FAQs

Are employees such as housekeepers, maintenance workers, and janitors covered by the Bloodborne Pathogens Standard?

Housekeeping workers in healthcare facilities may have occupational exposure, as defined by the standard. Individuals who perform housekeeping duties, particularly in patient care and laboratory areas, may perform tasks, such as cleaning blood spills and handling regulated wastes, which cause occupational exposure.

While OSHA does not generally consider all maintenance personnel and janitorial staff employed in non-healthcare facilities to have occupational exposure, it is the employer’s responsibility to determine which job classifications or specific tasks and procedures involve occupational exposure. For example, OSHA expects products such as discarded sanitary napkins to be discarded into waste containers which are lined in such a way as to prevent contact with the contents. At the same time, the employer must determine if employees can come into contact with blood during the normal handling of such products from initial pick-up through disposal in the outgoing trash.

If OSHA determines that sufficient evidence of reasonably anticipated exposure exists, the employer will be held responsible for providing the protections of 1910.1030 to the employees with occupational exposure.

Are employees such as housekeepers, maintenance workers, and janitors in warehouse and storage facilities covered by the Bloodborne Pathogens Standard?

While OSHA does not generally consider all maintenance personnel and janitorial staff employed in non-healthcare facilities to have occupational exposure, it is the employer’s responsibility to determine which job classifications or specific tasks and procedures involve occupational exposure. For example, OSHA expects products such as discarded sanitary napkins to be discarded into waste containers which are lined in such a way as to prevent contact with the contents. At the same time, the employer must determine if employees can come into contact with blood or other potentially infectious materials during the normal handling of such products from initial pick-up through disposal in the outgoing trash. If OSHA determines, on a case-by-case basis, that sufficient evidence of reasonably anticipated exposure exists, the employer will be held responsible for providing the protections of 29 CFR 1910.1030 to the employees with occupational exposure.

Are feminine hygiene products considered regulated waste?

OSHA does not generally consider discarded feminine hygiene products to fall within the definition of regulated waste. The intended function of products such as sanitary napkins is to absorb and contain blood. The absorbent material of which they are composed would, under most circumstances, prevent the release of liquid or semi-liquid blood or the flaking off of dried blood.

OSHA expects these products to be discarded into waste containers which are properly lined with plastic or wax paper bags. Such bags should protect employees from physical contact with the contents.

At the same time, it is the employer’s responsibility to determine the existence of regulated waste. This determination is not based on actual volume of blood, but rather on the potential to release blood (e.g., when compacted in a waste container). If OSHA determines that sufficient evidence of regulated waste exists, either through observation (e.g., a pool of liquid in the bottom of a container, dried blood flaking off during handling), or based on employee interviews, citations may be issued if the employer does not comply with the provisions of the standard on regulated waste.

Can tasks and procedures be grouped for certain job classifications in the plan?

Yes. Tasks and procedures that are closely related may be grouped. In other words, they must share a common activity, such as “vascular access procedure” or “handling of contaminated sharps.”

Can pre-screening be required for hepatitis B titer? Post-screening?

The employer cannot require an employee to take a pre-screening or post-vaccination serological test. An employer may, however, decide to make pre-screening available at no cost to the employee.

All medical evaluations and procedures, including the hepatitis B vaccine and vaccination series, are to be provided according to the current recommendations of the U.S. Public Health Service.

According to the current guidelines, employees who have ongoing contact with patients or blood and are at ongoing risk for percutaneous injuries should be tested for anti-HBs one to two months after the completion of the three-dose vaccination series. Non-responders must receive a second three-dose series and be retested after the second series. Non-responders must be medically evaluated.

Can the employer make up its own hepatitis B vaccination declination form?

If an employee declines the hepatitis B vaccination, the employer must ensure that the employee signs a hepatitis B vaccine declination. The declination’s wording is found in Appendix A of the standard. A photocopy of the Appendix may be used as a declination form, or the words can be typed or written onto a separate document.

An employer may use different words if they convey the same information. However, any additions to that language should be made for the sole purpose of improving employee comprehension. Forms must not add language that would discourage employee acceptance of the vaccine, add liability concerns, or require the employee to provide confidential medical information.

Can employees refuse the hepatitis B vaccination?

Employees have the right to refuse the hepatitis B vaccine and/or any post-exposure evaluation and follow-up. However, the employer must properly inform the employee of the benefits of the vaccination and post-exposure evaluation through training. The employee also has the right to decide to take the vaccination at a later date if the employee so chooses. The employer must make the vaccination available at that time.

Can there be substitutes for the biohazard label?

Yes. Red bags or red containers may be substituted for the biohazard label.

Do employers have to buy a washer and dryer to clean employees’ personal protective equipment?

There is no OSHA requirement stipulating that employers must purchase a washer and dryer to launder protective clothing. It is an option that employers may consider. Another option is to contract out the laundering of protective clothing. Employers may also choose to use disposable personal protective clothing and equipment.

Does the exposure control plan need to be a separate document?

No. The exposure control plan may be part of another document, such as the facility’s health and safety manual, as long as all components are included. However, in order for the plan to be accessible to employees, it must be a cohesive entity by itself or there must be a guiding document which states the overall policy and goals and references the elements of existing separate policies that comprise the plan. For small facilities, the plan’s schedule and method of implementation of the standard may be an annotated copy of the final standard that states on the document how the provisions of the standard are implemented. Larger facilities could develop a broad facility program, incorporating provisions from the standard that apply to their establishments.

Does the revised Bloodborne Pathogens standard apply to medical or dental offices that have fewer than 10 employees?

OSHA's Bloodborne Pathogens standard applies to all employers with employees who have occupational exposure to blood or other potentially infectious materials (OPIM), regardless of how many workers are employed. However, the offices and clinics of medical doctors and dentists are exempt from the requirement to keep a log of occupational injuries and illnesses and thus exempt from maintaining a sharps injury log. (See Appendix A to Subpart B of 29 CFR Part 1904.) All other applicable provisions of the Bloodborne Pathogens standard still apply.

Does protective clothing need to be removed before leaving the work area?

Yes. OSHA requires that personal protective equipment be removed before leaving the work area. While “work area” must be determined on a case-by-case basis, a work area is generally considered to be an area where work involving occupational exposure occurs or where the contamination of surfaces may occur.

How often must the exposure control plan be reviewed?

The standard requires an annual review of the exposure control plan. In addition, whenever changes in tasks, procedures, or employee positions affect, or create new occupational exposure, the existing plan must be reviewed and updated accordingly.

How should contaminated laundry be handled?

Contaminated laundry must be handled as little as possible with a minimum of agitation. It must be bagged or containerized at the location where it was used and cannot be sorted or rinsed in the location of use. Also, contaminated laundry must be placed and transported in bags or containers labeled or color-coded in accordance with 1910.1030(g)(1)(i).

When a facility utilizes Universal Precautions in the handling of all soiled laundry, alternative labeling or color-coding is sufficient if it permits all employees to recognize the containers as requiring compliance with Universal Precautions.

Whenever contaminated laundry is wet and presents a reasonable likelihood of soak-through or leakage from the bag or container, the laundry must be placed and transported in bags or containers which prevent soak-through and/or leakage of fluids to the exterior.

Also, the employer must ensure that employees who have contact with contaminated laundry wear protective gloves and other appropriate personal protective equipment.

How long must medical records be kept?

Medical records must be kept for the duration of employment plus 30 years.

How long must bloodborne pathogen training records be kept?

Training records must be retained for three years from the training date.

How must regulated waste be disposed?

Regulated waste must be placed in containers which are:

• Closable;
• Constructed to contain all contents and prevent leakage of fluids during handling, storage, transport or shipping;
• Labeled or color-coded in accordance with 1910.1030(g)(1)(i); and
• Closed before removal to prevent spillage or protrusion of contents during handling, storage, transport, or shipping.

If outside contamination of the regulated waste container occurs, it must be placed in a second container. The second container must be:

• Closable;
• Constructed to contain all contents and prevent leakage of fluids during handling, storage, transport, or shipping;
• Labeled or color-coded in accordance with 1910.1030(g)(1)(i); and
• Closed before removal to prevent spillage or protrusion of contents during handling, storage, transport, or shipping.

Disposal of all regulated waste must be in accordance with applicable regulations.

How should sharps containers be handled?

Sharps containers must be maintained upright throughout use, replaced routinely, and not be allowed to overfill.

When removing sharps containers from the area of use, the containers shall be:

• Closed immediately before removal or replacement to prevent spillage or protrusion of contents during handling, storage, transport, or shipping.
• Placed in a secondary container if leakage is possible, which must be:
  • Closable;
  • Constructed to contain all contents and prevent leakage during handling, storage, transport, or shipping; and
  • Labeled or color-coded according to paragraph (g)(1)(i) of the standard.
• Reusable containers shall not be opened, emptied, or cleaned manually or in any other manner which would expose employees to the risk of percutaneous injury.

Upon closure, duct tape may be used to secure the lid of a sharps container as long as the tape does not serve as the lid itself.

In the exposure control plan, are employers required to list specific tasks that place the employee at risk for all job classifications?

No. If all the employees within a specific job classification perform duties where occupational exposure occurs, then a list of specific tasks and procedures is not required for that job classification. However, the job classification (e.g., “nurse”) must be listed in the plan’s exposure determination, and all employees within the job classification must be included under the requirements of the standard.

Is a routine booster dose of hepatitis B vaccine required?

The U.S. Public Health Service does not recommend routine booster doses of hepatitis B vaccine, so they are not required at this time.

Must the exposure control plan be accessible to employees?

Yes. The exposure control plan must be accessible to employees. The location of the plan may be adapted to the circumstances of a particular workplace, provided that employees can access a copy at the workplace during their work shift. If the plan is maintained solely on a computer, employees must be trained to operate the computer.

A hard copy of the exposure control plan must be provided within 15 working days of the employee’s request as specified under 1910.1020.

Must used razor blades be disposed of in a sharps container?

Uncontaminated used box cutter blades, uncontaminated knives, uncontaminated razor blades, uncontaminated broken glass, other uncontaminated sharps, or any other uncontaminated object that can penetrate the skin do not fall under the definition of regulated waste nor contaminated sharps. Handling uncontaminated sharps would not pose an “occupational exposure” as defined in 1910.1030(b). If no occupational exposure exists, then 1910.1030 does not need to be met.

OSHA does not have any disposal requirements for uncontaminated sharps.

What type of information must be provided to the employee(s) following an exposure incident?

The standard requires that post-exposure counseling be given to employees following an exposure incident. Counseling concerning infection status, including results and interpretation of all tests, will assist the employee in understanding the potential risk of infection and in making decisions regarding the protection of personal contacts. For example, counseling should include U.S. Public Health Service (USPHS) recommendations about the transmission and prevention of HIV. Counseling based on the USPHS recommendations must also be provided for HBV and HCV and other bloodborne pathogens, as appropriate. In addition, counseling must be made available regardless of the employee’s decision to accept serological testing.

What does OSHA mean by the term “contaminated laundry?”

Contaminated laundry means laundry (e.g., towels, bed sheets, clothing) which has been soiled with blood or other potentially infectious materials or may contain sharps.

What water temperature and detergent types are acceptable when laundering personal protective equipment under the Bloodborne Pathogens Standard?

The decontamination and laundering of protective clothing are governed by the laundry provisions of 1910.1030(d)(4)(iv). Washing and drying the garments should be done according to the clothing manufacturer’s instructions.

What are the required colors for the biohazard label?

The label must be fluorescent orange or orange-red or predominantly so, with symbols and lettering in a contrasting color. The label must be either an integral part of the container or affixed as close as feasible to the container by a string, wire, adhesive, or other method to prevent its loss or unintentional removal.

What are the exceptions to the labeling requirement under the Bloodborne Pathogens Standard?

Labeling is not required for:

• Containers of blood, blood components, and blood products bearing an FDA-required label that have been released for transfusion or other clinical uses;
• Individual containers of blood or other potentially infectious materials that are placed in secondary labeled containers during storage, transport, shipment, or disposal;
• Specimen containers, if the facility uses Universal Precautions when handling all specimens, the containers are recognizable as containing specimens, and the containers remain within the facility;
• Laundry bags or containers containing contaminated laundry may be marked with an alternative label or color-coded provided the facility uses Universal Precautions for handling all soiled laundry, and the alternative marking permits all employees to recognize the containers as requiring compliance with Universal Precautions. If contaminated laundry is sent off-site for cleaning to a facility which does not use Universal Precautions in the handling of all soiled laundry, it must be placed in a bag or container which is red in color or labeled with the biohazard label described above; and
• Regulated waste that has been decontaminated.

What type of personal protective equipment (PPE) must be worn to reduce or eliminate exposure to bloodborne pathogens?

The standard requires that PPE be “appropriate.” PPE will be considered “appropriate” only if it does not permit blood or other potentially infectious materials (OPIM) to pass through to, or reach, the skin, employees’ underlying garments, eyes, mouth, or other mucous membranes under normal conditions of use and for the duration of time that the PPE will be used. This allows the employer to select PPE based on the type of exposure and the quantity of blood or OPIM which can be reasonably anticipated to be encountered during performance of a task or procedure.

What type of eye protection is required when working with blood or other potentially infectious materials (OPIM)?

The use of eye protection would be based on the reasonable anticipation of facial exposure. Masks in combination with eye protection devices, such as glasses with solid side shields, goggles, or chin-length face shields, shall be worn whenever splashes, spray, spatter, or droplets of blood or OPIM may be generated and eye, nose, or mouth contamination can be reasonably anticipated.

What must be contained in an employee medical record under the Bloodborne Pathogens Standard?

The medical record includes:

• The name of the employee;
• A copy of the employee’s hepatitis B vaccination status including the dates of all the hepatitis B vaccinations and any medical records relative to the employee’s ability to receive the vaccination;
• Copies of all results of examinations, medical testing, and follow-up procedures;
• Copies of the healthcare professional’s written opinion; and
• Copies of the information provided to the healthcare professional.

What must be included in a bloodborne pathogen training record?

Bloodborne pathogen training records must contain the:

• Dates of the training,
• Contents or a summary of the training sessions,
• Names and job titles of all persons attending the training, and
• Names and qualifications of the persons conducting the training.

What does OSHA mean by the term “regulated waste?”

The Bloodborne Pathogens standard uses the term “regulated waste” to refer to the following categories of waste which require special handling:

1. Liquid or semi-liquid blood or other potentially infectious materials (OPIM),
2. Items contaminated with blood or OPIM and which would release these substances in a liquid or semi-liquid state if compressed,
3. Items that are caked with dried blood or OPIM and are capable of releasing these materials during handling,
4. Contaminated sharps, and
5. Pathological and microbiological wastes containing blood or OPIM.

What type of disinfectant can be used to decontaminate equipment or working surfaces which have come in contact with blood or other potentially infectious materials (OPIM)?

OSHA’s position is that EPA-registered tuberculocidal disinfectants, diluted bleach solutions, and EPA-registered disinfectants that are labeled as effective against both HIV and HBV as well as sterilants/high-level disinfectants cleared by the FDA, meet the requirement in the standard and are “appropriate” disinfectants to clean contaminated surfaces, provided that such surfaces do not become contaminated with agent(s) or volumes of or concentrations of agent(s) for which higher level disinfection is recommended. The particular disinfectant used, as well as the frequency with which it is used, will depend upon the circumstances in which a given housekeeping task occurs (i.e., location within the facility, type of surface to be cleaned, type of soil present, and tasks and procedures being performed). The employer’s written schedule for cleaning and decontamination should identify such specifics on a task-by-task basis.

What alternatives are acceptable if soap and running water are not available for hand washing?

Antiseptic hand cleansers in conjunction with clean cloth/paper towels or antiseptic towelettes are examples of acceptable alternatives to running water. However, when these types of alternatives are used, employees must wash their hands with soap and running water as soon as feasible. These alternatives are only acceptable at work sites where it is infeasible to provide soap and running water.

What type of container should be purchased to dispose of sharps?

Sharps containers are made from a variety of materials from cardboard to plastic. As long as they meet the definition of a sharps container (i.e., containers must be closable, puncture-resistant, leakproof on sides and bottom, and labeled or color-coded), OSHA would consider them to be acceptable.

What recordkeeping does OSHA require for exposure incidents?

Any employer who is required to maintain a log of occupational injuries and illnesses under OSHAs Recordkeeping standard (29 CFR Part 1904) is also required to establish and maintain a sharps injury log for the recording of percutaneous injuries from contaminated sharps.

Employers must also record all work-related needlestick injuries and cuts from sharp objects that are contaminated with another person’s blood or other potentially infectious materials on the OSHA 300 Log. Employers may use the OSHA 300 Log to meet the requirements of the sharps injury log provided they enter the same information required for the sharps injury log on the OSHA 300 Log and maintain the records in a way that segregates sharps injuries from other types of work-related injuries and illnesses, or allows sharps injuries to be easily separated.

Employers must enter sharps injury cases on the OSHA 300 Log and the sharps injury log without entering the employee’s name. If an employee is splashed or exposed to blood or OPIM without being cut or punctured, the incident must be recorded on the OSHA 300 Log if it results in the diagnosis of a bloodborne illness or if it meets one or more of the recording criteria in 1904.7.

If an employer is exempted from the OSHA recordkeeping rule, the employer does not have to maintain a sharps log.

What must be in a bloodborne pathogen spill kit?

A bloodborne pathogen “spill kit” or “clean-up kit” is not required. However, a kit containing certain items may help the employer ensure workers have the proper items necessary for safe and effective cleanup of incidents involving blood or other potentially infectious materials. These items could include (but are not limited to):

• Personal protective equipment (e.g., gloves);
• Appropriate disinfectants (EPA registered tuberculocide or sterilant) or bleach;
• Housekeeping supplies (e.g., absorbent towels, kitty litter); and
• Proper waste containers and labels for regulated waste.

What are the qualifications that a person must possess in order to conduct bloodborne pathogen training?

The person conducting the training is required to be knowledgeable in the subject matter covered by the elements in the training program and be familiar with how the course topics apply to the workplace that the training will address. The trainer must demonstrate expertise in the area of occupational hazards of bloodborne pathogens. Examples of individuals who could conduct training include health care professionals such as control practitioners, nurse practitioners, and registered nurses. Non-healthcare professionals who could conduct training include industrial hygienists, epidemiologists, or professional trainers provided that they can demonstrate evidence of specialized training in the area of bloodborne pathogens.

What testing must be done on the source individual?

The employer must identify and document the source individual, if known, unless the employer can establish that identification is not feasible or is prohibited by state or local law. The source individual’s blood must be tested as soon as feasible, after consent is obtained, in order to determine HIV and HBV infectivity. The information on the source individual’s HIV and HBV testing must be provided to the evaluating healthcare professional.

If consent cannot be obtained and is required by state law, the employer must document in writing that consent cannot be obtained.

Also, the results of the testing must be provided to the exposed employee. The exposed employee must be informed of applicable laws and regulations concerning disclosure of the identity and infectious status of the source individual.

What information must the employer provide to the healthcare professional following an exposure incident?

The healthcare professional must be provided with a copy of the standard as well as the following information:

• A description of the employee’s duties as they relate to the exposure incident;
• Documentation of the route(s) and circumstances of the exposure;
• The results of the source individual’s blood testing, if available; and
• All medical records relevant to the appropriate treatment of the employee, including vaccination status, which are the employer’s responsibility to maintain.

What should be included in the evaluation of an exposure incident?

Following an exposure incident, employers are required to document, at a minimum, the route(s) of exposure and the circumstances under which the exposure incident occurred. To be useful, the documentation must contain sufficient detail about the incident. There should be information about the following:

• The engineering controls in use at the time and work practices followed,
• Description of the device in use,
• The protective equipment or clothing used at the time of the exposure incident,
• Location of the incident and procedures being performed when the incident occurred,
• Employee’s training, and
• The source individual (unless the employer can establish that identification is infeasible or prohibited by state or local law).

The employer should then evaluate the policies and “failures of controls” at the time of the exposure incident to determine actions that could prevent future incidents.

When are labels required under the Bloodborne Pathogens Standard?

A warning label that includes the universal biohazard symbol as specified at 1910.1030(g)(1)(i)(B) followed by the term “biohazard” must be included on:

• Bags/containers of contaminated laundry;
• Bags/containers of regulated waste;
• Refrigerators and freezers that are used to store blood or OPIM; and
• Bags/containers used to store, dispose of, transport, or ship blood or other potentially infectious materials (e.g., specimen containers).

In addition, contaminated equipment which is to be serviced or shipped must have a readily observable label attached which contains the biohazard symbol and the word “biohazard” along with a statement relating which portions of the equipment are contaminated.

When should gloves be changed?

Disposable gloves shall be replaced as soon as practical after they have become contaminated, or as soon as feasible if they are torn, punctured, or their ability to function as a barrier is compromised. Hands must be washed after the removal of gloves used as personal protective equipment, whether or not the gloves are visibly contaminated.

When must the hepatitis B vaccination be offered to employees?

The hepatitis B vaccination must be made available within 10 working days of initial assignment, after appropriate training has been completed. Thus, arranging for the administration of the first dose of the series must be done at a time which will enable this schedule to be met. Only persons who render first aid only as a collateral duty, responding solely to injuries resulting from workplace incidents, generally at the location where the incident occurred would not have to be offered the pre-exposure hepatitis B vaccination (OSHA would consider this a de minimus violation — a technical violation carrying no penalties).

When is the exposed employee’s blood tested?

After consent is obtained, the exposed employee’s blood is collected and tested as soon as feasible for HIV and HBV serological status. If the employee consents to the follow-up evaluation after an exposure incident, but does not give consent for HIV serological testing, the blood sample must be preserved for 90 days. If, within 90 days of the exposure incident, the employee elects to have the baseline sample tested for HIV, testing must be done as soon as feasible.

Where should sharps containers be located?

Sharps containers must be easily accessible to employees and located as close as feasible to the immediate area where sharps are used or can be reasonably anticipated to be found (e.g., laundries, restrooms).

In areas where there may be difficulty placing sharps containers in the immediate use area, alternatives include using containers that are lockable or are designed to prevent removal of syringes while maintaining easy accessibility for discarding. If a mobile cart is used in these areas, an alternative would be to lock the sharps container onto the cart.

Who is covered by the Bloodborne Pathogens Standard?

If an employer has even one employee who has occupational exposure to blood or other potentially infectious materials (OPIM) the standard at 29 CFR 1910.1030 applies. Occupational exposure is defined as reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or OPIM that may result from the performance of an employee’s duties.

Blood is defined as human blood, human blood components, and products made from human blood. Whereas, OPIM is defined as the following:

• Saliva in dental procedures;
• Semen;
• Vaginal secretions;
• Cerebrospinal, synovial, pleural, pericardial, peritoneal, and amniotic fluids;
• Any body fluids visibly contaminated with blood;
• All body fluids in situations where it is difficult or impossible to differentiate between body fluids;
• Unfixed human tissues or organs (other than intact skin);
• HIV-containing cell or tissue cultures, organ cultures, and HIV- or HBV-containing culture media or other solutions; and
• Blood, organs, or other tissues from experimental animals infected with HIV or HBV.

Who must be offered the hepatitis B vaccination?

The hepatitis B vaccination series must be made available to all employees who have occupational exposure. However, the employer does not have to make the hepatitis B vaccination available to employees who have previously received the vaccination series, who are already immune as their antibody tests reveal, or for whom receiving the vaccine is prohibited for medical reasons.

Who is responsible for providing personal protective equipment (PPE)?

The responsibility for providing, laundering, cleaning, repairing, replacing, and disposing of PPE at no cost to employees rests with the employer. Employers are not obligated under the standard to provide general work clothes to employees, but they are responsible for providing PPE. For example, if laboratory jackets or uniforms are intended to protect the employee’s body or clothing from contamination, they are to be provided at no cost by the employer.

Who keeps the medical records?

The employer is responsible for the establishment and maintenance of medical records. However, these records may be kept off-site at the location of the healthcare provider. The employer must ensure that the medical records are kept confidential and are not reported or disclosed without the express written consent of the worker, except as required by the standard or as may be required by law.

Whose responsibility is it to pay for the hepatitis B vaccine?

The responsibility lies with the employer to make the hepatitis B vaccine and vaccination, including post-exposure evaluation and follow-up, available at no cost to the employee.