Audit, Compliance and Risk Blog

Protecting Employees Against Bloodborne Pathogens

Posted by Jon Elliott on Tue, May 10, 2016

Pathogens.jpgThe Occupational Safety and Health Administration (OSHA) requires employers to protect their employees against possible exposure to “bloodborne pathogens (BBPs).” OSHA’s Bloodborne Pathogen Standard prescribes protections for workers occupationally exposed to blood or other potentially infectious materials (OPIM). Healthcare workers are the most obvious beneficiaries, but emergency responders and others may also be regularly at risk to these exposures.

What Are BBPs?

OSHA defines bloodborne pathogens as “pathogenic microorganisms that are present in human blood and can cause disease in humans. These pathogens include, but are not limited to, hepatitis B virus (HBV) and human immunodeficiency virus (HIV).” In its preamble to the BBP Standard, OSHA listed the following additional bloodborne pathogens. These additional pathogens are fully subject to the BBP Standard (except provisions explicitly limited to HBV and HIV):

  • Hepatitis C

  •  Malaria

  •  Syphilis

  •  Babesiosis

  •  Brucellosis

  •  Leptospirosis

  •  Arboviral infections

  •  Relapsing fever

  •  Creutzfeld-Jakob Disease

  •  Human T-lymphotrophic virus Type I and II, and associated myelopathy

  •  Viral Hemorrhagic Fever

Other pathogens are also targeted – either formally or by recommendations to apply BBP Standard measures (described below). For example, ebola was targeted during the 2015 outbreak in the U.S., and new guidance from OSHA and the National Institute for Occupational Safety and Health (NIOSH) recommend application to protect against the Zika virus.

Who Is At Risk?

Anyone whose occupational activities may involve exposure to blood or OPIM is potentially at risk for BBP exposures, and the broader and more frequent the exposures the higher the risk. Operations that typically have occupational exposures to bloodborne pathogens may include the following:

  • Health care facilities, such as:

    • Hospitals.

    • Hospice facilities.

    • Cinics and nursing homes.

    • Dental facilities.

    • Medical laboratories.

    • Physician’s offices.

  • Medical equipment service and repair operations

  • Food banks, plasma centers, hemodialysis centers

  • Commercial laundries that service health care or public safety operations

  • Emergency or public safety operations, such as:

    • Ambulance services.

    • Emergency first aid operations (voluntary first aid is not subject to the BBP Standard, but “Good Samaritan” employees may still be at risk).

    • Fire, police, paramedic, and lifeguard services.

  • Correctional facilities

  • Funeral service operations

  • Maid services in hotels and motels

  • Regulated waste operations.

What Does The BBP Standard Require?

Employers must do the following, in programs to protect employees whose activities trigger BBP (i.e., if some employees are covered, the employer should consider which employees qualify for protections, but is not required to provide BBP Standard protections to all employees).

  • Written Exposure Control Plan, designed to eliminate or minimize employee exposure. It must contain at least the following elements:

    • Implementation of other measures listed below

    • Procedures for evaluating exposure incidents

    • Exposure determination with the following:

      • List all job classifications where all employees have occupational exposures

      • List all job classifications where some employees have occupational exposures

    • List all tasks and procedures in which occupational exposures occur (this determination must be made without regard to personal protective equipment (PPE))

  • Methods of compliance, including “universal precautions” to prevent contact with blood or OPIM. This method assumes that all human blood and specified human body fluids are infectious. These precautions are to include appropriate combinations of the following:

    • Engineering controls (such as needleless devices)

    • Work practice controls (such as no-hands procedures in handling contaminated sharps)

    • PPE (such as gloves and eye protection)

    • Housekeeping procedures designed to ensure sanitary workplaces.

  • Hepatitis B vaccination schedule – offer vaccinations at no cost to all employees routinely exposed to blood and OPIM. Each individual has the right to reject vaccinations.

  • Communication of BBP hazards and the employer’s responses, to exposed employees. This includes training, which must include the following:

    • How to obtain a copy of the BBP Standard and an explanation of its contents

    • Epidemiology and symptoms of bloodborne diseases

    • How bloodborne pathogens are transmitted

    • Explanation of the Exposure Control Plan and how to obtain a copy

    • How to recognize tasks that might result in occupational exposure

    • Use and limitations of work practices and engineering controls

    • Information on types, selection, proper use, limitations, location, removal, handling, decontamination, and disposal of PPE

    • Information on hepatitis B vaccination, such as safety, benefits, efficacy, methods of administration, and availability

    • Who to contact and what to do in an emergency

    • How to report an exposure incident and on the post-exposure evaluation and follow-up

    • Warning labels, signs, and color coding

    • Question and answer sessions on any aspect of the training

  • Record keeping, including:

    • Training records.

    • Medical records.

    • Sharps Injury Log (recording injuries from punctures and cuts).

Self-Assessment Checklist

Has the organization evaluated occupational activities, to determine whether any activities routinely expose employees to blood or other potentially infectious materials?

If BBP/OPIM exposure risks are present, has the organization:

  • Prepared an Exposure Control Plan that meets BBP Standard requirements, for subject employees in each workplace?

  •  Implemented the Plan, including all required elements?

Where Can I Go For More Information

Specialty Technical Publishers (STP) provides a variety of single-law and multi-law services, intended to facilitate clients’ understanding of and compliance with requirements. These include:

About the Author

jon_f_elliott.jpgJon Elliott is President of Touchstone Environmental and has been a major contributor to STP’s product range for over 25 years. He was involved in developing 12 existing products, including Environmental Compliance: A Simplified National Guide and The Complete Guide to Environmental Law.

Mr. Elliott has a diverse educational background. In addition to his Juris Doctor (University of California, Boalt Hall School of Law, 1981), he holds a Master of Public Policy (Goldman School of Public Policy [GSPP], UC Berkeley, 1980), and a Bachelor of Science in Mechanical Engineering (Princeton University, 1977).

Mr. Elliott is active in professional and community organizations. In addition, he is a past chairman of the Board of Directors of the GSPP Alumni Association, and past member of the Executive Committee of the State Bar of California's Environmental Law Section (including past chair of its Legislative Committee).

You may contact Mr. Elliott directly at:

photo credit: FDA Lab 3407 via photopin (license)

Tags: Employer Best Practices, Health & Safety, OSHA, Employee Rights, Environmental risks, EHS, Hazcom, pharmaceuticals