A bloodborne pathogen program in civilian aircraft accident investigation

The Occupational Safety and Health Administration (OSHA) amended 29 CFR Part 1910 in 1991 to include regulations addressing occupational exposure to bloodborne pathogens (BBP). The rule affects all employees that have the potential for occupational exposure to these pathogens. The National Transportation Safety Board (NTSB) and Federal Aviation Administration (FAA) are the primary organizations involved in aircraft accident investigation in the United States. No other organizations in this country have a similar scope or mandate of responsibility. An accident scene presents significant challenges in terms of implementing a program which was primarily envisioned to affect personnel in "traditional" healthcare delivery facilities; the OSHA requirements now had to be met in the chaotic, inhospitable, and logistically difficult environment of an aircraft accident site. Unanticipated issues such as heat-related conditions, performance of physically demanding work in cumbersome gear, biohazard trash disposal from remote sites, and a host of other problems had to be dealt with. The FAA, in close cooperation with other Federal agencies, developed a training and administrative program to meet the requirements of the OSHA BBP rule as it relates to the unique environment of an aircraft accident site. The program has been implemented and successfully tested under actual field conditions at several major aviation accidents that have occurred recently. This article provides observations on the FAA's program and lessons learned from its implementation.