Training

Bloodborne Pathogens: What Employers MUST Do


The dangers of bloodborne pathogens extend far beyond the realms of health care and emergency response. Here’s what OSHA says you must do to protect your workforce.


Regular readers of this column know that we harp on the fact that the dangers of bloodborne pathogens (BBPs) are not limited to healthcare workers. Many other employees – including housekeeping personnel, first-aid team members, first responders, police, firefighters, funeral home employees, lifeguards, and more – also face significantly increased risks from BBPs.


And, depending on their job responsibilities, workers in almost any industry can be exposed to BBPs (disease-causing microorganisms that exist in human blood and certain other bodily fluids).


In fact, it is estimated that nearly 6 million workers are at risk of infections from such BBPs as hepatitis B, hepatitis C, and HIV/AIDS. And that’s one of the reasons why OSHA takes its BBP Standard (29 CFR 1910.1030) so seriously – and why you should, too.




Your employees can teach themselves about bloodborne pathogens, as demanded by OSHA’s BBP standard, with BLR’s Interactive CD Course: Bloodborne Pathogens program. Try it at no cost or risk. Get the details.

How can you protect your workforce?


Our Safety Training Tips editor notes that you are required to train all employees whose jobs could expose them to infectious diseases, at no cost to them, and during working hours. The training must occur at the time of an employee’s initial assignment to a job that may expose him or her to infectious diseases, and at least annually thereafter.


You must provide additional training when jobs or procedures are changed or when the nature of the employee’s exposure changes. And the training materials must match employees’ education, literacy, and language levels.


In addition, every employer that has any employees who are reasonably anticipated to have occupational exposure to blood or other potentially infectious materials must have a written Exposure Control Plan (ECP) that is accessible to employees at all times. For example, all employees designated as first-aid providers or responders are reasonably anticipated to have occupational exposure.


The ECP must be reviewed and updated at least annually and whenever necessary to reflect any new or revised employee tasks and procedures that affect exposure or any changes in technology that reduce or eliminate BBP exposure.


The ECP exposure determination must contain:



  • A list of all job classifications in which all employees in those job classifications have occupational exposure,
  • A list of job classifications in which some employees have occupational exposure, and
  • A list of all tasks and procedures, or groups of closely related tasks and procedures, in which occupational exposure occurs.

It is important to remember that this exposure determination must be made without regard to whether PPE is being used.


Our sister website, HR.BLR.com, says that methods of complying with OSHA’s BBP Standard include:



  • Universal precautions. This means treating all human blood and certain human bodily fluids as if they are known to contain BBPs.
  • Engineering controls and work practices. Engineering and work practice controls must be used to eliminate or minimize employee exposure and should be reviewed regularly.
  • PPE. Where occupational exposure remains after implementing feasible controls, the employer must provide readily accessible PPE at no cost to the employee. The requirements for PPE include:

    • It must prevent blood or other potentially infectious materials from reaching the employee’s regular clothes or body during normal use.
    • The employer must provide for cleaning, laundering, disposal, and repair or replacement of PPE.
    • Gloves must be worn when it can be reasonably anticipated that there may be hand contact with blood or other potentially infectious materials. Disposable (single-use) gloves must not be washed or decontaminated for reuse.
    • Masks, eye protection, and face shields must be worn when necessary to protect the face from contamination.
    • Gowns, aprons, and other protective clothing must be worn as necessary, depending on the type and degree of anticipated exposure.



Try the unique, self-directed, self-testing program, Interactive CD Course: Bloodborne Pathogens, at no cost or risk. Find out more.


  • Hand-washing. Employers must provide hand-washing facilities that are readily accessible to employees and ensure that employees wash their hands as soon as feasible after removal of gloves or other PPE. When it is not feasible to provide hand-washing facilities, the employer must provide either an appropriate antiseptic hand cleanser or antiseptic towelettes.
  • Food and drink. Eating, drinking, smoking, applying cosmetics or lip balm, and handling contact lenses are prohibited in work areas where there is a reasonable likelihood of occupational exposure.
  • Housekeeping. Employers must ensure that the worksite is maintained in a clean and sanitary condition. All equipment and environmental and working surfaces must be cleaned and decontaminated as soon as possible after contact with blood or other potentially infectious materials.
  • Regulated waste. Contaminated needles and other contaminated sharps must not be bent, recapped, or removed unless the employer can demonstrate that no alternative is feasible or that such action is required by a specific medical or dental procedure.

In tomorrow’s Advisor, we’ll look at the training requirements of OSHA’s BBP Standard, and at a tool that can help you efficiently – and economically – provide your workers with this potentially lifesaving instruction.

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