How To Comply with the OSHA Bloodborne Pathogen Standard
If you’re a business owner or you manage safety at a business, you probably don’t have time to deal with confusing regulations like the Bloodborne Pathogen Standard. We’re going to make it easy for you! The last thing you need is to be audited by OSHA and potentially face fines and business interruptions.
It looks really complicated but it’s not hard. The first thing you need to do is figure out if your employees could be exposed to blood or other potentially infectious body fluids (listed below in bold). A lot of business owners think that the bloodborne pathogen standard only applies to people in the medical field, but it can apply to lots of other businesses too.
[Side Blurb: The red arrows point to the actual regulations from the Code of Federal Regulations. You don’t need to read them, but they’ll help you understand if you choose to.]
If you could reasonably anticipate that your employees could be exposed to blood or other infectious body fluids (below in bold) on the job, you need to comply with the bloodborne pathogen standard. This includes janitorial employees and housekeepers, tattoo artists, waste management workers such as garbage collectors, lab workers, funeral industry workers and many more.
The following human body fluids must be treated as infectious like blood:
semen,
vaginal secretions,
cerebrospinal fluid,
synovial fluid,
pleural fluid,
pericardial fluid,
peritoneal fluid,
amniotic fluid,
saliva in dental procedures,
any body fluid that is visibly contaminated with blood,
and all body fluids in situations where it is difficult or impossible to differentiate between body fluids;
Once you determine if some of your employees could be exposed, you need to make a list of which positions within your company could be exposed and which couldn’t. For example, if you are a cleaning company and have cleaning personnel cleaning homes or businesses and you also have sales or office staff, it would be reasonable to say that your cleaning people could be exposed but you wouldn’t expect your office staff to be exposed. List out the titles of employees who could be exposed.
You’re going to want to download the PDF template here (template link) and enter the job titles of individuals who could be exposed, and list what tasks they could be doing as well on page 4.
This list is going to be part of your Exposure Control Plan or ECP for short. This is just a document which describes how you protect your employees from the germs in blood that could make people sick. You can use the fillable PDF download above and enter your business’s information to make the exposure control plan. It’s easy.
You can make your Exposure Control Plan by entering your business’s information in the fillable PDF at the download link here: Exposure Control Plan Fillable PDF
Once you start using your exposure control plan, you’ll need to make sure you update it annually with input from your employees who could be exposed. So, remember to talk to your employees in 11 months of so and update the plan with any new positions at your company, tasks where people could be exposed or types of Personal Protective Equipment (Don’t worry we’ll explain Personal Protective Equipment in a minute.) your employees use. If you’re using our FREE Exposure Control Plan template, we will email you a reminder when it’s time to update your ECP.
Now you’re going to have to think about how you’re going to protect your employees from blood and other infectious body fluids. Usually, this means gloves and sometimes safety glasses if there’s a possibility they could splash it in their eyes. This is called PPE or Personal Protective Equipment (Thank covid for teaching us that…). If your employees are handling really large amounts of contaminated stuff, they may need gowns or aprons, but this is rare and usually only for medical or lab workers.
If your employees are handling needles or other sharp stuff with blood on it, you’ll need to think about that too. You can protect your employees from needles with “sharps boxes”. The fancy thing to call tools like sharps boxes that protect people is “engineering controls”. Other engineering controls are things like special retractable needles and anything else to isolate your employees from potential exposure. So, make sure to get some of these sharps bins if your employees might be contacting needles or even broken glass with blood on it.
Link to Sharps Disposal Container
Another thing to make sure your employees do is follow safe work practices. In this case, they should be washing their hands if they touch something with blood on it, even if they were wearing gloves. If you touch something with blood on it and then touch your eyes, nose or mouth you can get sick from those germs.
I know this may seem like a lot but remember that it’s all written down in the PDF Exposure Control Plan download.
If your employees are handling anything which is contaminated with blood or other potentially infectious fluids (remember the list in bold above) you’re going to need separate, leak proof containers which should be labeled with the biohazard symbol, or color coded as red. This doesn’t need to be anything fancy, just separate red plastic bags or bins will do fine. This is where you’ll put things like contaminated laundry or trash. You can either use color coding or label them with the biohazard symbol below.
We recommend you simply order a roll of sticky biohazard labels online and stick them to any containers where you store or dispose of potentially contaminated items. This way OSHA can’t argue that your employees were unaware of your color-coding system, and it just makes everything simpler. You can also simply print out the biohazard labels here: Printable Biohazard Labels
Link to Biohazard Labels
Link to Red Bags
Great! Now you’ve completed your exposure control plan and protected your employees with PPE, “Engineering controls” (such as sharps bins) and safe work practices like hand washing. You have also labeled anything potentially infectious so that people can identify the hazard. Now you need to offer your employees the Hepatitis B vaccine and get them Bloodborne Pathogen Trained. You can make your own bloodborne pathogen training based on OSHA’s 29 CFR 1910.1030 requirements or use the quick and easy SimpleSafetyGuide.com Bloodborne Pathogen Training. Our training was designed by safety professionals with years of experience in corporate safety compliance so you know it meets all the OSHA requirements. Many training courses available online miss important points which may lead to OSHA fines.
It’s required that all employees who could be exposed to blood or other potentially infectious body fluids are trained by a OSHA compliant Bloodborne Pathogen training like the one at SimpleSafetyGuide.com before they begin work in an area where they could be exposed and annually after that. If you get training from us at SimpleSafetyGuide.com we will send you an email to remind you that retraining is due next year.
Buy Bloodborne Pathogen Training Now
You’ll need to offer your employees the Hepatitis B vaccine within 10 days of being assigned to work anywhere they could be exposed. If they don’t want to take the vaccine they will need to sign the a form called a Hepatitis B Vaccine Declination Form.
Link to download Vaccination form
It’s easy to have your employees vaccinated at most urgent care centers which offer occupational health services. If you call around your local urgent care centers, it won’t be hard to find. Major companies like Patient First and Concentra offer these services in every major city. SimpleSafetyGuide.com has no relationship with these companies and we don’t endorse them, but we want to make it as easy as possible for you to get your Bloodborne Pathogen Compliance setup so we wanted to give you some examples.
It’s important to have a relationship with a local occupational health clinic which can offer your Hepatitis B Vaccines and provide your employees a medical evaluation if they are exposed. You will need to enter the name and address of this clinic or medical professional in your Exposure Control Plan.
You’ll need to keep the form on file for the time the employee works for you plus 30 years, so basically forever. We recommend you keep the form in your files as long as you’re in business. You also need to record any incidents where your employees are injured by sharps like needles or broken glass on the sharps incident log here:
Link to sharps incident log
The last thing you need to do is plan for what to do if one of your employees is exposed to a bloodborne pathogen. An exposure is when someone gets blood or another potentially infectious body fluid (listed above) in their eyes, nose, mouth or in a break in the skin. If someone gets one of these fluids on their intact skin that is not an exposure (you can learn all about this in our Bloodborne Pathogen Training!
If you have an exposure incident, you will need to send your employee to see a medical professional and they will decide on what to do. Make sure you document what happened including how they were exposed and the circumstances under which the exposure occurred.
That’s it! You’ve complied with OSHA’s Bloodborne Pathogen Standard. We know it seems complicated, but with help from SimpleSafetyGuide.com, it’s simple. Remember to download our fillable Exposure Control Plan for FREE and fill it out, then get your employees trained with our Simple Bloodborne Pathogen Training.
Good Luck in your business!
Written by Andrew Oestmann Chase
Founder, Simple Safety Institute