Bloodborne Pathogens (BBP)

Bloodborne pathogens (BBP) are disease-causing microorganisms present in human blood that can infect people who are exposed to it. The best-known examples are hepatitis B virus (HBV), hepatitis C virus (HCV) and human immunodeficiency virus (HIV). OSHA's Bloodborne Pathogens Standard, 29 CFR 1910.1030, sets the rules for protecting workers with occupational exposure.

Exposure can happen through a needlestick, a cut from contaminated glass or sharps, or blood splashing into the eyes, nose, mouth or broken skin. Healthcare is the most obvious setting, but the standard also covers many workers outside hospitals.

What Are Bloodborne Pathogens?

OSHA's Bloodborne Pathogens Standard (29 CFR 1910.1030) defines bloodborne pathogens as "pathogenic microorganisms that are present in human blood and can cause disease in humans," including but not limited to HBV and HIV. HCV is also a major bloodborne pathogen of concern.

The standard applies to all employees with occupational exposure, which OSHA defines as reasonably anticipated skin, eye, mucous membrane or parenteral contact with blood or other potentially infectious materials (OPIM) that may result from the performance of an employee's duties. OPIM includes:

• Certain human body fluids, such as semen, vaginal secretions, cerebrospinal, synovial, pleural, pericardial, peritoneal and amniotic fluid, and saliva in dental procedures
• Any body fluid visibly contaminated with blood, and situations where it is difficult or impossible to tell body fluids apart
• Unfixed human tissues or organs, other than intact skin
• Certain HIV- or HBV-containing cell or tissue cultures and experimental materials

Who Is at Risk?

Coverage depends on job duties, not job title or industry. Workers commonly covered include:

• Nurses, physicians, dental staff, phlebotomists and laboratory workers
• Paramedics, firefighters, police officers and other first responders
• Housekeeping, janitorial and laundry staff who handle contaminated materials
• Employees designated to provide first aid as part of their job duties
• Regulated waste handlers and staff in correctional and residential care facilities

An employee who gives first aid voluntarily as a Good Samaritan, without being assigned that duty, is not considered occupationally exposed under the standard. The employer's exposure determination, described below, decides who is covered. OSHA's bloodborne pathogens topic page provides additional guidance, fact sheets and standard interpretations for specific industries and situations.

Key Requirements of the OSHA Bloodborne Pathogens (BBP) Standard

Exposure control plan

Employers with occupationally exposed employees must have a written exposure control plan. It must include an exposure determination listing the job classifications and tasks with exposure, the schedule and method for implementing the standard's requirements, and the procedure for evaluating exposure incidents. The plan must be reviewed and updated at least annually and whenever new or modified tasks or procedures affect exposure. The review must also consider safer medical devices, and employers must solicit input from non-managerial employees responsible for direct patient care in selecting engineering and work practice controls.

Engineering and work practice controls

Following the hierarchy of controls, the standard requires engineering controls such as sharps disposal containers, self-sheathing needles and needleless systems, examined and maintained or replaced on a regular schedule. Work practice controls include hand washing after removing gloves, not recapping contaminated needles by two-handed methods, and prohibiting eating and drinking in work areas with exposure risk. The Needlestick Safety and Prevention Act of 2000 led OSHA to strengthen these requirements for safer sharps.

Universal precautions and PPE

Employers must use universal precautions, an approach in which all human blood and certain body fluids are treated as if known to be infectious. Appropriate personal protective equipment, such as gloves, gowns, face shields and masks, must be provided at no cost, in appropriate sizes, and cleaned, repaired or replaced by the employer.

Hepatitis B vaccination

The hepatitis B vaccine series must be made available at no cost within 10 working days of initial assignment to all employees with occupational exposure, unless an exception applies (for example, the employee has already received the series). Employees who decline must sign the declination statement in Appendix A of the standard and can still receive the vaccine later if they change their mind.

Post-exposure evaluation and follow-up

After an exposure incident, the employer must make a confidential medical evaluation and follow-up available immediately. This includes documenting the route of exposure, identifying and testing the source individual where feasible and permitted, testing the exposed employee's blood with consent, and providing post-exposure prophylaxis when medically indicated, along with counseling.

Hazard communication, training and recordkeeping

• Labels: containers of regulated waste and contaminated items must carry the biohazard label or be in red bags or containers.
• Training: required at the time of initial assignment and at least annually thereafter, at no cost and during working hours, with an opportunity to ask questions of a knowledgeable trainer.
• Training records: kept for 3 years from the date of training.
• Medical records: kept confidential for at least the duration of employment plus 30 years.
• Sharps injury log: employers required to keep the OSHA 300 Log must also maintain a sharps injury log for percutaneous injuries from contaminated sharps, protecting employee privacy.

How to Build a Bloodborne Pathogens Program Step by Step

1. Conduct the exposure determination. List every job classification in which all or some employees have occupational exposure, and the tasks involved, without considering PPE.
2. Write the exposure control plan. Document controls, PPE, vaccination, post-exposure procedures, training and recordkeeping. Make it accessible to employees.
3. Select and install controls. Evaluate safer sharps and other engineering controls with input from frontline employees.
4. Offer the hepatitis B vaccine. Track who has completed the series, who is in progress and who has declined.
5. Train exposed employees. Cover the standard, modes of transmission, the plan, controls, PPE, vaccination and what to do after an exposure.
6. Prepare the exposure response. Arrange a healthcare provider in advance and make sure employees know to report exposures immediately.
7. Review the plan annually. Update it for new tasks, new devices and lessons learned from exposure incidents.

Examples of Exposure Incidents

• A nurse receives a needlestick while disposing of a used syringe.
• A custodian is cut by a discarded needle hidden in a trash bag.
• A designated first aid responder gets blood in their eye while treating a coworker's laceration.
• A laboratory technician's specimen tube breaks in a centrifuge, splashing their face.

Each of these should trigger the post-exposure procedure. If the exposure results in a recordable case, such as a needlestick or cut from a contaminated sharp, it also needs to be evaluated for the OSHA 300 Log.

Common Mistakes to Avoid

• Leaving designated first aid providers or maintenance staff out of the exposure determination.
• Letting the annual plan review lapse, or reviewing it without considering newer safer devices.
• Offering the vaccine without collecting signed declinations from employees who refuse it.
• Delaying post-exposure evaluation, when some treatments work best if started quickly.
• Training once and assuming it carries over, rather than retraining every year.

How SMS360 Helps

SMS360's Training Management module helps employers assign bloodborne pathogens training to exposed job roles, track completion and keep training records in one place. Automated reminders flag annual refresher training before it lapses, and dashboards show who is current, due or overdue across sites. Training records can be retrieved quickly when an auditor or OSHA inspector asks for proof that each exposed employee was trained.

Frequently Asked Questions

What are the three main bloodborne pathogens (BBP)?

The three bloodborne pathogens of most concern in the workplace are hepatitis B virus (HBV), hepatitis C virus (HCV) and human immunodeficiency virus (HIV). OSHA's definition in 29 CFR 1910.1030 names HBV and HIV specifically and states that bloodborne pathogens are not limited to these. Other pathogens, such as those causing syphilis or malaria, can also be transmitted through blood.

How often is bloodborne pathogens training required?

OSHA requires bloodborne pathogens training at the time of initial assignment to tasks where occupational exposure may occur and at least annually thereafter. Additional training is needed when changes such as new tasks or procedures affect an employee's exposure. Training must be provided at no cost, during working hours, and must allow trainees to ask questions of someone knowledgeable about the training content.

Who needs bloodborne pathogens training?

Any employee with occupational exposure, meaning they can reasonably be anticipated to contact blood or other potentially infectious materials as part of their job, needs training. This includes healthcare workers, first responders, custodial staff who handle contaminated waste, and employees designated to give first aid. The employer's written exposure determination identifies which job classifications are covered.

Do employers have to pay for the hepatitis B vaccine?

Yes. Under 29 CFR 1910.1030, the hepatitis B vaccine series must be made available at no cost to employees with occupational exposure, within 10 working days of initial assignment. Employees may decline by signing the declination statement in the standard's Appendix A, and they can still request the vaccine at a later date if they remain covered.