Tattoo & Body Artist Training Manual: An OSHA Summary

Due to its invasive nature, there is a potential for serious infection to occur during tattooing. The needles that are used to penetrate the skin at various sites on the body can become contaminated by blood or serum.
 
HIV (the virus which causes AIDS), Hepatitis B and Hepatitis C viruses are present in blood and spread by infected blood entering another person’s bloodstream. This can happen during tattooing, when needles used for penetrating the skin are contaminated with infected blood or serum and are not replaced before use on another person.
 
The person at risk may be the next client being treated with the contaminated instrument or you, if you accidentally penetrate your skin with the contaminated instrument. This is called a ‘needle-stick’ injury. Contact with infected blood, serum or contaminated instruments on open cuts, sores or broken skin can also lead to infection.
 
Blood or serum does not have to be visible on an instrument or needle for infection to be transmitted. It is important to note: all instruments that penetrate the skin of a person, including needles and attachments such as nozzles, needle bars and tubes, must be sterile.

Cross-contamination

Some of the ways which cross-contamination can occur in tattooing are as follows:
 
– If one or more operators share the same equipment or materials.
 
– If used and clean instruments come into contact with one another.
 
– If clean instruments are placed on unclean surfaces.
 
– If strict operator hygiene is not observed.
 
– If contaminated dressings, spatulas, disposable gloves are not disposed of immediately and appropriately after use.
 
– If structural facilities, furnishings and fittings of the premises are not adequately protected, or thoroughly cleaned between clients.
 
– If towels and other articles used on clients are not changed or thoroughly cleaned between clients.

 

Operators should be aware of the potential for unprotected surfaces and equipment to become contaminated with blood and serum during tattooing. Some examples of how this can occur are as follows:

– Adjusting overhead light fittings.

– Adjusting settings on power packs.

– Answering telephones.

– Touching ink bottles or ink trays.

– Touching curtains, drapes or bin lids.

– Adjusting furniture and equipment. Clients, operators and the community can be at risk if cross-contamination occurs.

 

OSHA 29 CFR 1910.1030

In March 1992, OSHA’s Bloodborne Pathogen Standard, 29 CFR 1910.1030 took effect. This standard was designed to prevent deaths and bloodborne infections. While the standard was primarily aimed at hospitals, funeral homes, nursing homes, clinics, law enforcement agencies, emergency responders, and HIV/HBV research laboratories, anyone who can “reasonably expect to come in contact with blood or potentially infectious materials” as part of their job is covered by the standard. OSHA’s summary of the standard is below.

Purpose

OSHA Standard 29 CFR 1910.1030 limits occupational exposure to blood and other potentially infectious materials since any exposure could result in transmission of bloodborne pathogens which could lead to disease or death.

Scope

Covers all employees who could be “reasonably anticipated” as the result of performing their job duties to face contact with blood and other potentially infectious materials. OSHA has not attempted to list all occupations where exposures could occur. “Good Samaritan” acts such as assisting a co-worker with a nosebleed would not be considered occupational exposure. Infectious materials include semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva in dental procedures, any body fluid visibly contaminated with blood and all body fluids in situations where it is difficult or impossible to differentiate between body fluids. They also include any unfixed tissue or organ other than intact skin from a human (living or dead) and human immunodeficiency virus (HIV)- containing cell or tissue cultures, organ cultures and HIV or hepatitis B (HBV)-containing culture medium or other solutions as well as blood, organs or other tissues from experimental animals infected with HIV or HBV.

 

Exposure Control Plan

Requires employers to identify, in writing, tasks and procedures, as well as job classifications, where occupational exposure to blood occurs–without regard to personal protective clothing and equipment. It must also set forth the schedule for implementing other provisions of the standard and specify the procedure for evaluating circumstances surrounding exposure incidents. The plan must be accessible to employees and available to OSHA. Employers must review and update it at least annually–more often if necessary to accommodate workplace changes.

 

Methods of Compliance

Mandates universal precautions, (treating body fluids/materials as if infectious) emphasizing engineering and work practice controls. The standard stresses hand-washing and requires employers to provide facilities and ensure that employees use them following exposure to blood. It sets forth procedures to minimize needlesticks, minimize splashing and spraying of blood, ensure appropriate packaging of specimens and regulated wastes and decontaminate equipment or label it as contaminated before shipping to servicing facilities. Employers must provide, at no cost, and require employees to use appropriate personal protective equipment such as gloves, gowns, masks, mouthpieces and resuscitation bags and must clean, repair and replace these when necessary. The standard requires a written schedule for cleaning, identifying the method of decontamination to be used in addition to cleaning following contact with blood or other potentially infectious materials. It specifies methods for disposing of contaminated sharps and sets forth standards for containers for these items and other regulated waste. Further, the standard includes provisions for handling contaminated laundry to minimize exposures.

 

Hepatitis B Vaccination

This Standard requires vaccinations to be made available to all employees who have occupational exposure to blood within 10 working days of assignment, at no cost, at a reasonable time and place, under the supervision of licensed physician/licensed healthcare professional and according to the latest recommendations of the U.S. Public Health Service (USPHS). Prescreening may not be required as a condition of receiving the vaccine. Employees must sign a declination form if they choose not to be vaccinated, but may later opt to receive the vaccine at no cost to the employee. Should booster doses later be recommended by the USPHS, employees must be offered them.

 

Post-Exposure Evaluation and Follow-Up

Specifies procedures to be made available to all employees who have had an exposure incident plus any laboratory tests must be conducted by an accredited laboratory at no cost to the employee. Follow-up must include a confidential medical evaluation documenting the circumstances of exposure, identifying and testing the source individual if feasible, testing the exposed employee’s blood if he/she consents, post-exposure prophylaxis, counseling and evaluation of reported illnesses. Healthcare professionals must be provided specified information to facilitate the evaluation and their written opinion on the need for hepatitis B vaccination following the exposure. Information such as the employee’s ability to receive the hepatitis B vaccine must be supplied to the employer. All diagnoses must remain confidential.

 

Hazard Communication

Requires warning labels including the orange or orange-red biohazard symbol affixed to containers of regulated waste, refrigerators and freezers and other containers that are used to store or transport blood or other potentially infectious materials. Red bags or containers may be used instead of labeling. When a facility uses universal precautions in its handling of all specimens, labeling is not required within the facility. Likewise, when all laundry is handled with universal precautions, the laundry need not be labeled. Blood which has been tested and found free of HIV or HBV and released for clinical use, and regulated waste which has been decontaminated, need not be labeled. Signs must be used to identify restricted areas in HIV and HBV research laboratories and production facilities.

 

Information and Training

This Standard mandates training within 90 days of the effective date, initially upon assignment and annually–employees who have received appropriate training within the past year need only receive additional training in items not previously covered. Training must include making accessible a copy of the regulatory text of the standard and explanation of its contents, general discussion on bloodborne diseases and their transmission, exposure control plan, engineering and work practice controls, personal protective equipment, hepatitis B vaccine, response to emergencies involving blood, how to handle exposure incidents, the post-exposure evaluation and follow-up program, signs/labels/color-coding. There must be opportunity for questions and answers, and the trainer must be knowledgeable in the subject matter. Laboratory and production facility workers must receive additional specialized initial training.

 

Recordkeeping

Calls for medical records to be kept for each employee with occupational exposure for the duration of employment plus 30 years, must be confidential and must include name and social security number; hepatitis B vaccination status (including dates); results of any examinations, medical testing and follow-up procedures; a copy of the healthcare professional’s written opinion; and a copy of information provided to the healthcare professional. Training records must be maintained for three years and must include dates, contents of the training program or a summary, trainer’s name and qualifications, names and job titles of all persons attending the sessions. Medical records must be made available to the subject employee, anyone with written consent of the employee, OSHA and NIOSH–they are not available to the employer. Disposal of records must be in accord with OSHA’s standard covering access to records.

OSHA 29 CFR 1910.1030

For a complete copy of the Occupational Safety and Health Administration’s (OSHA’s) Bloodborne Pathogen Standard, see chapter 4.

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