Hospitality Workforce How Exposure Control Plan Can Help Counter Risks

How Exposure Control Plans Can Help Counter Risks of Blood-Borne Pathogens

By ASHLEY HENDERSON, HUB INTERNATIONAL

Even as the Florida restaurant industry continues to respond to the state’s Hepatitis A epidemic, where the pace of new cases in 2019 prompted the August call of a public health emergency, a related issue in the risk of Hepatitis B may be getting sidelined for now but still requires attention. Over 3,000 cases of Hepatitis A were reported through Nov. 30 in Florida, with many workers in all types of food establishments testing positive. Restaurant owners have responded accordingly, both bringing in state health officials to provide vaccinations or giving their workers the time to get them. Many also say they have stepped up their preventative protocols like handwashing after bathroom use as Hepatitis A can spread through transmission by infected food handling.

Then, there’s Hepatitis B. Early in the year, Starbucks became the inadvertent poster child for that risk when 4,100 employees successfully petitioned to have needle disposal boxes placed in the coffee shop’s bathrooms. It stemmed from worsening problems with drug users carelessly disposing of their used hypodermic needles in bathrooms. In Florida, though, the issue of improved food service protocols to reduce exposures to Hepatitis B may been overshadowed by the outbreak of Hepatitis A.

The rise in both Hepatitis A and B relates to the opioid crisis — a greater use of hypodermic needles in unclean conditions by a user population that’s increasingly transient. Florida’s restaurant industry has numerous low-paying jobs that attract infected workers who may spread Hepatitis A. But the risk of blood-borne transmission of pathogens like Hepatitis B and other potentially infectious materials (OPIMs) should also be a concern — not just to restaurants but also to the larger hospitality industry in general.

The risk of blood-borne infections is high in hospitality. Kitchens can’t function without very sharp knives; one slip can raise the risk of an exposure. Housekeeping workers in hotels are increasingly provided with devices to use instead of their hands when reaching under mattresses or changing sheets because of needles that could be underneath or in the folds. And a lot of trash is created that may carry sharp objects and is carried or dragged to a dumpster. If the object breaks through and cuts the worker or spills in a common area, there’s another exposure.

OSHA requires restaurants to have an exposure control plan that is reviewed and updated at least annually. Surprisingly few guard against the risk of bloodborne pathogens with such a plan, but it’s important for protecting employees and controlling costs that can arise when accidents happen.

OSHA (and others) provide guides on creating an exposure control plan, but for the purposes of blood-borne pathogens, it’s important to be aware of the criteria that you’re required by OSHA to meet. Here are the top considerations: 1. First, your plan must be made available to all workers, and they must be educated on its purpose and use. It must reflect all required protections. All workers who have been exposed to blood-borne pathogens must be offered vaccinations at the employer’s expense. Should they decline, they must sign a specifically worded legal document to that effect. Recordkeeping is critical, as is observing privacy guidelines on OSHA logs and incident forms.

2. The plan must specify control measures to eliminate or minimize employee exposures. This encompasses both personnel assignments and engineered solutions. For personnel assignments, a narrow group of people, like a back-of-the-house restaurant manager, is trained in relevant first aid functions and charged with ensuring safety standards are met. For engineered solutions, it’s key to try to eliminate puncture exposures. If complete elimination of the hazard is not possible, other precautions may be taken. Needle resistant gloves are one form of personal protection, along with heavier duty trash disposal bags and needledisposal boxes. Guidelines and company training procedures also help: Trash bags should not be filled to the brim and casually thrown over the shoulder or dragged to the dumpster when use of rollers can move them faster and safer.

The burden is on restaurants and hotels to keep workers and patrons safe in an environment where serious diseases are more easily spread than ever before. An exposure control plan is one way to manage the risks more effectively.

About the author: Ashley Henderson is an Assistant Vice President and Senior Risk Consultant at global insurance brokerage Hub International.