Workplace safety is always a priority, and understanding potential threats is critical for everyone’s health. You need clear, reliable information to minimize risks when dealing with any body fluids. That means knowing exactly what to do and how to protect yourself on the job.
This comprehensive resource is your ultimate guide to Bloodborne Pathogens (BBP), which are infectious organisms found in blood and other body fluids that can cause disease in humans. We’ll outline specific risks and explain necessary precautions, along with emergency procedures. Your safety is governed by regulatory standards, so we will focus heavily on workplace requirements defined by the Occupational Safety and Health Administration (OSHA).
This guide clearly summarizes OSHA’s Bloodborne Pathogens Standard, including required engineering controls, Personal Protective Equipment (PPE), and mandatory training. By reading this, you will gain the knowledge needed to identify, manage, and prevent exposure incidents effectively in any professional setting.
Table of Contents
Your Workplace Safety Net: The Exposure Control Plan (ECP)
Every workplace that poses a risk of exposure to Bloodborne Pathogens must have a written safety plan: the Exposure Control Plan (ECP).
This document is a specific, detailed guide to how your employer identifies risks and protects you from them. Think of the ECP as your company’s promise to keep you safe, outlining rules, procedures, and required equipment. The ECP is not a generic document; it is tailored specifically to the tasks you perform and the hazards present in your setting. Knowing this plan and following it is a primary job requirement in protecting your health.
Locating and Using Your Exposure Control Plan
The ECP is the comprehensive tool that details every safety requirement for your specific job role. It lists which tasks or procedures involve occupational exposure, classifying them by risk level. Furthermore, the plan defines all protective measures, including required personal protective equipment (PPE), cleaning procedures, and disposal methods. You need to know that your employer must make the ECP accessible to all employees. You have the right to review this plan at any time during your work shift.
Mandated annual training stipulates that the ECP must be reviewed step by step, ensuring you understand its contents completely.
This regular review helps keep the plan current and effective, as required by OSHA, meaning it must be updated at least annually and whenever new procedures or equipment are introduced.
Knowing the location of the ECP and understanding its contents are fundamental parts of your workplace safety training.
For a model exposure control plan template see here.
Understanding Engineering Controls: Physical Safety Barriers
Within your ECP, you will find information about engineering controls. These are physical changes to the work environment designed to eliminate or reduce employee exposure to hazards, ideally at the source. Engineering controls work by isolating or removing the danger, making the entire environment safer without relying solely on your behavior.
Examples of effective engineering controls may include:
- Sharps Disposal Containers: These are puncture-resistant, labeled, and color-coded containers that you must use for disposing of contaminated sharps like needles, scalpels, and broken glass. They must be easily accessible and located as close as possible to the point of use.
- Safer Needle Systems: These devices incorporate built-in safety features to reduce the risk of accidental needle sticks. This includes:
- Self-Sheathing Needles: Needles that automatically cover themselves after use.
- Retractable Needles: Needles that retract into the barrel after injection.
- Needleless Systems: Devices that allow for injections or fluid withdrawal without the use of a sharp needle.
These physical safeguards provide the highest level of protection because they remove the hazard for you.
Work Practice Controls: The Right Way to Do Your Job
While engineering controls focus on the physical environment, work practice controls focus on how you perform your tasks. These are rules for behavior that reduce the likelihood of exposure by changing the way work tasks are performed. They are necessary because even with the best engineering controls, human behavior can still introduce risk.
Your ECP will outline specific work practice controls, which serve as mandates for behavior in your professional environment. Key requirements include:
- Proper Handwashing: You must wash your hands immediately after removing gloves or other PPE and after any contact with blood or other potentially infectious materials (OPIM). If a sink is not immediately available, use an antiseptic hand cleanser, but you must still wash with soap and water as soon as possible.
- Handling Sharps: Never bend, recap, or break used needles or other contaminated sharps by hand. Immediately place all used sharps into the appropriate sharps disposal container.
- Restricted Activities: Do not eat, drink, smoke, apply cosmetics, or handle contact lenses in work areas where you may be exposed to Bloodborne Pathogens. Food and drink must never be kept in refrigerators, freezers, shelves, or cabinets where blood or OPIM are present.
- Safe Handling of Soiled Laundry: Handle contaminated laundry as little as possible. Place wet, potentially soiled laundry in properly labeled, leak-proof bags or containers at the location where it was used, without manipulating it first. This minimizes the chance of fluids leaking or exposure from excessive handling.
Essential Protection: Personal Protective Equipment (PPE) Checklist
While engineering controls focus on minimizing hazards in the environment and work practice controls guide your behavior, Personal Protective Equipment (PPE) is your final defense against occupational exposure to Bloodborne Pathogens.
You must view PPE as a necessary barrier separating your body, clothing, and uniform from potentially infectious materials. OSHA requires your employer to provide, clean, maintain, and dispose of all necessary PPE at no cost to you. Using the correct equipment and knowing how to handle it ensures your safety during tasks that involve possible contact with blood or other potentially infectious materials (OPIM).
Choosing and Wearing the Right Protective Gear Correctly
Selecting the right PPE for bloodborne pathogens is crucial; it must match the degree of anticipated exposure. For example, a simple glove may suffice for routine tasks, but extensive splashing or spraying requires a gown, face shield, and more comprehensive protection. Always check your employer’s Exposure Control Plan (ECP) to confirm the required PPE for the specific task you are performing.
The most common types of PPE you will use to prevent exposure to Bloodborne Pathogens include:
- Gloves: Disposable medical-grade gloves (non-latex if you have latex allergies) protect your hands from direct contact. If you are allergic to latex, your employer must provide suitable alternatives, like nitrile gloves. You must change gloves regularly and immediately whenever they are torn, pierced, or visibly contaminated.
- Gowns, Aprons, and Lab Coats: These protect your clothing and exposed body areas. They must be fluid-resistant and long enough to cover your torso and arms adequately.
- Eye and Face Protection: Safety glasses must have side shields, but when there is a risk of splashing, full face shields or goggles are necessary to protect the mucous membranes of your eyes, nose, and mouth.
Before you put on any protective gear, you must inspect it carefully. If you notice any tears, holes, or signs of damage, you must immediately report this for replacement. Damaged or ill-fitting PPE provides no effective protection.
The Process of Donning and Doffing
Putting on (donning) and taking off (doffing) PPE must follow a strict, systematic process to ensure you do not contaminate yourself during the procedure. The order in which you remove the items is especially important because the outermost layer is the most soiled.
Donning (Putting On) Order:
- Gown: Put on the gown first. Secure all ties and fasteners, ensuring your entire work uniform or street clothes are covered.
- Mask or Respirator (if needed): Position the mask correctly over your nose and mouth.
- Goggles or Face Shield: Place eye protection over your eyes or wear the face shield to cover your entire face.
- Gloves: Put on the gloves last, ensuring the cuff of the glove extends over the cuff of the gown.
Doffing (Taking Off) Order (The sequence that matters most for safety):
When you remove PPE, always assume the outside surfaces are contaminated. The removal process aims to keep the contaminated side in and the clean side out.
- Gloves: Peel the first glove off from the wrist, turning it inside out, and hold it with the gloved hand. Slide the fingers of the ungloved hand under the wrist of the remaining glove and peel it off over the first glove. Dispose of both immediately
- Gown: Untie the waist and neck ties (if possible, without touching the outside). Remove the gown by pulling it away from your body, turning it inside out as you roll or fold it into a bundle, making sure the contaminated outer surface is contained within the bundle.
- Eye/Face Protection (Goggles or Face Shield): Remove these by handling the strap or ear pieces, avoiding touching the front surface.
- Mask: Remove the mask by holding the loops or ties, without touching the front.
Hand Hygiene: Immediately wash your hands thoroughly with soap and water or use an alcohol-based hand sanitizer after all PPE is removed. This final step is paramount to prevent disease transmission.
Safe Cleanup: Handling Spills and Waste Disposal
Even with meticulous use of PPE, accidents involving Bloodborne Pathogens can occur. Spills, particularly of blood or OPIM, must be addressed immediately using standardized procedures in your workplace. Proper cleanup and disposal procedures minimize the risk to you and others.
Procedures for Blood Spill Cleanup
When a spill occurs, your immediate actions should focus on containment and disinfection. You must never attempt to clean a spill without wearing the appropriate PPE, which usually includes heavy-duty utility gloves, a gown, and eye protection.
The general protocol for cleaning up a blood spill involves these steps:
- Contain and Absorb: Cover the spill with an absorbent material, such as paper towels or specialized absorbent powders, to prevent spreading.
- Clean: Carefully scoop up and dispose of the saturated absorbent material into a biohazard receptacle.
- Disinfect: Apply an appropriate disinfectant solution to the area. A common disinfectant is a freshly prepared solution of household bleach (sodium hypochlorite) mixed at a 1:10 dilution with water. Allow the required contact time, as specified by the disinfectant manufacturer, before wiping the area clean. For EPA guidelines on approved disinfectants see this article.
- Final Cleanup: Wipe the area with fresh paper towels. Dispose of all cleaning materials that contacted the spill into a designated biohazard bag.
If glass or sharps caused the spill, you must never pick up the fragments by hand. Use a brush and dustpan, tongs, or forceps for removal, and immediately place the sharps into a designated container.
Waste Disposal Methods and Requirements
Proper disposal of clinical waste is not just about cleanliness; it is a critical regulatory requirement under OSHA’s Bloodborne Pathogens standard. Different types of contaminated materials require specific containers:
- Sharps Disposal: Needles, scalpels, broken capillary tubes, and other objects capable of puncturing the skin must be placed in designated sharps disposal containers. These containers must be:
- Puncture-resistant.
- Labeled with the biohazard symbol and color-coded red.
- Leak-proof and closable.
- Located close to where sharps are used.
- Regulated Waste: Items contaminated with non-liquid or semi-liquid blood or OPIM (like soaked dressings, soiled procedural towels, or contaminated PPE) are considered regulated waste. This waste must be placed in closable, leak-proof containers or bags that are color-coded red or labeled with the biohazard symbol. Ensure that containers are closed before removal to prevent leakage during handling.
Following these precise handling and disposal protocols ensures that the hazards are contained from the moment of exposure until the waste is safely removed from the facility. Always confirm your specific workplace policy for waste segregation and pickup, as local regulations can sometimes impose additional requirements.
The Hepatitis B Vaccine and Your Right to Protection
When you work in an environment where exposure to Bloodborne Pathogens is possible, your employer has a specific duty to protect you from Hepatitis B Virus (HBV) infection. The Hepatitis B vaccine is one of the most important components of the OSHA Bloodborne Pathogens Standard. It provides effective, long-term protection, significantly reducing your risk of contracting this serious infection through an occupational exposure.
OSHA requires that the Hepatitis B vaccine series be offered to any employee who has occupational exposure, meaning you may reasonably anticipate contact with blood or other potentially infectious materials (OPIM) as part of your job duties. This offer must happen within 10 working days of your initial assignment to the job. The vaccine must be offered at no cost to you, and it must be given at a reasonable location and time.
Understanding the Free Vaccine Offer and Declination Forms
OSHA is clear: the Hepatitis B vaccination series is a fundamental protection you are entitled to if you face occupational exposure. Your employer must ensure you receive all necessary information about the vaccine, its benefits, and its high effectiveness before you decide.
The mandatory training you receive must include detailed information on the vaccine’s ability to protect you from HBV. You need to understand that this vaccine provides a safe way to prevent a serious, sometimes fatal, illness that is easily transmitted through blood contact in the workplace.
While your employer must offer the vaccine, you have the absolute right to accept or refuse it. If you decide not to receive the vaccination series, you must formally document this decision. The official way to formalize your refusal is by signing a declination form.
The declination form is a legal document that acknowledges several key points:
- You were informed of the risks of Hepatitis B infection.
- Your employer offered the vaccine to you at no cost.
- You chose to refuse the vaccination.
If you initially decline the vaccine but later change your mind, your employer must still provide the vaccine series to you at no cost. This ensures that your protection remains available throughout your employment, even if you delay the decision.
Immediate Action: What to Do After an Exposure Incident
No matter how meticulous you are with safety procedures, exposure incidents involving Bloodborne Pathogens can and do happen. This might involve a sudden needlestick injury or a splash of potentially infectious material (OPIM) onto your skin or mucous membranes. When an incident occurs, your response in the critical first moments is paramount for limiting the risk of infection. OSHA mandates a clear procedure to protect you, starting with immediate action and followed by required medical evaluation. Recognizing what constitutes an exposure incident and responding quickly are necessary steps in your workplace safety training.
Step-by-Step Response to a Puncture or Splash
When you sustain an injury or notice a splash of potentially infectious material, you must initiate a sequence of critical actions immediately. These steps are designed to mitigate the immediate risk of transmission and ensure you receive the mandated follow-up medical care. You must prioritize fast action as time is a factor in effective post exposure treatment.
Here is the essential sequence you must follow immediately after an exposure incident:
- Wash the Exposure Site Immediately: Your absolute first action is to clean the affected area thoroughly.
- Puncture or Cut: Allow any wound to bleed freely for a moment. Then, wash the area vigorously with soap and running water. Do not scrub roughly or use harsh chemicals like bleach on the wound site.
- Splash to Eyes or Mucous Membranes: If blood or OPIM splashes your nose or mouth, wash the area well with water. If the splash enters your eyes, you must rinse them continuously for at least 15 minutes using clean water, saline, or sterile eyewash.
- Contamination of Skin: Wash the contaminated skin area with soap and water instantly.
- Report to Your Supervisor Immediately: After performing immediate first aid, you must report the incident to your supervisor or the designated contact person at once. Immediate reporting is not optional; it is required under OSHA regulations. This report is necessary even if the skin exposure was small or the potential risk seems low. Reporting starts the necessary process for proper documentation and medical evaluation.
- Access the Confidential Follow-Up Evaluation: Once reported, your employer must immediately make a confidential medical evaluation and follow-up care available to you. This is a legal requirement under the Bloodborne Pathogens standard. You will be referred to a licensed healthcare professional who manages the required testing and evaluation.
It is important to know that your employer must pay for all necessary medical evaluations and procedures. This includes the required blood collection, testing, and any counseling or treatment, such as Post Exposure Prophylaxis (PEP) medications, if deemed necessary.
The healthcare professional will perform these evaluations in accordance with the current U.S. Public Health Service guidelines, and they will coordinate necessary blood testing for Hepatitis B, Hepatitis C, and HIV. They will also collect and test the source individual’s blood, if known and permissible by law, to determine their infection status. This entire process must be discreet, confidential, and completely free of charge to you.
Annual Training and Record Keeping Requirements for Compliance
Compliance with the Occupational Safety and Health Administration (OSHA) Bloodborne Pathogens Standard is not a one-time event; it is an ongoing commitment to safety. For your workplace to remain compliant and, more importantly, for you to stay protected, structured training and meticulous record keeping are required.
These systematic processes provide you with the necessary knowledge and ensure accountability across your employing organization. You need to understand when and how this training must take place, as well as the documentation your employer must maintain to prove adherence to these rules.
The Mandate for Annual Refresher Training
The safety information and protocols related to Bloodborne Pathogens are too critical to forget. Because of this, OSHA mandates that all employees who have occupational exposure must participate in training at least once every 12 months, following the initial training upon hiring. This annual refresher training helps ensure that familiar procedures remain fresh in your mind and that you are aware of any changes in safety protocols.
Your employer must guarantee that this training covers several key components essential for your safety:
- Review of the Exposure Control Plan (ECP): You must receive a detailed explanation of your workplace’s ECP, focusing on its location and how you can access it.
- Methodologies and Procedures: The session must cover the proper use and limitations of engineering controls, work practice controls, and Personal Protective Equipment (PPE).
- Exposure Incident Procedures: You must fully understand the steps you need to take immediately following an exposure incident, including reporting and medical follow-up requirements.
- Vaccination Information: You need current information regarding the Hepatitis B vaccine, including its availability and effectiveness.
Crucially, the training must be specific to your duties. You should not receive a generic presentation. The instruction must relate directly to the tasks you perform and the specific hazards you might face in your job.
You have the right to ask questions during the session and get clear, understandable answers from the trainer.
It is common nowadays for employers to use a hybrid training model whereby you will take standardised training from an online provider selected by your employer and then receive workplace specific training onsite.
All BBP training will provide Bloodborne Pathogens certification to prove compliance. This certificate will prove you have taken an OSHA compliant training and passed an exam, and will be valid for one year.
Training for New Hazards and Procedures
Compliance is dynamic, not static. If your workplace introduces new or modified tasks, procedures, or implements new engineering controls that affect your risk of occupational exposure, your employer cannot wait for the annual refresher period. You must receive additional training before you are allowed to perform the new tasks or use the new equipment.
For example, if your organization adopts a new type of safety syringe or changes the location for regulated waste disposal, you need to be trained on that specific change immediately. This specific, supplemental training ensures you know how to maintain safety standards despite changes in the work environment or process. The intent of this rule is simple: You should never face a hazard in the workplace without first understanding how to mitigate it. This proactive approach prevents accidents before they have a chance to occur.
Mandatory Record Retention for Training Documents
Documentation is how your employer proves they met the training requirements under the OSHA standard. If an incident or inspection occurs, these records demonstrate that you were properly informed and trained on dealing with Bloodborne Pathogens hazards.
OSHA requires very specific information to be included in the training records:
- The dates when the training sessions took place.
- A detailed summary of the training content (the lesson plan or materials used).
- The names and job titles of all employees who attended the training session.
- The names and qualifications of the instructors who taught the session.
Your employer must keep these records for 3 years from the date the training occurred.
This three-year retention period allows authorities to review the organization’s compliance history and confirm that employees received regular, relevant instruction. You can expect records to be kept in a secure, organized manner, usually managed by the safety or human resources department. Knowing these requirements helps you understand your professional responsibilities regarding attendance and documentation integrity.
Who Needs the Training?
The short answer is, anyone who may be at risk of exposure to blood-borne pathogens. There are many jobs and industries that require the training, including manufacturing, warehousing, hospitality, tattoo and body artists, janitorial and housekeeping staff; and numerous others. For a full guide on who needs bloodborne pathogen training see this article.
Summary
The OSHA Bloodborne Pathogens workplace standards are extremely thorough and understanding them can feel a bit overwhelming.
The key thing to remember is that the onus is on the employer to ensure they are compliant. Your part is to implement what you learn from the required training, follow all stipulated procedures and best practices and do your part in ensuring a safe and disease free workplace.
Reference Sources and Links
OSHA Model Exposure Control Plan
OSHA Sample Bloodborne Pathogens Exposure Control Plan
The OSHA Bloodborne Pathogens Standard
OSHA Guide to Personal Protective Equipment
CDC Donning and Doffing of PPE Procedures
OSHA Hepatitis B Vaccination Protection
OSHA Hepatitis B Vaccination Requirements for Employees
OSHA Bloodborne Pathogen Exposure Incidents
OSHA Documentation of Employees Hepatitis B Vaccination Status
OSHA Bloodborne Pathogens Post-Exposure Evaluation and Follow Up
