OSHA

The Occupational Safety and Health Administration (OSHA) is an agency within the U.S. Department of Labor. It was established by Congress in 1970 to protect the safety and health of America's workers by setting and enforcing standards and by encouraging continual improvements in workplace safety and health.

The Bloodborne Pathogens Standard

OSHA published its bloodborne pathogens standard in 1991 in response to growing concerns about the health risks associated with occupational exposure to blood and other potentially infectious materials (OPIM). Among these risks are exposure to hepatitis B (HBV), hepatitis C (HCV), and HIV.

All employees who have reasonably anticipated exposure to blood and OPIM are covered by the bloodborne pathogens standard. This, of course, includes tattoo artists, piercers, permanent cosmetics technicians, electrologists, and body modification practitioners.

The bloodborne pathogens standard requires employers: to develop and implement an exposure control plan; to use engineering and work practice controls; to provide personal protective equipment (PPE) to their employees; and to offer hepatitis B vaccination at no charge to employees who have potential exposure. There are also requirements for labeling, record-keeping, and employee training at time of initial assignment to tasks where occupational exposure may occur and at least annually thereafter.

Although the bloodborne pathogens standard has clearly stated provisions, it offers employers considerable flexibility in complying with them. For example, the bloodborne pathogens standard requires the use of engineering controls, but it does not specify any ones in particular. This approach allows the employer to take into account advances in technology and medical research, and to make choices based on the needs of a specific workplace.

Another example of the flexibility OSHA gives the employer is the requirement to have an exposure control plan (ECP). Instead of requiring everyone follow the same exposure control plan, OSHA gives the employer an active role in improving safety by being responsible for:

• Making an exposure determination to evaluate work site safety
• Writing an exposure control plan to deal with those hazards
• Providing appropriate on-site training to employees
• Reviewing the results of the exposure control plan and making appropriate changes

The Needlestick Safety and Prevention Act

In 2001, Congress updated the bloodborne pathogens standard by passing the Needlestick Safety and Prevention Act.

Some of the changes to the bloodborne pathogens standard included requirements for employers to:

• annually review and update their exposure control plan
• ask non-managerial employees who have potential exposure to bloodborne pathogens for their opinions regarding the identification, evaluation, and selection of safety devices
• maintain a sharps injury log

Body Art Safety Today

Today, in 2010, occupational exposure to bloodborne pathogens is still a concern in the body art industry.

Fortunately, both employers and employees have a great deal of control as to the amount of exposure they face.

Safety training, of course, is of great importance. Body art professionals will learn best if:

• Their training builds on previous experience
• They learn practical skills that can be used immediately
• They are involved in the process of developing and maintaining shop safety
• They take professionally developed classes that supplement and enhance in-shop training

The key to being in compliance with the bloodborne pathogen standard is for employer and employees to take an active role in establishing, following, and updating a strong exposure control plan. If this is uniformly done, then workplace safety in the body art industry will be significantly improved.