OSHA Bloodborne Pathogens Standard (29 CFR 1910.1030): Healthcare Compliance Guide

Overview of the Bloodborne Pathogens Standard

OSHA Bloodborne Pathogens Standard (29 CFR 1910.1030) protects healthcare workers and others from occupational exposure to blood and other potentially infectious materials (OPIM). Understanding and implementing this standard is essential for healthcare facilities, laboratories, and any workplace with potential blood exposure.

Scope and Application

Covered Employers

• Hospitals and healthcare facilities
• Physicians and dental offices
• Clinical and research laboratories
• Blood banks and plasma centers
• Funeral homes
• Correctional facilities
• First responders (EMS, fire, police)

Covered Materials

• Human blood and blood components
• Semen and vaginal secretions
• Cerebrospinal fluid
• Synovial fluid
• Pleural, peritoneal, and pericardial fluids
• Amniotic fluid
• Saliva in dental procedures
• Unfixed human tissues and organs
• HIV and HBV-containing cultures

Exposure Control Plan

Required Elements

• Exposure determination by job classification
• Schedule of implementation methods
• Procedure for incident evaluation
• Annual review and update
• Employee input on engineering controls

Exposure Determination

Identify employees with occupational exposure without regard to personal protective equipment:

• List all job classifications with exposure
• List tasks and procedures with exposure
• Document exposure frequency and circumstances

Methods of Compliance

Universal Precautions

Treat all human blood and OPIM as if known to be infectious for bloodborne pathogens.

Engineering Controls

Devices that isolate or remove the bloodborne pathogen hazard:

• Self-sheathing needles
• Needleless systems
• Sharps containers
• Biosafety cabinets
• Splash guards

Sharps Injury Log

Maintain log of injuries from contaminated sharps including:

• Type and brand of device involved
• Department or work area
• Explanation of how injury occurred
• Confidentiality maintained

Work Practice Controls

• Hand hygiene after removing gloves
• No recapping, bending, or breaking contaminated needles
• No eating, drinking, or applying cosmetics in work areas
• Specimens in leak-proof containers
• Minimize splashing and spraying
• Mouth pipetting prohibited

Personal Protective Equipment (PPE)

Employer Responsibilities

• Provide appropriate PPE at no cost
• Ensure proper fit and accessibility
• Clean, repair, or replace as needed
• Ensure proper use

Required PPE

• Gloves: Single-use, appropriate material
• Gowns/lab coats: Appropriate to task and exposure
• Face protection: Masks and eye protection or face shields
• Mouthpieces/resuscitation bags: For CPR

Housekeeping

• Clean and decontaminate work surfaces
• Use appropriate disinfectants (EPA-registered tuberculocidal)
• Clean contaminated equipment before servicing
• Handle contaminated laundry with minimum agitation
• Proper waste disposal procedures

Hepatitis B Vaccination

Employer Requirements

• Offer HBV vaccine within 10 days of initial assignment
• Provide at no cost to employee
• Provide during working hours
• By licensed healthcare professional

Employee Options

• Accept vaccination
• Decline (must sign declination form)
• May accept later if initially declined
• Post-exposure evaluation and follow-up

Declination Statement

If employee declines vaccination, must sign statement acknowledging:

• Risk of HBV infection
• Vaccine offered at no cost
• Right to receive vaccine later

Post-Exposure Evaluation and Follow-Up

Immediate Actions

1. Wash wound and flush mucous membranes
2. Report incident immediately
3. Document route of exposure
4. Identify source individual if possible

Source Identification

• Attempt to identify source individual
• Test source blood if consent obtained
• Inform exposed employee of source results
• Maintain confidentiality

Medical Evaluation

• Confidential evaluation by healthcare professional
• Testing of employee blood (with consent)
• Post-exposure prophylaxis if indicated
• Counseling
• Follow-up testing as recommended

Healthcare Professional Written Opinion

Employer receives opinion limited to:

• HBV vaccination indication and administration
• Employee informed of evaluation results
• Need for further evaluation or treatment

Communication of Hazards

Labels and Signs

• Biohazard labels on contaminated items
• Red bags or containers may substitute for labels
• Signs for restricted areas
• Labels on specimen containers

Warning Labels Must Include

• Biohazard symbol
• Word “BIOHAZARD”
• Fluorescent orange/orange-red with contrasting letters

Training Requirements

Initial Training

Before assignment to tasks with occupational exposure:

• Bloodborne pathogen information
• Epidemiology and symptoms
• Modes of transmission
• Exposure control plan
• Engineering and work practice controls
• PPE use
• HBV vaccination information
• Post-exposure procedures
• Signs, labels, and color coding

Annual Refresher Training

• Required within one year of previous training
• Update on any changes
• Opportunity for questions

Training Documentation

• Dates of training sessions
• Contents of training
• Trainer qualifications
• Names and job titles of attendees

Recordkeeping

Medical Records

• Maintain for duration of employment plus 30 years
• Include vaccination status and declinations
• Include post-exposure evaluation results
• Confidential per 29 CFR 1910.1020

Training Records

• Maintain for 3 years from training date
• Available to employees and OSHA

Sharps Injury Log

• Maintain for 5 years
• Protect employee privacy
• Include required information

Enforcement and Penalties

OSHA Inspections

• Complaint-based or programmed inspections
• Document review
• Employee interviews
• Workplace observation

Citation Categories

• Willful: Up to $156,259 per violation
• Serious: Up to $15,625 per violation
• Other-than-serious: Up to $15,625 per violation
• Repeat: Up to $156,259 per violation

Needlestick Safety and Prevention Act

2000 amendments to the BBP standard requiring:

• Use of safer needle devices
• Employee input on device selection
• Sharps injury log maintenance
• Annual review of engineering controls

Conclusion

Compliance with the Bloodborne Pathogens Standard protects healthcare workers from serious occupational infections. A comprehensive exposure control plan, proper training, engineering controls, and post-exposure protocols are essential elements of an effective program.