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No Good Deed Goes Unpunished...Can "Good Samaritans" Trigger OSHA's Bloodborne Pathogens Standard?By Steve Parascandola and Megan Black
Many companies that maintain first aid kits and AED (automated external defibrillator) units at their facilities do not assign specific employees to provide first aid/medical assistance in times of need. Rather, companies often leave this task to volunteers (“Good Samaritans”) and do not include any such activities in an individual employee’s job description. Generally speaking, this arrangement stays clear of OSHA’s Bloodborne Pathogens Standard. However, it is not necessarily that simple. In Given the above, employers are wise to review certain factors closely when assessing whether this Standard applies to their operations. Coverage under this Standard can be a fact-specific inquiry and more questions should be asked, including the following:
If the answer is “yes” to any of the above, then potential applicability of the Bloodborne Pathogens Standard deserves closer attention. Coverage under this Standard can generate numerous requirements, including employee training, exposure control plans, personal protective equipment, vaccinations, post-exposure evaluations, medical record maintenance, and labels and signs. For more information about this Standard, please view OSHA's Bloodborne FactSheet. |
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