Bloodborne Pathogens: Understanding the OSHA Standard

Overview of the Standard

The Occupational Safety and Health Administration (OSHA) Bloodborne Pathogens Standard, 29 CFR 1910.1030, protects workers who can reasonably be anticipated to contact blood or other potentially infectious materials (OPIM) as a result of performing their job duties. It was revised following the Needlestick Safety and Prevention Act of 2000 to strengthen requirements for safer medical devices and employee involvement.

The standard addresses three pathogens of particular concern in healthcare:

• Hepatitis B virus (HBV)
• Hepatitis C virus (HCV)
• Human immunodeficiency virus (HIV)

Other bloodborne pathogens exist, and the standard's protections apply to any pathogenic microorganism present in human blood that can cause disease.

Blood and Other Potentially Infectious Materials

OSHA defines OPIM to include:

• Semen and vaginal secretions.
• Cerebrospinal, synovial, pleural, pericardial, peritoneal, and amniotic fluids.
• Saliva in dental procedures.
• Any body fluid visibly contaminated with blood, and all body fluids where it is difficult or impossible to differentiate between body fluids.
• Unfixed human tissues or organs (other than intact skin).
• HIV-, HBV-, or HCV-containing cell or tissue cultures, culture media, and related solutions, and blood or tissues from experimental animals infected with these agents.

The standard requires universal precautions: treating all human blood and OPIM as if known to be infectious. Many healthcare employers implement this through CDC's broader Standard Precautions.

The Exposure Control Plan

Each employer with employees who have occupational exposure must establish a written Exposure Control Plan (ECP). Key requirements include:

• An exposure determination listing job classifications and tasks with occupational exposure, made without regard to PPE use.
• A schedule and method for implementing the standard's requirements.
• Procedures for evaluating exposure incidents.
• Review and update at least annually, and whenever new or modified tasks or procedures affect exposure.
• Annual consideration and documentation of commercially available safer medical devices.
• Solicitation of input from non-managerial frontline employees in identifying, evaluating, and selecting engineering and work practice controls.

The ECP must be accessible to employees. Ask your supervisor or safety officer where your facility's plan is kept.

Methods of Compliance: Controls and PPE

OSHA expects employers to use a combination of controls:

• Engineering controls isolate or remove the hazard. Examples include puncture-resistant, leak-proof, labeled sharps containers; needleless systems; and sharps with engineered sharps injury protections, such as retractable or shielded needles.
• Work practice controls change how a task is performed. Examples include not bending, recapping, or removing contaminated needles unless no alternative is feasible (and then only with a mechanical device or one-handed technique), washing hands after glove removal, and not eating, drinking, applying cosmetics, or handling contact lenses in work areas with exposure risk.
• Personal protective equipment such as gloves, gowns, face shields, eye protection, and masks, provided by the employer at no cost to employees in appropriate sizes, and cleaned, repaired, or replaced by the employer as needed.

Sharps containers should be easily accessible, kept upright, and replaced routinely so they are not overfilled. Regulated waste and containers of blood or OPIM must carry the biohazard label (fluorescent orange or orange-red with contrasting lettering and symbol) or be placed in red bags or containers.

Hepatitis B Vaccination

Employers must make the hepatitis B vaccination series available, at no cost, to all employees with occupational exposure, within 10 working days of initial assignment, unless the employee has previously received the complete series, antibody testing shows immunity, or the vaccine is contraindicated for medical reasons.

Employees may decline the vaccine but must sign the declination statement specified in the standard. An employee who initially declines may later request the vaccine, and the employer must then provide it at no cost. CDC recommends hepatitis B vaccination for healthcare personnel at risk of exposure and provides guidance on post-vaccination antibody testing.

After an Exposure Incident

An exposure incident is a specific eye, mouth, other mucous membrane, non-intact skin, or parenteral contact with blood or OPIM resulting from the performance of an employee's duties. If an exposure occurs:

• Wash needlesticks and cuts with soap and water.
• Flush splashes to the nose, mouth, or skin with water.
• Irrigate eyes with clean water, saline, or sterile irrigants.
• Report the incident to your supervisor or designated person immediately.
• Seek medical evaluation promptly. CDC guidance emphasizes that HIV post-exposure prophylaxis (PEP), when indicated, should be started as soon as possible.

The employer must provide a confidential medical evaluation and follow-up at no cost, including documentation of the route of exposure, identification and testing of the source individual when feasible and permitted by law, testing of the exposed employee's blood with consent, post-exposure prophylaxis when medically indicated, and counseling. The healthcare professional's written opinion is provided to the employee.

Employers required to keep OSHA injury and illness records must also maintain a sharps injury log that protects the confidentiality of the injured employee.

Training and Recordkeeping

Employers must provide bloodborne pathogens training during working hours at no cost, at the time of initial assignment, at least annually thereafter, and when changes in tasks affect exposure. Training must include an opportunity for interactive questions with a knowledgeable person.

Records requirements include:

• Medical records for each employee with occupational exposure, kept confidential and maintained for the duration of employment plus 30 years.
• Training records, including dates, content summary, trainer, and attendees, maintained for 3 years from the training date.

Note: this free refresher module supports your learning but does not replace the site-specific, interactive training your employer is required to provide under the standard.