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Exposure determination requirements
  • Exposure determination requires employers to identify and document which employees can reasonably anticipate exposure to blood or OPIM in their job duties.
  • Job classifications should be divided into two groups: jobs in which all employees have occupational exposure, and jobs in which only some employees have occupational exposure.

Exposure determination requires employers to identify and document which employees have occupational exposure, based on the definition of occupational exposure without the use of personal protective clothing or equipment. Employers should make the exposure determination by reviewing job classifications and dividing them into two groups:

  • All employees have occupational exposure, and
  • Some employees have occupational exposure.

The first group includes job classifications in which all employees have occupational exposure. Examples include pre-hospital care workers such as paramedics and emergency medical technicians. Where all employees have occupational exposure, it’s not necessary to list specific work tasks in the exposure determination.

The second group includes job classifications in which only some of the employees have occupational exposure. For this group, it’s necessary to list the specific tasks and procedures, or closely related groups of tasks and procedures, that can cause exposure. An example would be if some custodians are assigned to handle blood spills while others are not. In that case, the employer would list custodians in the second group and then list something like “blood spill cleanup tasks” under that job class.

If a job classification, task, or procedure involving occupational exposure is left off the list, but all employees in the job or performing the task or procedure have been included in all other aspects of the plan (such as vaccinations and training), this is considered an other-than-serious violation.