• Employee exposure to blood and OPIM [29 CFR 1910.1030(b)] due to ineffective Exposure Control Plan (ECP).

• Identify employees who have occupational exposure to blood or OPIM [29 CFR 1910.1030(b)], and then establish and implement a written Exposure Control Plan (ECP), designed to eliminate or minimize employee exposure [29 CFR 1910.1030(c)(1)].
• Exposure Control Plan requirements include:
  • Documenting an annual review and update of the written plan that reflects changes in technology for safer medical devices [29 CFR 1910.1030(c)(1)(iv)(A)]. Employers must also document consideration and implementation of the safer medical devices annually [29 CFR 1910.1030(c)(1)(iv)(B)].
  • Employer must get input for the devices from those responsible for direct patient care [29 CFR 1910.1030(c)(1)(v)]. This input must also be documented.
• Employer should ensure that the Exposure Control Plan (ECP) is accessible to all employees [29 CFR 1910.1030(c)(1)(iii)]. They should also review and update it at least yearly [29 CFR 1910.1030(c)(1)(iv)].
• Employer should ensure that employees with occupational exposure to bloodborne pathogens receive appropriate training, at no cost to employee, and during working hours [29 CFR 1910.1030(g)(2)(i) and 29 CFR 1910.1030(g)(2)(vii)].
  
 

For additional information, see Healthcare Wide Hazards - Needlesticks/Sharps Injuries.

• Bloodborne Pathogens. OSHA Safety and Health Topics Page.
• Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens Standard. OSHA Directive CPL 02-02-069 [CPL 2-2.69], (2001, November 27).
• Model Plans & Programs for the OSHA Bloodborne Pathogens and Hazard Communication Standards. OSHA Publication 318, (2003), 29 pages. Also available as a 520 KB PDF.

• No post-exposure follow-up made available after a needlestick/sharps injury to help document injury or offer medically indicated post-exposure prophylaxis.

• Employer should ensure that a Post-Exposure Evaluation and Follow-up is in place to handle needlestick/sharps injuries.
• Employer should provide a confidential medical evaluation and follow-up to the exposed employee, immediately following the report of an exposure incident [29 CFR 1910.1030(f)(3)]. It is recommended that the follow-up include identifying injury patterns and accident analysis to determine if other training, procedures, or safer needle devices should be used to prevent future accidents.
  • Post-exposure evaluation and follow-up should include:
    • A confidential medical evaluation [29 CFR 1910.1030(f)(3)].
      
    • Documentation of the route(s) of exposure and the circumstances under which the exposure incident occurred [29 CFR 1910.1030(f)(3)(i)]. Testing of the source individual's blood [29 CFR 1910.1030(f)(3)(ii)(A)] and making the results of the source individual's testing usually after consent, available to the exposed employee [29 CFR 1910.1030(f)(3)(ii)(C)].
      
    • Administration of post-exposure prophylaxis, when medically indicated, as recommended by the US Public Health Service [29 CFR 1910.1030(f)(3)(iv)].
      
      • Updated U.S. Public Health Service Guidelines for the Management of Occupational Exposures to HBV, HCV, and HIV and Recommendations for Postexposure Prophylaxis. Centers for Disease Control and Prevention (CDC) Morbidity and Mortality Weekly Report (MMRW) 50(RR11);1-42, (2001, June 29). Also available as a 334 KB PDF, 67 pages.
      • Updated U.S. Public Health Service Guidelines for the Management of Occupational Exposures to HIV and Recommendations for Postexposure Prophylaxis. Centers for Disease Control and Prevention (CDC), Morbidity and Mortality Weekly Report (MMWR) 54(RR09); 1-17, (2005, September 30). Updates US Public Health Service recommendations for the management of the health-care personnel (HCP) who have occupational exposure to blood and other body fluids that might contain human immunodeficiency virus.
• Maintain a log of injuries from contaminated sharps [29 CFR 1910.1030(h)(5)].
• The National Institute for Occupational Safety and Health (NIOSH) recommends that if an employee experiences a needlestick/sharps injury or is exposed to blood or other body fluid during the course of work that the following steps be taken immediately:
  
  • Wash needlestick and cuts with soap and water.
    
  • Flush splashes to the nose, mouth, or skin with water.
    
  • Irrigate eyes with clean water, saline, or sterile irrigates.
    
  • Report the incident to your supervisor.
    
  • Seek medical treatment immediately.
    
• Questions about appropriate medical treatment for occupational exposures to blood is available 24 hours from the Clinicians' Post Exposure Prophylaxis Hotline (PEPline) (1-888-448-4911).

• Lack of information to adequately implement a bloodborne pathogens program or address bloodborne pathogen hazards.

• Employer should establish and maintain both medical and training records [29 CFR 1910.1030(h)(1) and 29 CFR 1910.1020].
  • If an exposure incident occurs, employer should add reports to the medical record to document the incident, including testing results following the incident, follow-up procedures, and the written opinion of the health care professional.
    • Medical Records must be preserved and maintained for each employee with an occupational exposure to bloodborne pathogens [29 CFR 1910.1030(h)(1)] and for at least the duration of employment plus 30 years. They must be kept confidential (not disclosed without written permission of employee, except by law) and separate from other personnel records and must also include:
      
      • The employee's name and social security number, hepatitis B vaccination status, including the dates of vaccination and medical records related to the employee's ability to receive vaccinations.
    • Training Records must be established and maintained for all exposed employees for 3 years, from the date the training occurred. They must include [29 CFR 1910.1030(h)(2)]:
      
      • The names and job titles of all persons attending the training sessions, the dates, and content of the training sessions, and the names and qualifications of all trainers.
  • Whenever an employer is ceasing to do business and there is no successor employer to receive and maintain the records subject to this standard, the employer must notify affected current employees of their rights of access to records at least three (3) months prior to the cessation of the employer's business. [29 CFR 1910.1020(h)(2)]
    
• Employer must make both medical and training records available upon request to: [29 CFR 1910.1030(h)(3)(ii)]
  
  • Director of NIOSH.
    
  • Assistant Secretary of Labor for the Occupational Safety and Health.
    
  • Employees or employee representatives (someone having written consent of the employee).
• Employer must maintain a log of injuries from contaminated sharps [29 CFR 1910.1030(h)(5)] for each injury including:
  
  • Type and brand of device involved [29 CFR 1910.1030(h)(5)(i)(A)]
    
  • Department or work area of occurrence [29 CFR 1910.1030(h)(5)(i)(B)]
    
  • Explanation of how the incident occurred [29 CFR 1910.1030(h)(5)(i)(C)]

NOTE: If an employer is not required to maintain injury/illness log under 1904, then this does not apply [29 CFR 1910.1030(h)(5)(ii)].

• Recordkeeping. OSHA.

• Exposure to blood and OPIM from needlestick injuries due to:
  • Unsafe needle devices.
  • Improper handling and disposal of needles.

• Use safer needle devices and needleless devices to decrease needlestick or other sharps exposures. See Safer Needle Devices Section.
• Proper handling and disposal of needles and other sharps according to the Bloodborne Pathogens Standard can help prevent needlestick injuries. See Handling Needles/Sharps.

For additional information, see Healthcare Wide Hazards - Needlesticks/Sharps Injuries.

• Use of Blunt-Tip Suture Needles to Decrease Percutaneous Injuries to Surgical Personnel. OSHA and the National Institute for Occupational Safety and Health (NIOSH) Publication No. 2008-101, (2007, October). Also available as a 281 KB PDF, 4 pages. Supersedes NIOSH Publication 2007–132.
  

• Exposure to blood and OPIM through other sharps:
  • Glass Capillary Tubes that break when used may result in a penetrating wound.
  • I.V. Connectors that use needle systems.
  • Disposable razors that could be contaminated. These should be considered "contaminated sharps" and be disposed of properly in appropriate sharps containers.

• Implement engineering and work practice controls to help prevent exposures.

 

For additional information, see Healthcare Wide Hazards - Needlesticks/Sharps Injuries.
 

• Exposure to bloodborne pathogens due to lack of universal precautions.

• Employer should implement universal precautions [29 CFR 1910.1030(d)(1)].
  
  • Treat all blood and other potentially infectious materials with appropriate precautions.
    
    • Use gloves, masks, and gowns if blood or OPIM exposure is anticipated.
    • Use engineering and work practice controls to limit exposure.
      

For additional information, see Healthcare Wide Hazards - Universal Precautions.

• Exposure to blood and OPIM due to an ineffective Personal Protective Equipment (PPE) program.

• Appropriate use of Personal Protective Equipment (PPE). PPE is required by the Bloodborne Pathogens Standard (if exposure to blood and OPIM is anticipated and where occupational exposure remains, after institution of engineering and work practice controls) [29 CFR 1910.1030(d)(2)(i)].
• Wear gloves when hand contact with blood, mucous membranes, OPIM, or non-intact skin is anticipated, and when performing vascular access procedures, or when handling contaminated items or surfaces [29 CFR 1910.1030(d)(3)(ix)].
• Employer must ensure that employees wash hands and any other skin with soap and water or flush mucous membranes with water as soon as feasible after contact with blood or other potentially infectious materials (OPIM) [29 CFR 1910.1030(d)(2)(vi)].
  
• Employers must provide readily accessible hand washing facilities [29 CFR 1910.1030(d)(2)(iii)].
• Dispose of PPE. Protective clothing must be removed before leaving the work area [29 CFR 1910.1030(d)(3)(vii)], and disposed of in an appropriately designated area or container for storage, washing, decontamination or disposal [29 CFR 1910.1030(d)(3)(viii)].

• Exposure to latex in products like latex gloves and developing latex sensitivity or a latex allergy.

• Employers must provide appropriate gloves when exposure to blood or other potentially infectious materials (OPIM) exists [29 CFR 1910.1030].
  
• Alternatives shall be readily accessible to those employees who are allergic to the gloves normally provided [29 CFR 1910.1030(d)(iii)].
   

For additional information, see Healthcare Wide Hazards - Latex Allergy.

• Exposure to a potentially fatal bloodborne illnesses such as Hepatitis B Virus (HBV).
  
  • Hepatitis is much more transmissible than HIV.
    
  • Risk of infection from a single needlestick is 6%-30%.
    
  • 50% of the people with HBV infection are unaware that they have the virus.
  • The CDC states that HBV can survive for at least one week in dried blood on environmental surfaces or contaminated needles and instruments. For additional information, see Contaminated Work Environments.

• Employer should implement an effective exposure control plan [29 CFR 1910.1030(c)(1)] to prevent exposure.
  
• Employer must offer all employees who have occupational exposure to blood or OPIM, under the supervisions of a licensed physician the hepatitis B vaccination [29 CFR 1910.1030(f)(2)]:
  
  • Except as provided in 29 CFR 1910.1030(f)(2)(i).
  • At no cost to employee, at a reasonable time and place [29 CFR 1910.1030(f)(2)(i)].
  • After the employee has received the required training [29 CFR 1910.1030(f)(1)].
  • Within 10 working days of initial assignment.
  • Those declining the hepatitis B vaccine must sign a declination statement [29 CFR 1910.1030 Appendix A]. A sample declination form is available.
  • OSHA provides the following non-mandatory sample form: Written Opinion for Hepatitis B Vaccination.
    
• Employer should offer testing for antibody to hepatitis B surface antigen one to two months after the completion of the three-dose vaccination series.
  • Employees who do not respond to the primary vaccination series must be offered a second three-dose vaccine series and retesting. Non-responders must be offered medical evaluation [29 CFR 1910.1030(f)(1)(ii)(D)].
    
  • Employee must be offered a timely post-exposure follow-up with hepatitis B immune globulin and initiation of hepatitis B vaccine [29 CFR 1910.1030(f)(1)(ii)(D)].
    
  • A healthcare professional's written opinion is required after an exposure incident [29 CFR 1910.1030(f)(5)(ii)].
    
    • OSHA provides the following non-mandatory sample form: Written Opinion for Post-Exposure Evaluation.
• Employer should make immediately available a confidential medical evaluation and follow-up [29 CFR 1910.1030(f)(3)], following a report of an exposure incident.
• Employer must maintain a log of injuries from contaminated sharps [29 CFR 1910.1030(h)].
  

• Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens Standard. OSHA Directive CPL 02-02-069 [CPL 2-2.69], (2001, November 27).
• A Comprehensive Immunization Strategy to Eliminate Transmission of Hepatitis B Virus Infection in the United States. Centers for Disease Control and Prevention (CDC), Morbidity and Mortality Weekly Report (MMWR) 55(RR16);1-25, (2006, December 8).
• Immunization of Health Care workers. Centers for Disease Control and Prevention (CDC), Recommendations of the Advisory Committee on Immunization Practices (ACIP) and the Hospital Infection Control Practices Advisory Committee (HICPAC) 46(RR-18);1-42, (1997, December 26).
• Bloodborne Pathogens in Healthcare Settings. Centers for Disease Control and Prevention (CDC), Division of Healthcare Quality Promotion, (2001).
• Updated U.S. Public Health Service Guidelines for the Management of Occupational Exposures to HBV, HCV, and HIV and Recommendations for Postexposure Prophylaxis. Centers for Disease Control and Prevention (CDC) Morbidity and Mortality Weekly Report (MMRW) 50(RR11);1-42, (2001, June 29). Also available as a 334 KB PDF, 67 pages.
• Viral Hepatitis. Centers for Disease Control and Prevention (CDC), National Center for HIV, STD, & TB Prevention.

• Exposure to potentially fatal bloodborne illnesses such as Human Immunodeficiency Virus (HIV).
  
  • Risk of HIV infection after needlestick is 1 in 3,000 or 0.3%.
    
  • The CDC documented 55 cases and 136 possible cases of occupational HIV transmission to US healthcare workers between 1985 and 1999.

• Employer should implement an effective exposure control plan [29 CFR 1910.1030(c)(1)] to prevent exposure.
  
• Employer must, under certain circumstances, provide post-exposure prophylaxis for HIV to healthcare workers who have an exposure incident [29 CFR 1910.1030(b)].
  • Limited data suggests that such prophylaxis may considerably reduce the chance of becoming infected with HIV. However, the drugs used for prophylaxis have many adverse side effects.
• Employer must offer employees who have an incident a confidential medical evaluation and follow-up [29 CFR 1910.1030(f)(3)].
  
  • A healthcare professional's written opinion is required after an exposure incident [29 CFR 1910.1030(f)(5)(ii)].
    
    • The following non-mandatory sample form is available: Written Opinion for Post-Exposure Evaluation.
• Employer must maintain a log of injuries from contaminated sharps [29 CFR 1910.1030(h)].

• Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens Standard. OSHA Directive CPL 02-02-069 [CPL 2-2.69], (2001, November 27).
• Updated U.S. Public Health Service Guidelines for the Management of Occupational Exposures to HBV, HCV, and HIV and Recommendations for Postexposure Prophylaxis. Centers for Disease Control and Prevention (CDC) Morbidity and Mortality Weekly Report (MMRW) 50(RR11);1-42, (2001, June 29). Also available as a 334 KB PDF, 67 pages.
• Updated U.S. Public Health Service Guidelines for the Management of Occupational Exposures to HIV and Recommendations for Postexposure Prophylaxis. Centers for Disease Control and Prevention (CDC), Morbidity and Mortality Weekly Report (MMWR) 54(RR09); 1-17, (2005, September 30). Updates US Public Health Service recommendations for the management of the health-care personnel (HCP) who have occupational exposure to blood and other body fluids that might contain human immunodeficiency virus.

• Exposure to potentially fatal bloodborne illnesses such as Hepatitis C Virus (HCV), which is a major cause of chronic liver disease.
  • Risk of HCV infection after needlestick is 1.8%.

• Employer should implement an effective exposure control plan [29 CFR 1910.1030(c)(1)] to prevent exposure.
  
• Employer must offer employees who have an incident a confidential medical evaluation and follow-up [29 CFR 1910.1030(f)(3)].
  • A healthcare professional's written opinion is required after an exposure incident [29 CFR 1910.1030(f)(5)(ii)].
    
    • The following non-mandatory sample form is available: Written Opinion for Post-Exposure Evaluation.
  • Immunoglobulin or antiviral therapy is not recommended and no effective post-exposure prophylaxis is known at this time (CDC 1998).

• Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens Standard. OSHA Directive CPL 02-02-069 [CPL 2-2.69], (2001, November 27).
• Hepatitis C: What Clinicians and other Health Professionals Need to Know. Centers for Disease Control and Prevention (CDC), (2001).
• Bloodborne Pathogens in Healthcare Settings. Centers for Disease Control and Prevention (CDC), Division of Healthcare Quality Promotion, (2001).
• Recommendations for Prevention and Control of Hepatitis C Virus (HCV) Infection and HCV-Related Chronic Disease. Centers for Disease Control and Prevention (CDC), Morbidity and Mortality Weekly Report (MMWR) 47(RR19);1-39, (1998, October 16).
• Updated U.S. Public Health Service Guidelines for the Management of Occupational Exposures to HBV, HCV, and HIV and Recommendations for ostexposure Prophylaxis. Centers for Disease Control and Prevention (CDC) Morbidity and Mortality Weekly Report (MMRW) 50(RR11);1-42, (2001, June 29). Also available as a 334 KB PDF, 67 pages.
• Viral Hepatitis C. Centers for Disease Control and Prevention (CDC), National Center for HIV, STD, & TB Prevention.

• Exposure to bloodborne pathogens due to improper labeling of potential hazards.

• Implement labeling and signs.
  
  • Biohazardous Waste Container. Regulated waste, such as I.V. tubing used to administer blood, contaminated PPE, and needles etc., must be disposed of into appropriately labeled biohazardous waste containers [29 CFR 1910.1030(g)(1)(A)].
  • Biohazard Label. Containers that contain regulated waste (contaminated PPE, needles, etc.) as well as refrigerators and freezers containing blood or OPIM, must bear the biohazard symbol [29 CFR 1910.1030(g)(1)(i)(A)
    • Labels should be fluorescent orange or orange-red, with lettering and symbols in a contrasting color [29 CFR 1910.1030(g)(1)(i)(C)].
    • Red bags or red containers may be substituted for labels [29 CFR 1910.1030(g)(1)(i)(E)].
  • Exception for Blood Products. Individual containers of blood, blood components or products that are labeled as to their contents and have been released for transfusion or other clinical use need not be labeled as hazardous [29 CFR 1910.1030(g)(1)(i)(F)].
    
  • Individual containers of blood or OPIM need not be labeled if placed in a labeled container for storage, transport, shipment or disposal [29 CFR 1910.1030(g)(1)(i)(G)].