5 OSHA Bloodborne Pathogens and Exposure Control

Recognizing bloodborne pathogen hazards

OSHA’s Bloodborne Pathogens Standard, 29 CFR 1910.1030, applies when employees may reasonably be expected to have occupational exposure to blood or other potentially infectious materials (OPIM) while doing their work.

Bloodborne pathogens include hepatitis B virus (HBV), hepatitis C virus (HCV), and human immunodeficiency virus (HIV). Exposure may occur through a needlestick or other puncture, contact with broken skin, or contact with mucous membranes such as the eyes, nose, or mouth.

OPIM includes certain human body fluids, unfixed human tissues or organs, and other materials specified in the standard. Whether occupational exposure exists depends on the tasks and procedures an employee performs, not just the employee’s job title. For example, handling contaminated sharps or cleaning up blood may involve occupational exposure.

Building and maintaining the exposure-control plan

An employer with employees who have occupational exposure must establish a written Exposure Control Plan (ECP) designed to eliminate or minimize exposure. The plan must be accessible to employees and include:

• An exposure determination identifying job classifications and tasks in which exposure can occur.

• A schedule and method for implementing required protections, including work practices, personal protective equipment (PPE), vaccination, training, and recordkeeping.

• Procedures for evaluating the circumstances of an exposure incident.

The employer must review and update the plan at least annually, and when job tasks or procedures change in ways that affect exposure. The review must consider new technology that could reduce exposure and document consideration and implementation of appropriate, effective safer medical devices. In workplaces where employees provide direct patient care and face sharps-injury risks, non-managerial employees with that exposure must be involved in identifying, evaluating, and selecting relevant controls.

Using precautions and workplace controls

The ECP works alongside other protections required by the standard. Universal precautions means treating human blood and specified OPIM as potentially infectious. Employers must use appropriate engineering and work-practice controls and provide and require appropriate PPE.

Controls include sharps-disposal containers and safer devices. For example, a worker handling a used sharp should dispose of it promptly in an appropriate sharps container rather than leave it exposed for someone else to handle.

Training employees with exposure

Employers must provide required training at no cost and during working hours to every employee with occupational exposure. Training is required when an employee is first assigned to tasks where exposure may occur and at least annually thereafter; annual training must occur within one year of the previous training. Additional training is required when changed or new tasks or procedures affect exposure.

Training must be appropriate to employees’ educational level, literacy, and language. Among other topics, it must cover:

• The standard and the employer’s ECP.

• How bloodborne pathogens are transmitted and how to recognize tasks that involve exposure risks.

• How controls and PPE work, including their limitations.

• What to do and whom to notify after an exposure incident.

Employees must have an opportunity to ask questions and receive answers during training.

Vaccination and response to exposure

The employer must make the hepatitis B vaccination series available to employees with occupational exposure after required training and within 10 working days of initial assignment. Vaccination must be provided at no cost. It need not be offered if an employee has already completed the series, testing has shown immunity, or vaccination is medically contraindicated. An employee who initially declines must sign OSHA’s declination statement but may later accept the vaccine while still covered by the standard.

After an exposure incident, the employer must promptly make confidential, no-cost medical evaluation and follow-up available. This process includes documenting the exposure circumstances, providing relevant information to the healthcare professional, and following applicable public-health recommendations. Employees should promptly report a needlestick or splash so the employer can arrange evaluation and follow-up.

Keeping required records

OSHA requires distinct records, with different contents, retention periods, and access rules.

• Employee medical records: Include required vaccination information, relevant examination and follow-up results, the healthcare professional’s written opinion, and specified information provided to that professional. Keep these records confidential and retain them for the duration of employment plus 30 years. Employees may access their own records under applicable OSHA rules.

• Training records: Include training dates and content or a summary, trainer names and qualifications, and attendees’ names and job titles. Retain them for three years from the training date.

• Sharps injury log: Employers required to maintain an OSHA injury-and-illness log under 29 CFR Part 1904 must also maintain a confidential sharps injury log. It records the device type and brand, department or work area, and how the incident occurred. Retention follows applicable Part 1904 requirements.

Employers should maintain the ECP and records so employees can find the plan, understand protections, and report incidents without delay.

How the requirements work together

OSHA’s bloodborne-pathogen requirements combine hazard identification, a written and regularly updated exposure-control plan, effective controls, employee training, hepatitis B vaccination, post-exposure care, and recordkeeping. The employer’s central responsibility is to identify where exposure can occur and consistently provide the protections and procedures needed to prevent it and respond when it happens.