[MCOH-EH] [EXTERNAL] Re: Holding Blood for HIV testing for 90 days

Kathy.Dayvault at dekalbmedical.org Kathy.Dayvault at dekalbmedical.org
Tue Sep 12 12:09:05 PDT 2017
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Thanks, 

You know these days with advances in technology and virology, a PCR is a 
valuable tool.

Kathy Dayvault, RN, BSN, MPH
 Manager, Occupational Health and Safety 
 WorksWell Onsite
 Dekalb Medical  2701 North Decatur Road
 Decatur, GA 30033
ph: 404.501.4972 Fax:404-501-2045
kathy.dayvault at dekalbmedical.org




From:   "Hodgson, Michael - OSHA" <Hodgson.Michael at dol.gov>
To:     MCOH/EH <mcoh-eh at mylist.net>, 
Date:   09/12/2017 03:00 PM
Subject:        Re: [MCOH-EH] [EXTERNAL] Re: Holding Blood for HIV testing 
for 90 days
Sent by:        "MCOH-EH" <mcoh-eh-bounces at mylist.net>



Hi, thanks for the inquiry, I asked Sheila Arbury, RN, MPH, our go-to BBP 
staffer.  She pulled out one interpretation letter on this subject. It 
upholds the 90-day preservation rule.  Waiting to hear back from 
enforcement, but it’s not clear whether OSHA has actually ever cited 
someone for the failure to follow the law.  Letter of July 16,2008:
 
Background: OSHA's Occupational Exposure to Bloodborne Pathogens standard 
addresses the requirement for blood testing as part of a post exposure 
evaluation at 29 CFR 1910.1030(f)(3)(iii)(B). The standard states: "If the 
employee consents to baseline blood collection, but does not give consent 
at that time for HIV serologic testing, the sample shall be preserved for 
at least 90 days. If, within 90 days of the exposure incident, the 
employee elects to have the baseline sample tested, such testing shall be 
done as soon as feasible" (boldface added). 

Question: It is our experience that laboratories will typically only store 
a blood sample for 7-30 days. Following a work-related bloodborne 
pathogens exposure incident, if an employee consents to baseline blood 
collection, but does not give consent at that time for HIV serologic 
testing, is it permissible for the employer to have the employee sign a 
consent verifying their understanding of the lab's procedure of the 30-day 
storage time frame? 

Reply: No, an employer may not have employees sign a consent form waiving 
the right to have untested baseline blood maintained for the minimum time 
limitation of 90 days. According to the preamble to the final rule, the 
Centers for Disease Control and Prevention (CDC) stated, "the worker 
should be advised to report and seek medical evaluation for any acute 
febrile illness that occurs within 12 weeks after the exposure. Such an 
illness, particularly one characterized by fever, rash, or 
lymphadenopathy, may be indicative of recent HIV infection." The preamble 
adds: "CDC has further stated that the first 6-12 weeks are 'when most 
infected persons are expected to seroconvert' (Ex. 15, MMWR 1989; 38 [No. 
S-6]:13)." The final rule specifically provides that untested baseline 
blood samples be preserved for at least 90 days in order to account for 
the 12 week post-exposure period when an acute retroviral illness may 
develop and to afford the employee the opportunity to know his/her 
immediate post-exposure HIV status even if consent for HIV testing was 
initially withheld. [56 Federal Register 64159 (1991).]
 
https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=27199
 
 
Sheila Arbury, RN, MPH 
Office of Occupational Medicine and Nursing
 
 
From: MCOH-EH [mailto:mcoh-eh-bounces at mylist.net] On Behalf Of 
Kathy.Dayvault at dekalbmedical.org
Sent: Monday, September 11, 2017 8:50 AM
To: MCOH/EH <mcoh-eh at mylist.net>
Cc: MCOH-EH <mcoh-eh-bounces at mylist.net>
Subject: [EXTERNAL] Re: [MCOH-EH] Holding Blood for HIV testing for 90 
days
 
His only response was that he realized holding blood for 90 days would be 
problematic. 

Dr. Hodgson,  OSHA Director or Occupational Medicine and Nursing,  is 
probably the best to weigh in. 

Dr. Hodgson....any thoughts about the portion of the BBP standard in 
regards to holding blood for 90 days in the even the exposed person 
changes their mind about testing? 

Thanks, 

Kathy Dayvault, RN, BSN, MPH 
 Manager, Occupational Health and Safety 
 WorksWell Onsite 
 Dekalb Medical  2701 North Decatur Road 
 Decatur, GA 30033 
ph: 404.501.4972 Fax:404-501-2045 
kathy.dayvault at dekalbmedical.org 




From:        Amy Olson <aolson9 at jhmi.edu> 
To:        'MCOH/EH' <mcoh-eh at mylist.net>, 
Date:        09/11/2017 10:58 AM 
Subject:        Re: [MCOH-EH] Holding Blood for HIV testing for 90 days 
Sent by:        "MCOH-EH" <mcoh-eh-bounces at mylist.net> 




Kathy, 
Out of curiosity, what was the OSHA response? 
AO 
  
From: MCOH-EH [mailto:mcoh-eh-bounces at mylist.net] On Behalf Of 
Kathy.Dayvault at dekalbmedical.org
Sent: Monday, September 11, 2017 10:49 AM
To: MCOH/EH <mcoh-eh at mylist.net>
Cc: MCOH-EH <mcoh-eh-bounces+kathy.dayvault=dekalbmedical.org at mylist.net>
Subject: Re: [MCOH-EH] Holding Blood for HIV testing for 90 days 
  
We do not have the capacity in our lab to hold samples and I have had this 
conversation with an OSHA representative earlier this year. 

We strongly encourage employees at the time to go and have their blood 
drawn, around 90 % of them do. 

Technology has advanced, and if they came back requesting labs, we would 
draw them and perform viral loads on anything positive. 

It might not be the best solution especially if the viral load comes into 
question,  we may end up owning it from a WC perspective, after lots of 
conversation with an ID. 

Thanks, 

Kathy Dayvault, RN, BSN, MPH 
Manager, Occupational Health and Safety 
WorksWell Onsite 
Dekalb Medical  2701 North Decatur Road 
Decatur, GA 30033 
ph: 404.501.4972 Fax:404-501-2045 
kathy.dayvault at dekalbmedical.org 
 



From:        "Thrasher, Terri" <Terri.Thrasher at cchmc.org> 
To:        MCOH/EH <mcoh-eh at mylist.net>, 
Date:        09/11/2017 10:18 AM 
Subject:        Re: [MCOH-EH] Holding Blood for HIV testing for 90 days 
Sent by:        "MCOH-EH" <
mcoh-eh-bounces+kathy.dayvault=dekalbmedical.org at mylist.net> 





I interpreted it the same way. 
 
From: MCOH-EH [mailto:mcoh-eh-bounces at mylist.net] On Behalf Of Amy Olson
Sent: Monday, September 11, 2017 8:13 AM
To: 'MCOH/EH' <mcoh-eh at mylist.net>
Subject: Re: [MCOH-EH] Holding Blood for HIV testing for 90 days 
 
Thanks for your response. I understand what you have described. The OSHA 
Standard states the following: 
1910.1030(f)(3)(iii)(B) 
If the employee consents to baseline blood collection, but does not give 
consent at that time for HIV serologic testing, the sample shall be 
preserved for at least 90 days. If, within 90 days of the exposure 
incident, the employee elects to have the baseline sample tested, such 
testing shall be done as soon as feasible. 
 
Given that certain source testing results would lead to wanting to 
document baseline HIV status of the employee, it would seem that this 
particular section of the standard cannot be upheld if an employee 
actually had a blood draw and opted to NOT consent to HIV testing. Again, 
I have never encountered this, but it is a possibility and I am curious as 
to how people are addressing this. Am I missing something? 
From: MCOH-EH [mailto:mcoh-eh-bounces at mylist.net] On Behalf Of Nancy 
Rodway
Sent: Monday, September 11, 2017 7:15 AM
To: 'MCOH/EH' <mcoh-eh at mylist.net>
Subject: Re: [MCOH-EH] Holding Blood for HIV testing for 90 days 
 
As a board certified pathologist and board certified occupational 
physician, your lab cannot exceed the 30 days without validity studies. 
And validity studies are cumbersome for the laboratorians. 
Why hold them?  With post-exposure testing, the source results guide your 
clinical decision making pretty quickly.   
 
Nancy Rodway MD MS MPH FASCP FCAP FACOEM 
 
 
Sent from Outlook 
 



From: MCOH-EH <mcoh-eh-bounces+nrodway=hotmail.com at mylist.net> on behalf 
of Amy Olson <aolson9 at jhmi.edu>
Sent: Monday, September 11, 2017 5:59 AM
To: 'MCOH/EH'
Subject: [MCOH-EH] Holding Blood for HIV testing for 90 days 
 
Happy Monday from Florida, 
Our hospital is doing well in St. Petersburg. Many thanks to people who 
have reached out. 
 
As I wait for the sun to rise, I’m going through some things and I have a 
question. As I understand the BBP standard, we are required to hold an 
employee’s blood for 90 days so they could decide at a future date to have 
it tested for HIV. I have yet to run into a situation where an employee 
deferred testing, but now that I have direct responsibility for the 
Exposure Control Plan, I have more interest in ensuring what is written is 
something we can deliver. Our lab is continuing to research, but when I 
posed the question about holding blood and testing within 90 days, this is 
the response I got: “It’s not that we can’t hold a sample for 90 days. 
There isn’t a commercial ref lab that has validated this particular 
testing for a sample >30 days old. That seems to be the dilemma for HIV ½ 
analysis.” 
 
What are other people doing? Am I misinterpreting the standard? 
 
Thank you, 
Amy Olson 
Director, Employee Health and Wellness
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