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

[Hudson, T. Warner]

We've handled around 4000 BBP exposures in last 8 years here and no one has ever chosen this route.  Seems like a rule in search of a problem we cannot find.  Warner

T. Warner Hudson, MD FACOEM, FAAFP
Medical Director, Occupational and Employee Health
UCLA Health System and Campus
Office 310.825.9146
Fax 310.206.4585
Pager 800.233.7231  ID 27132
E-mail twhudson at mednet.ucla.edu<mailto:twhudson at mednet.ucla.edu>
Website www.ohs.uclahealth.org<http://www.ohs.uclahealth.org>

From: MCOH-EH [mailto:mcoh-eh-bounces at mylist.net] On Behalf Of Amy Olson
Sent: Monday, September 11, 2017 5:13 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)<https://na01.safelinks.protection.outlook.com/?url=https%3A%2F%2Fwww.osha.gov%2Fpls%2Foshaweb%2Fowalink.query_links%3Fsrc_doc_type%3DSTANDARDS%26src_unique_file%3D1910_1030%26src_anchor_name%3D1910.1030(f)(3)(iii)(B)&data=02%7C01%7Ctwhudson%40mednet.ucla.edu%7C4985b6ed874c4b9a494208d4f90e81c5%7C39c3716b64714fd5ac04a7dbaa32782b%7C0%7C0%7C636407288082151040&sdata=Em1Q4u03Nszyuj%2BE6BZnrZ9xbtx8HXzNLbF%2Fkj4x1ao%3D&reserved=0>
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<mailto: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





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________________________________
From: MCOH-EH <mcoh-eh-bounces+nrodway=hotmail.com at mylist.net<mailto:mcoh-eh-bounces+nrodway=hotmail.com at mylist.net>> on behalf of Amy Olson <aolson9 at jhmi.edu<mailto: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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