteran's Administration and Federal Register recommendations and requirements.

1 Remove particulate matter from surfaces and instruments using one of these disinfecting agents. Don't get them in anyone's eye(s):

  1.   3% hydrogen peroxide

  2. 10% household bleach/water solution

  3. 70% or higher concentration of ethanol or isopropanol (alcohol)

  4. other solutions proven clinically effective

2 Wash your hands for at least 10 seconds with antibacterial soap before and after physical contact with a patient and after restroom use.

3 Never recap needles with two hands. Use the "scoop" method or a recapping device.

4 Contaminated non-disposable "sharps" (needles, etc.) and other instruments shall be disinfected with the autoclave. Place instruments waiting to be autoclaved in a shallow, well-marked container such as a stainless steel or plastic tray. Instruments should lie flat so no one risks a "stick" from a non-sterile instrument.

5 Contaminated disposable sharps shall be discarded in a labeled red sharps container. These containers should be non-crushable. No sharps shall be bent, recapped, or broken off.

6 Eating, drinking, smoking, applying cosmetics or lip balm, or handling contact lenses are prohibited where there's a reasonable likelihood of occupational exposure (primarily in the exam rooms). Contact lens dispensing is not included and is necessary, but no person should dispense contact lenses if they have an open cut on their hands or fingers. Contact lenses should be dispensed only once they're disinfected.

7 Do not keep food or drinks where blood or potentially infectious materials are present.

8 All procedures involving blood or potentially infectious materials (including tears and saliva) shall be performed in a manner that minimizes splashing, spraying, splattering and generation of droplets. When it can be expected that such will occur, use protective gear (goggles, gloves, aprons or lab coats, resuscitation bags, pocket masks, other ventilation devices).

9 Place specimens of potentially infectious material (such as cultures) in a container that doesn't leak during collection, handling, processing, storage, transport or shipping.

10 Employees shall remove immediately, or as soon as feasible, any garments penetrated by blood or other potentially infectious materials --whether it's their own or a patient's.

11 Employees shall wear gloves when it can be anticipated that there may be hand contact with blood or other infectious materials. Gloves don't protect against puncture injuries; prolonged use may result in small holes. Manufacturers may supply defective gloves.Inspect them before use. Don't reuse or disinfect them. Maintain the work site in a clean and sanitary condition.

12 A written schedule may be used to specify which staff person has responsibility for a given office area.

13 All equipment plus environmental and working surfaces shall be cleaned and decontaminated using an approved germicidal agent. Certain instruments require special procedures -- see manufacturer's manual.

  1. Contaminated work surfaces shall be decontaminated: after completion of procedures; immediately or as soon as practical, when visibly contaminated; after any spill; at the end of the work day, by the person the doctor or office manager assigns to that area.

  2. Soiled linens or towels shall be handled as little as possible and must be placed in a plastic bag in the area of use. All plastic bags will be considered to contain potentially infectious material. They should be clearly marked or unique in a way that ensures that they're known to contain biohazardous materials or waste.

  3. Employees in contact with soiled linens must wear gloves and/or other appropriate personal protective equipment. Hypoallergenic gloves, glove liners, powderless gloves or similar alternatives shall be available to those with latex allergies.

14 Remove protective coverings (plastic wrap, aluminum foil, or paper) used to cover equipment and environmental surfaces as soon as feasible when they become overtly contaminated.

15 All bins, pails, cans and similar receptacles intended for reuse that have a likelihood of contamination with blood or other potentially infectious materials shall be inspected and decontaminated on a regularly scheduled basis and immediately upon visible contamination. They should be a different color than regular (paper) waste containers.

16 Employees should obtain the following appropriate immunizations. An exception could be granted in the case of allergies or other known adverse reactions for which a person might be at risk.

  1. Seasonal influenza

  2. Hepatitis B

  3. Hepatitis A

  4. Tetanus/diphtheria

17 Post-exposure procedures:

  1. Administer first aid to yourself or the patient.

  2. Report to the office manager as soon as practical for evaluation and prophylaxis.

    1. HIV post-exposure prophylaxis is best started within 2 hours of at-risk exposure and can include azidothymidine (AZT) (Zidovudine) 600 mg x 4 weeks and (3TC) combivir with AZT (Lamivudine) 150 mg bid x 4 weeks

    2. Route of exposure and circumstances under which it occurred must be documented.

    3. The source individual should have a blood test as soon as feasible.

    4. HBV post-exposure prophylaxis includes Hepatitis B immunoglobulin and HBV immunization as indicated.

18 Definitions (Source is the Federal Register 29 CFR Part 1910.1030):

  1. Occupational exposure: reasonably anticipated skin, eye, mucous membrane or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee's duties.

  2. Other potentially infectious materials:

    1. i. The following human body fluids: semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva, blood. When in doubt, treat the fluid as if it's potentially infectious.

    2. ii. Any unfixed tissue or organ (other than intact skin) from a human (living or dead).

    3. iii. HIV-containing cell or tissue cultures, organ cultures and HIV- or HBV-containing culture medium or other solutions; and blood, organs, or other tissues from experimental animals infected with HIV or HBV.

  3. Parenteral: piercing mucous membranes or the skin barrier through such events as needle sticks, human bites, cuts, and abrasions.

  4. HIV: human immunodeficiency virus.

  5. HBV: hepatitis B virus.

  6. Blood: human blood, human blood components and products made from human blood.

  7. Blood-borne pathogens: pathogenic microorganisms that are present in human blood and cause disease in humans.

  8. Contaminated: the presence or the reasonably anticipated presence of blood or other potentially infectious materials.

  9. Contaminated sharps: any contaminated object that can penetrate the skin including, but not limited to, needles, scalpels, broken glass, and broken capillary tubes.

  10. Decontamination: the use of physical or chemical means to remove, inactivate, or destroy blood-borne pathogens on a surface or item until they're no longer capable of transmitting infectious particles and the surface or item is rendered safe for handling, use, or disposal.

  11. Exposure incident: a specific eye, mouth, other mucous membrane, non-intact skin or parenteral contact with blood or other potentially infectious materials that results from the performance of an employee's duties.

  12. Universal precautions: an approach to infection control. Human blood and certain body fluids are treated as if known to be infectious with HIV, HBV, and other blood-borne pathogens. They're also known as standard precautions.



Optometric Management, Issue: November 2001