Implementation of Blood and Saliva Labs

There are many issues involved, that should be considered when implementing blood and other potentially infectious materials such as saliva into the health science labs. The importance of providing a healthy and safe work environment and total compliance of all federal, state, and local protocols are among some of these topics at hand. While the addition of real blood and other biohazardous materials may aid in the edification and enrichment of our instructive labs, the true goal should be to minimize the potential hazards of this implementation while creating an improved lab curriculum.

First and foremost we should develop a purpose, plan, and background that ensures all employees with occupational exposure to human blood-borne pathogens and students are protected from contracting blood-borne disease via implementation of a blood-borne pathogens exposure control plan. This plan must follow the requirements established by the Department of Public Health in the State of Florida and be adopted by U.S. Occupational Safety and Health Administration, as well as any Alachua County Health Department Rules and Regulations (

This plan and background should include the following: exposure criteria and determination (what is an exposure and what determines if someone is exposed), the exposure plan itself (what to do when someone has been exposed), universal precautions (wearing gloves, goggles, lab jackets, etc.), work practice controls used to eliminate or minimize employee exposure (sinks for frequent hand washing, no gum chewing or applying lip gloss during labs), housekeeping (janitorial staff, cleaning labs), possible storage of specimens, and proper labeling, bagging, and disposal of biohazardous materials.

The exposure control plan would require a Safety Coordinating Committee that would review and update the exposure control plan at least annually and hold additional meetings to develop, review, revise, and implement the exposure policy and control plan as new or revised job positions are developed and/or as new or modified tasks and procedures are developed which affect positions with possible occupational or student exposure (

After a plan has been developed and safety committee is formed, a health care provider and campus-wide infectious waste management company must be contracted. The health care provider must provide services for immediate medical follow-up after any and all incidents have been reported. These services include possible blood testing, vaccination, and counseling in accordance with the current U.S Public Health Service. The infectious waste management company must provide services that properly handles, treats, sterilizes, decontaminates, and disposes of all waste materials including sharps and contaminated laundry in accordance to federal, state, and local laws.

In addition to these services provided, the issue of consent (blood screening for HBV, HIV, etc), confidentiality (employer, school, records), and liability (waivers) is a major concern when implementing blood and saliva labs. All incidences must be documented for both employees and students within twenty-four hours of the exposure, therefore a hired record keeper would be required to establish and maintain accurate records for any and all forms of incidence, consent, confidentiality, and liability. It is imperative that all incidences involving students are in compliance to the Family Educational Rights and Privacy Act better known as the “Buckley Amendment”(The Family Educational Rights and Privacy Act (FERPA) 20 U.S.C. § 1232g; 34 CFR Part 99). All medical records must be kept for at least thirty years according to OSHA standards and reviewed for preventive measures only with the consent of the employee and/or student (Title 29 Federal Code of Regulations, Part 1910.20 Access to Employee Exposure and Medical Records). With this in mind, it would be critical to provide legal services, contracted or otherwise, for all employees and/ or students when issues arise involving any exposure incident as a liability precaution.

Another issue that should be considered is the proper training and certification of all employees and/ students. An Occupational Health program should be developed with certified individuals or health care professionals to train all employees and students in blood-borne pathogen exposure and control. All employees and students must have annual training in order to receive certification to handle and participate in blood and other potentially infectious materials in laboratory settings. First aid and Cardiopulmonary Resuscitation courses should also be taken at the health care professional level and certification should be received before any employee and student participate in any lab. Also any immunizations or vaccinations should be provided for employees and students. Prior to the start of lab courses, individuals involved in any lab should have an up to date immunization record and health care professionals for preventative measures should check all records annually.

Lastly, there is the concern of costs and expenses when introducing blood and saliva into a college laboratory setting. Hiring certified individuals such as health care professionals, special janitorial staffing, training, legal services, and so forth contribute to the growing list of expenses for this addition. The providing (or not providing) of personal protective equipment such as goggles, lab jackets, gloves, masks, etc. and medical services such vaccinations, immunizations, post exposure evaluations and follow up for all employees and/or students is a cost factor that should be considered, since OSHA Law requires all employees to have these resources available to them at no expensive (Title 29 Federal Code of Regulations, Part 1910.20 Access to Employee Exposure and Medical Records). The proper disposal of biohazardous materials requires special attention. For example, any sharps would have to be disposed of within twenty-four hours. Contracting a waste management company that is able to dispose of these materials, sharps, etc. in a certain time frame would definitely be a cost concern.

In summation, there are major issues of concern that should be addressed when implementing blood and other potentially infectious materials into a lab setting. Ideally the goal here is to provide students with adequate training so they may pursue their studies and eventually their careers safely and knowledgeably. The use of blood and saliva must be evaluated in light of its risk to students as well as employees, and the fulfillment of this department's academic mission.

References:

UW-Madison's Bloodborne Pathogens Reference and Training Manual

OSHA Instruction CPL 2-2.69 Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens, November 27, 2001

Family Policy Compliance Office U.S. Department of Education.

U.S. Department of Labor Occupational Safety and Health Administration Fact Sheets