Needle disposal boxes in Starbucks bathrooms? It’s a safety measure that the mega coffee chain put into place in response to employee concerns over the risk of injury from hypodermic needles left in the trash by drug-using customers.

The issue over discarded needles and other hazardous items that could spread dangerous infections led 4,100 Starbucks employees to petition for the sharps boxes. It also led to a small OSHA fine of $3,100, not just over the lack of disposal containers, but for Starbucks’s failure to offer hepatitis B shots to workers who might have been exposed.

Violating federal OSHA standards designed to protect employees from such risks can lead to fines far heftier than Starbucks experienced: “Failure-to-abate” violations have gone up to $13,260 per day for each day that the violation’s not fixed. And OSHA’s civil penalties for each willful or repeated violation have risen to $132,598.

Exposures That Aren’t Unusual in any Hospitality Setting

Restaurants, bars, hotels and others should be aware of the risk of infections from pathogens and OPIMs like human or animal tissue, saliva, urine, or fecal matter that employees may encounter on the job.

• Kitchen workers in restaurants, for example, use very sharp knives. One slip can raise the risk of a bloodborne exposure.
• Housekeeping staff at hotels must take care when reaching under mattresses (or even changing the sheets) which can be hiding places for needles. It’s why they’re commonly given devices to use instead of their hands to reduce the risk.
• Employees drag or carry overfilled trash bags that can contain broken glass or other sharp objects to the dumpster, inadvertently cutting themselves or spilling OPIMs in common areas.

Still, surprisingly few hospitality industry employers guard against these risks with exposure control plans. Most just don’t think about it until they have to even though OSHA requires the development of plans, reviewed and updated at least annually, for individual facilities. Doing so is smart, not only to protect your employees, but also to better control the costs that can stem from these incidents.

Developing and Implementing an Exposure Control Plan

Various guides and templates are available for developing exposure control plans, including from OSHA. It’s important, though, to be mindful of the criteria that must be met under its bloodborne pathogens standard. Among the more critical aspects:

1. In addition to making the plan available to all workers and educating them on its purpose and use, it must reflect all required protections. All workers who have been exposed to bloodborne pathogens must be offered hepatitis B vaccinations at the employer’s expense. Should they decline, they must sign a specifically worded legal document to that effect. Record-keeping is critical, as is observing privacy guidelines on OSHA logs and incident forms.
2. The plan must outline specific control measures – whether through personnel assignments or engineered solutions – to eliminate or minimize employee exposures. That means narrow groups of people – a hotel housekeeping supervisor or a back-of-the-house restaurant manager – are trained in relevant first aid functions and ensure safety standards are met. And those engineered solutions? The more difficult it is for punctures to happen, the better. Needle resistant gloves are one form of personal protection, along with heavier duty trash disposal bags (which Starbucks is testing with needle disposal boxes). And providing guidelines on common-sense practices goes a long way, too. Trash bags should not be filled to the brim and casually thrown over the shoulder or dragged to the dumpster when use of rollers can move them faster and safer, too.

Now more than ever, a high degree of vigilance is necessary to protect against the increasingly common ways that serious, bloodborne diseases can be spread. It’s not just your employees who are at risk, but your guests, as well. An exposure control plan will help you manage the risks more effectively.

HUB International’s team of brokers is available to help your hospitality organization understand and manage risk and insurance issues at your organization.