OSHA has released interim guidance on preventing occupational exposure to Zika virus for outdoor and mosquito control workers as well as for healthcare and laboratory workers. Guidance here.

Summary of NNU’s response and concerns in letter to OSHA:

NNU is concerned about the treatment of OSHA’s Bloodborne Pathogen (BBP) Standard in this guidance document. OSHA’s BBP Standard requires employers to create an Exposure Control Plan that assesses risk for occupational exposure to bloodborne pathogens and then utilizes engineering and administrative controls to prevent exposure. Where engineering or administrative controls are not fully protective, the employer is required to provide PPE (29 CFR 1910.1030 (d)(2)(i)). The standard states:

Personal protective equipment will be considered “appropriate” only if it does not permit blood or other potentially infectious materials to pass through to or reach the employee’s work clothes, street clothes, undergarments, skin, eyes, mouth, or other mucous membranes under normal conditions of use and for the duration of time which the protective equipment will be used. (29 CFR 1910.1030(d)(3)(i))

 The guidance document, however, discusses a difference between universal and standard precautions, stating:

In healthcare, standard precautions can be used to expand the universal precautions required by the BBP standard by adding several protections (including expanded PPE) not covered by the BBP standard. Standard precautions include, but are not limited to, hand hygiene and the use of PPE to avoid direct contact with blood and other potentially infectious materials…. (page 4)

However, we know that the BBP Standard requires employers to provide engineering controls and PPE that prevent direct contact with blood or other potentially infectious materials. Hand washing after removal of PPE is also required by the BBP Standard (29 CFR 1910.1030(d)(2)(v)). We have written to federal OSHA, requesting that they clarify their guidance document to indicate that employers are required under the BBP Standard to provide PPE and other equipment “to avoid direct contact with blood and other potentially infectious materials” and that occupational Zika virus exposure is fully covered by the BBP Standard.