Color Coding for Health

Color coding is not just important for hospitals and assisted living facilities. How about schools, offices and factories? Is it any less important in those facilities to keep cleaning materials used in restrooms separate from those used in the cafeteria? Of course not!

  1. Contract cleaners can demonstate their ability to clean for health in a highly visual way
  2. School systems can identify the color coding system in posters placed where staff and students can see and support
  3. In factories where turnover in cleaning personel is high, color-coding assists in training
« Reduce Cleaning Cost Inside Your Facility by Keeping Dirt and Germs Outside | Main | Color Coding Microfiber Helps Facilities Stop Cross-Contamination and HAIs »

When Was Your Last Janitorial Staff Training in Bloodborne Pathogens?

HOSPECO, blood spill clean-up kitThere are two sides to the OSHA coin when it comes to training of janitorial staffs in BBP, or bloodborne pathogens. The Federal Code, 29 CFR 1910.1030, has not changed recently. So in this letter of interpretation, dated April 17, 1992, regarding 29 CFR 1910.1030, supervisors of custodial staffs might take comfort in this excerpt:

"OSHA does not generally consider maintenance personnel/janitorial/housekeeping staff employed in non-health care facilities to have occupational exposure."

Before you tune out, however, here is how OSHA addresses the issue in a broader context. From that same letter, the following twist:

"At the same time, it is the employer's responsibility to determine which job classifications or specific tasks and procedures involve occupational exposure. If OSHA determines, on a case-by-case basis, that sufficient evidence exists of reasonably anticipated exposure, the employer will be held responsible for providing the protections of 29 CFR 1910.1030 to the employees with occupational exposure."

So, the question is, can a janitor on your staff or cleaning for your service be reasonably expected to come in contact with bodily fluids? Is that a situation you could "reasonably anticipate"? Well, of course it is. Custodial staffs routinely deal with bodily fluids. And the monetary consequences of not having offered adequate training when a lawsuit or OSHA complaint is filed could be many times the cost of training and providing adequate protection.

Here are circumstances where a custodial worker might reasonably be anticipated to be exposed to bodily fluids and have a "need to know" regarding bloodborne pathogens:

  • Cleaning up vomit
  • Collecting or transporting sharps (needles) in trash bags*
  • Cleaning and emptying feminine hygiene receptacles
  • Cleaning a toilet, urinal, sink or restroom floor
  • Cleaning up broken glass - the glass may be contaminated by somone who was cut, or the custodial worker themself may be injured
  • Cleaning carpet or hard surfaces after an injury
  • Cleaning wrestling mats, locker rooms and showers

*Even in an office or school setting, some occupants are likely to use needles or stick pens to inject insulin. 8.3% of Americans have diabetes and 5% of those have type 1. Most type 1 and some type 2 diabetics take insulin. Your planning may need to address having sharps containers provided and a protocol for how such shots are administered.

The best reason for learning about 29 CFR 1910.1030, however, is to protect your cleaning staff and to help them protect themselves. Bloodborne disease can seriously alter a worker's life.

In general terms, you undertake four tasks:

  • Developing and documenting an Exposure Control Plan
  • Determining which employees are at risk and what precautions should be taken
  • Reviewing PPE, or personal protective equipment, needed for various risks identified
  • Providing annual training (and finding ways to keep it fresh) and training new employees considered "at risk" under the definitions you create in your ECP mentioned above.

OSHA has a helpful document in drafting your Exposure Control Plan you can download by clicking Exposure Control Plan Templates.

Here is a link to the OSHA information about the regulation: Bloodborne Pathogens 

Here is a link to training regarding Bloodborne Pathogens in both English and Spanish: Training Resource 


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