Is the use of personal protective equipment appropriate only after implementing such engineering controls?
According to OSHA’s traditional adherence to a hierarchy of controls and basic industrial hygiene practice, engineering controls and work practice controls must be instituted as the primary means of eliminating or minimizing employee exposure. This has always been required by OSHA. If the fluids collected in the suction canisters that you describe meet OSHA’s definition of blood or OPIM, they would constitute a hazard regulated by the Bloodborne Pathogens Standard. In accordance with paragraph (d)(2)(i) of the standard, an employer must use engineering and work practice controls that eliminate occupational exposure or reduce it to the lowest feasible extent. After the proper engineering and work practice controls have been implemented and a possible exposure still exists, personal protective equipment must be provided and its use ensured by the employer. • Is the onsite pouring of fluids without the aid of an engineering control an acceptable practice under the Bloodborne Pathogens Sta
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