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Bloodborne Pathogens Program

Appendix 2: Authorized Healthcare Providers

The Bloodborne Pathogens Standard is a performance standard; employers are informed of the requirements, and it is their responsibility to develop the methods of compliance. University departments are likewise given latitude in developing their programs and are free to obtain independently the services of healthcare providers. This supplement provides guidance on the qualifications of healthcare providers hired to perform services required by the standard.

The OSHA standard requires that all medical evaluations and procedures, including the hepatitis B vaccine and vaccination series and postexposure evaluation and follow-up, including prophylaxis, are provided by or under the supervision of a licensed physician or by or under the supervision of another licensed healthcare professional.

Licensed healthcare professional is defined as "a person whose legally permitted scope of practice allows him or her to independently perform the activities required by paragraph (f)." Paragraph (f) is the previous paragraph in this document.

The legal scope of practice for this professional must allow the independent performance of all the procedures related to vaccination and postexposure evaluation and follow-up. A variety of healthcare professionals may perform these functions. For example, in addition to licensed physicians, the majority of states have laws that enable advanced nurse practitioners to provide medical services independently. Nurse practitioners and clinical nurse specialists are registered nurses prepared through a formal, organized education program and certified for an advanced practical role. This group of registered nurses provides primary healthcare that includes traditional medical services as well as nursing care.

Vaccination protocols require oversight by the licensed healthcare professional. The hepatitis B vaccination must be given in the standard dose and through the standard route of administration as recommended in the USPHS/CDC guidelines. The results of any prevaccination antibody testing must be reviewed to determine if the employee is immune. Any contraindications must be fully characterized before vaccination is provided.

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