Blood-borne Pathogen Control: OSHA Requirements

Nov 1st, 2017 | By | Category: Featured Articles

Check out this comprehensive, easy to read overview of the U.S. Occupational Safety and Health Administration (OSHA) blood-borne pathogen standard published by EHS Data Base. An excerpt is published below, and more detail is provided in the original article.



Blood-borne pathogens are microorganisms such as viruses or bacteria that are carried in blood and can cause diseases in people. Blood-borne pathogen control in the workplace is an essential program to keep employees safe if they are required to provide first aid care in the workplace.

The viruses that cause Hepatitis B Virus (HBV) and Human Immune-deficiency Virus (HIV) are two examples of blood-borne pathogens. For a blood-borne pathogen to be spread, the bodily fluids of an infected person must enter into the bloodstream of another person. The most common cause of transmission in the workplace is when an infected person’s blood enters another person’s bloodstream through an open wound.


Occupational Exposure

OSHA standard 29 CFR 1910.1030(c)(1)(i) states that

Each employer having an employee(s) with occupational exposure as defined by paragraph (b) of this section shall establish a written Exposure Control Plan designed to eliminate or minimize employee exposure.

Occupational exposure, as defined by paragraph (b), is “reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee’s duties.”

There are good reasons to provide workers with a safety training program about blood-borne pathogens. First, anybody can be exposed during an accident or even from close contact with someone who has an open sore. Second, OSHA has cited contractors for failing to provide education in this area, specifically when employees are required to be certified in first aid/CPR. And third, business-owned facilities, such as shops and offices, are covered under the general industry regulations and therefore subject to OSHA’s blood-borne pathogen standard.


Exposure Control Plan

Who must have an exposure control plan?

Any employer with employees covered by the standard must have a written exposure control plan. This includes all employers with employees who may have occupational exposure to blood. It should be noted that plans are required of employers with two categories of employees other than those most readily identifiable:

(1) Part-time, temporary and per diem employees in the health care industry; and

(2) Employees trained in first aid/CPR and designated to respond to emergencies in any place of employment.


Exposure Control Plan Elements

The exposure control plan must include a determination of which employees are covered using

(1) A list of all job classifications in which all employees have occupational exposure to blood or other potentially infectious materials; and

(2) A list of job classifications in which only some of the employees have occupational exposure. The job classifications in which only some of the employees have exposure must then be analyzed. Those tasks and procedures in which occupational exposure occurs must be identified, and the employees performing those tasks, and therefore covered by the plan, identified. However, it is not necessary to list individual employee names.

The exposure determination must be made without regard to the use of personal protective equipment (as though it were not being used). An exposure control plan is required of all employers with employees covered by the standard.

In addition to the determination of covered employees outlined above, it must include at least the following elements:

  1. The schedule and methods of implementation for all elements of the standard that pertain to this employer; and
  2. The procedure for the evaluation of circumstances surrounding exposure incidents, as required by the standard.


Annual Review

The standard requires the employer to annually review and update the exposure control plan and more frequently when necessary to reflect new or modified tasks that affect occupational exposure as well as to reflect new or revised employee positions with occupational exposure. An important part of this review is the consideration and evaluation of engineering controls, such as commercially available safer needle devices and needleless systems, which eliminate or reduce employee exposure to percutaneous injury with contaminated devices.

To accomplish this, the employer must solicit input from non-managerial employees in the evaluation, selection, and use of new commercially available devices. The non-management employees chosen must be from among those who are responsible for direct patient care.

A copy of the standard with notes detailing the schedule and method of implementation of the standard in that particular workplace may be adequate for small facilities. Larger facilities may wish to incorporate the exposure control plan as one portion of the infection control plan or may otherwise develop a facility-wide program. Model exposure control plans, which can be adapted to individual company needs, can be obtained either through the Education, Training.


Methods of Compliance

Universal Precautions

Universal precautions, as outlined and defined by the Centers for Disease Control and Prevention (CDC), are to be used to prevent contact with blood or other potentially infectious materials. The term universal precautions refers to a method of blood-borne disease control which requires that all human blood and other potentially infectious materials be treated as if known to be infectious with HIV, HBV or other blood-borne pathogens regardless of the perceived low risk of a patient or patient population. Another method of infection control is called body substance isolation (BSI) or standard precautions.

This method defines all body fluids and substances as infectious. BSI incorporates not only the fluids and materials covered by this standard but expands coverage to include all body fluids and substances. It is an acceptable alternative to universal precautions provided that all other portions of the standard are also followed.

Engineering and Work Practice Controls

The standard requires the employer to use engineering and work practice controls as the primary means of eliminating or minimizing employee exposure. Engineering controls reduce employee exposure in the workplace by either removing or isolating the hazard or isolating the worker from exposure. Work practice controls alter the manner in which a task is performed to make the task safer. When occupational exposure remains after using these controls, the employer must provide,
and be sure that employees use, personal protective equipment as additional protection.

Some examples of engineering controls that may be used to reduce exposure to blood or other potentially infectious materials include:

  • Self-sheathing needles;
  • Puncture-resistant containers for the disposal of contaminated sharps; and
  • Resuscitation bags and ventilation devices.

Examples of work practice controls include

  • Prohibiting recapping;
  • Removing or bending needles unless no alternative exists;
  • Enforcing hand washing procedures following the removal of gloves;
  • Restricting eating and drinking in work areas; and
  • Decontaminating equipment before servicing.

Handwashing Facilities and Requirements

Handwashing facilities must be readily accessible to employees. Handwashing with soap and at least tepid (lukewarm) running water must be performed as soon as feasible to adequately flush contaminated material from the skin. The employer must ensure that handwashing is routinely performed immediately following removal of gloves and other personal protective equipment that have become contaminated. Employers must make handwashing facilities available at a reasonable distance from a work area where exposure may occur. Contamination of surfaces is more likely when employees must travel long distances, through doorways and through stairs to reach handwashing facilities, and is therefore not permitted by the standard.

When handwashing facilities cannot be made available, such as to emergency personnel at accident sites, antiseptic hand cleaners or antiseptic towelettes must be provided. The employee must wash his or her hands or other contaminated skin with running water and soap as soon as possible.

Handling Needles and Sharps

Devices exist to provide an alternative to the use of needles for some procedures. Examples of such devices include stopcocks (on-off switches), needle-protected systems or needleless systems to connect intravenous lines, and self-sheathing needles. Needles may be recapped only in very limited situations.

When a procedure requires that the needle be recapped, the employee must use some type of device that protects the hand or allows a safe one-handed recapping method. Finger or hand shields may be used but must be constructed so that the employee is not exposed to a needle protruding from the side or end of the cap. Forceps may also be used, but a onehanded method is required. Shearing or breaking contaminated needles is never permitted.

Personal Protective Equipment

When occupational exposure continues after engineering and work practice controls have been instituted, personal protective equipment (PPE) must be used. The PPE must prevent blood or other potentially infectious materials from passing through to or contacting the employees’ work or street clothes, undergarments, skin, eyes, mouth, or other mucous membranes. This barrier must remain intact under normal conditions of use and for the entire time it is being used. The employer must provide appropriate PPE at no cost to the employee. PPE must be cleaned, laundered, disposed of, repaired and replaced at no cost to the employee.

PPE must be provided in appropriate sizes and accessible locations. Training must be given as to what personal protective equipment to use, where it is kept, and how it is properly used.


The standard requires employers to ensure that the worksite is maintained in a clean and sanitary condition. An appropriate written schedule for cleaning and a method of decontamination based upon the location within the facility, type of surface to be cleaned, type of soil present, and tasks and procedures must be implemented. The term worksite refers not only to permanent fixed facilities but also covers temporary, non-fixed worksites such as ambulances, bloodmobiles, and temporary blood collection centers.

A solution of household bleach (containing 5 percent sodium hypochlorite) diluted with water to a concentration of 1:10 to 1:100 is an effective disinfectant against HBV and HIV. However, it may be corrosive to some equipment and environmental surfaces and therefore may not be an appropriate choice for all situations.

Hepatitis B Vaccination

The standard requires that all employees with reasonably anticipated exposure, regardless of the frequency of exposure, be offered vaccination against the hepatitis B virus. This must take place after the training, and within 10 working days of initial assignment in a covered job description. The vaccine must be provided at no cost to the employee unless:

(1) The employee has previously received the complete hepatitis B vaccination series;

(2) Antibody testing reveals the employee is immune; or

(3) Medical reasons prevent taking the vaccinations.

An employee may refuse the vaccination, but if he or she does so, the employer must document the refusal by having the employee sign the declination from required by the standard. Employees who decline the vaccine must be allowed the option of having the vaccination at any time so long as they still have occupational exposure.


Post-exposure Evaluation and Follow-up

Following the report of any incident in which an employee has non-intact skin, eye, mouth, mucous membrane or parenteral (under the skin) contact with blood or other potentially infectious materials, the employer must provide the employee a confidential medical evaluation and follow-up. This evaluation must be conducted by a licensed health care professional. It must include the following elements:

  1. Documentation of the route(s) of exposure and the circumstances under which the exposure occurred.
  2. Identification and documentation of the source individual unless the employer documents that such identification is infeasible or prohibited by state or local law.
  3. Collection and testing of the exposed employee’s blood for HBV and HIV serological status, which means finding out if the virus is already present in the employee’s blood.
  4. Post-exposure prophylaxis, when medically indicated as recommended by the CDC.
  5. Counseling: The employer must provide counseling about both the exposure incident and the medical follow-up, and must also provide psychological counseling if it is recommended by the healthcare professional.
  6. Evaluation of reported illnesses: The exposed employee should be instructed to report and seek medical evaluation for any acute illness or any illness with a fever that occurs during the follow-up period.

Following the post-exposure follow-up, the health care professional must provide the employer a written opinion including whether the hepatitis B vaccine is indicated and whether the employee received such vaccination. An opinion of what post-exposure evaluation and follow-up is needed. The employer must obtain this report and give a copy to the employee within 15 days after the evaluation is completed.

All other findings or diagnoses must remain confidential and cannot be included in the written report. This provision of confidentiality may become a problem in small medical or dental offices where the employer serves as the health care professional for the employees. Using a physician outside the workplace is recommended in such situations.


Communication of Hazards to Employees

Labeling Requirements

Warning labels must be placed on containers of regulated waste, refrigerators and freezers containing blood or other potentially infectious materials, and other containers used to store, transport, or ship blood or other potentially infectious materials, with some exceptions as noted below. Labels for contaminated equipment must state which portions of the equipment remain contaminated.

Labels are required to be fluorescent orange or orange-red in color with lettering or symbols in a contrasting color. They are to be attached as close as feasible to the container by string, wire, adhesive or other method that prevents their loss or unintentional removal. Labels must include the following symbol and wording:

Red bags or red containers may be substituted for labels. Labeling is not required for the following:

(1) Containers of blood, blood components or blood products that are labeled and have been released for transfusion or other clinical use;

(2) Individual containers of blood or other potentially infectious materials that are placed in a labeled larger container during storage, transport, shipment or disposal; and

(3) Regulated waste that has been decontaminated.

Training Requirements

Effective training helps to ensure that employees understand the hazards associated with blood-borne pathogens, the modes of transmission, the exposure control plan, the use of engineering controls, work practices and personal protective clothing.

The standard requires that the training be given at the educational level and in the language primarily used by the employees being trained. The training may be specific to different groups being trained. For example, doctors and nurses may require less information on the causes and symptoms of blood-borne pathogens than would laundry workers. All training must take place during working hours, at no cost to the employee, and in a reasonable, accessible location.

Training must be provided at the time of initial employment and at least annually (once a year) after that. When a worker’s job is changed to include different ways to do tasks or procedures, or when new tasks or procedures are added that affect the employee’s occupational exposure, additional training is required. The standard specifies that the person conducting the training must be knowledgeable in the subject matter in the standard as it relates to the workplace where the employee(s) will be working. The employer should document (keep a written record of) training that the trainer has received in the area of blood-borne pathogens, as well as familiarity with the workplace involved.


Training Program Elements

The following must be included in the training program at a minimum:

  1. A copy of the standard must be made available where each employee has access to it. The contents must be explained as part of the training.
  2. A general explanation of the causes and symptoms of blood-borne diseases must be given.
  3. The program must cover how blood-borne pathogens are communicated from one person to another.
  4. The exposure control plan must be explained in a way that each employee can understand it. The plan must be kept available where each employee has access to it.
  5. Employees must be given information on the appropriate methods for recognizing tasks and other activities that may involve exposure to blood and other potentially infectious materials.
  6. The use and limitations of methods that will prevent or reduce exposure must be covered. This instruction must include appropriate engineering controls, work practices and PPE.
  7. The employee must be taught the types, proper use, location, removal, handling, decontamination and disposal of personal protective equipment.
  8. An explanation must be given of the basis for selection of PPE, so that the employee will be able to judge the best PPE to use in any situation.
  9. The hepatitis B vaccine must be explained in detail, including information of the vaccine’s effectiveness, safety, method of administration, the benefits of being vaccinated and the assurance that the vaccine will be offered free of charge to the employee.
  10. Affected employees must be instructed on the appropriate actions to take and people to contact in an emergency involving blood or other potentially infectious materials.
  11. Procedures to follow in case of an exposure incident must be outlined, including the method of reporting the incident and the medical follow-up that will be made available.
  12. Employees must be given information on the post-exposure evaluation and follow-up that must be provided to them following an exposure incident.
  13. An explanation of the signs and labels and the color coding required by the standard must be given.
  14. The person conducting the training must provide an opportunity for questions and answers on the training. A video, film or written information by itself is not sufficient for this standard. Similarly, computer-based training is not sufficient by itself unless the employee can have questions and concerns answered by a knowledgeable individual at the time that he or she takes the computer based training.


Blood-borne Pathogen Post Exposure Procedures

  • Document the route of exposure and exposure event circumstances;
  • Identify and document the source individual;
  • Test the source individual’s blood for HBV and HIV as soon as possible;
  • Have your blood tested;
  • Administer post exposure prophylaxes;
  • Provide counseling; and
  • Evaluate reported illnesses.

More Information

The remainder of this article can be found on the EHS Data Base web site.


Photograph: Textures 4 by Ann-Kathrin Rehse, Bad Nenndorf, Niedersachsen, Germany.

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