Though OSHA’s BBP standard specifically mentions HIV and hepatitis B, they are far from the only pathogens found in blood or OPIM. It’s important to remember that the standard reflects the science and technology that was accessible to workplaces when the standard was promulgated in 1991. As advances in vaccinations and pathology continue, the standard could change to reflect additional protections that may be appropriate to mandate in the workplace.  In addition to decontamination, proper disposal is paramount to reducing exposures and keeping both workers and the public safe. Disposal of potentially contaminated waste, including sharps or saturated towels used during cleanup, is becoming a bigger issue in workplaces that interact with the public. Due to the opioid epidemic and homelessness crises across the United States, employers must now identify and control how workers are expected to interact with the sharps likely to be found in the workplace in trash receptacles, parking lots, public restrooms, and on sidewalks. Improper disposal of sharps leads to increased exposures and potential needlesticks further down the waste stream and can especially affect members of the public and sanitation workers.  Disposal requirements are dictated at the federal level by OSHA’s BBP standard, 29 CFR 1910.130 (and by Washington Administrative Code 296-823 in our state, Washington), but local municipalities and transfer stations can have specific requirements on how sharps can be handled at the landfill. Employees must know how to safely handle and dispose of sharps. For example, syringes should not be recapped, and sharps should not be tossed in the regular trash; instead, sharps should be disposed of in a puncture-resistant and leak-proof container. It’s important to note that OSHA’s standard applies to workplaces that have a reasonably anticipated exposure to a BBP or OPIM even if no exposure events have occurred. This means the standard applies to businesses with well recognized exposures outside of healthcare settings, including in the hospitality industry.  INDUSTRY EXPOSURES Food service and traditional hospitality industries such as hotels and motels have strikingly similar exposures concerning BBP, though there are especially significant exposures for hotel staff while cleaning. Both industries revolve around customers, and any time members of the public interact with a workplace, there is the opportunity for individuals to bring a BBP exposure with them. Hotel staff are among workers at the highest risk of contact with a contaminated sharp when cleaning rooms. When working in areas where a contaminated sharp could have fallen, especially cracks in furniture or piles of linens, workers should be aware of the risk and have a plan in place for safely dealing with the hazard. OSHA specifically defines contaminated laundry as laundry that has been soiled with blood or OPIM or may contain sharps. Workers and their supervisors should be specifically trained on where sharps could be found hiding in their workplace and how to respond to a needlestick event. Adult entertainment is not often discussed in occupational safety and health settings; however, this workplace has many of the same exposures as the hospitality industry. The worksite typically has low lighting and soft seating, which could easily disguise BBP hazards. While there are strict codes of conduct, semen has been found on various surfaces in clubs during compliance inspections, and semen is considered an OPIM. Depending on the laws in the city where the club operates, there could also be exposure to OPIM via vaginal secretions on dancing surfaces such as poles, especially if full nudity is permitted. Exposure is especially concerning when non-intact skin creates a pathway for pathogens to enter the body such as through small scratches and scrapes. Dancers may have ample opportunity for exposure to BBP or OPIM. Aspects of their job that have the potential to create injuries that would create an infection pathway include personal grooming, theatrical outfits and costumes with sequins or gemstones that may scratch or otherwise abrade skin, and tall shoes not designed for long periods of mobility that can pose a trip or fall hazard.  Veterinary clinics and other animal care facilities are additional examples of workplaces that are often overlooked because OSHA specifically excluded animal blood from the BBP standard. In the case of veterinary clinics, when an employee is stuck by a needle or is bitten or scratched by an animal, a BBP hazard is introduced by the worker bleeding—not the animal’s blood. If a worker is trying to give an animal a vaccination and the animal moves suddenly, causing an accidental needlestick to the worker, that sharp is now contaminated and needs to be handled and disposed of properly to prevent anyone else from being exposed to human blood. If coworkers clean up blood after their colleague is injured, it is still an exposure to blood and its pathogens. The fact is that bites, scratches, and accidental needlesticks do happen while caring for animals, so while OSHA’s standard explicitly excludes animal blood, it does not exclude the industry from BBP exposure.    Educators, care facility workers, mass transit workers, and private transit drivers, including those who work for a taxi or rideshare service, also have a reasonably anticipated exposure to BBP. These professionals may find contaminated sharps in the workplace or they might find themselves in unexpected situations where they may need to assist someone who requires first aid. This especially applies to drivers who take sick or injured passengers to the hospital or urgent care. Well-documented evidence also supports increased exposures to BBP in schools and transportation due to workplace violence incidents such as scratching, biting, spitting, or throwing body fluids on an employee. Workers are also at risk of motor vehicle accidents and gun violence in these industries. Many educators and care professionals will assist those in their charge without a second thought during an emergency; however, it is imperative that these professionals stop and use universal precautions before dealing with blood or OPIM. They must be trained on how they are expected to interact with blood or OPIM when situations arise, they must be offered the hepatitis B vaccination before an exposure happens, and they must be trained on what personal protective equipment to wear and where to find it.  Estheticians, salon workers, and body modification artists have BBP hazards in their workplaces as well. For example, there is potential for a barber to accidentally nick or cut a client. Workers who perform microblading facials and apply permanent cosmetics face the same exposures as traditional tattoo artists and piercers, who have a more obvious exposure to blood since these services must penetrate the dermis, where blood vessels reside, to get the desired effect. The use of gloves seems to be very common in the tattoo and piercing industry, but the use of other PPE such as aprons, glasses, face shields, or masks appears to be specified by the artists themselves. These types of businesses often follow the “salon model,” where the workers performing services in a business are independent contractors who rent space from the business owner, traditionally with contracts and rules of conduct to work in the space. The owner of the space is still expected to maintain a safe workplace for those independent contractors, and no salon owner wants an outbreak of a communicable disease. One way to circumvent such a situation may be to include language in a business contract that specifies that contractors are responsible for maintaining some sort of continuing education or training. Contractors may also be required to agree to use universal precautions at a minimum to be allowed to lease space. Local cities, licensing agencies, or certification boards may also have training requirements to maintain a professional title, which may include BBP training.  Taking out the trash is a high-risk task that seems universal across industries. Any waste receptacle that the public can access may be at a higher risk of containing sharps than a trash can used only by employees. Workers must be trained on how to properly carry trash to prevent contact with their body. Many workers will carry trash at arm’s length, which creates a potential contact hazard: a needle poking out of the bag could stick a worker’s leg or torso as the bag swings while the worker walks. A possible engineering control to prevent this contact could be using a hard-shelled bin on wheels to transfer waste from the trash can into the dumpster. Getting employees involved with controls and solutions for safe trash handling is a great topic at safety meetings and is an important part of an exposure control plan.  BE IN COMPLIANCE Through our work in occupational safety and health compliance, we often see exposure trends as emerging hazards in different industries. In Washington, we communicate these hazards through publications such as Division of Occupational Safety and Health Hazard Alerts and through our consultation services. Finding BBP hazards in workplaces is becoming common and is recognized across many industries. The best ways to be in compliance are reflected in citation data: using a sharps container, identifying who needs to be offered a hepatitis B vaccination, training workers, and having a written program. A good place to start is to read the regulation on OSHA’s website, but don’t forget that state plans may be more stringent than federal OSHA and you must comply with the state plan as it applies. Taking the time to assess where a worker could interact with a BBP hazard and setting up controls to prevent the interaction from happening in the first place can prevent a serious occupational disease from ruining a worker’s life.    EVA M. GLOSSON, MS, is an industrial hygiene compliance supervisor at the Washington State Department of Labor & Industries, Division of Occupational Safety and Health in Seattle. DARIAN W. DISRUD, BS, is an industrial hygiene compliance officer at the Washington State Department of Labor & Industries, Division of Occupational Safety and Health in Seattle. Send feedback to The Synergist.

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