OSHA’s Bloodborne Pathogen Standard, 29 CFR 1910.1030, applies to all occupational exposure to human blood or other potentially infectious material as defined in the standard.  When implementing a bloodborne pathogen program, the standard needs to be reviewed in detail to ensure full compliance is achieved.  Pay particular attention to the stipulated training requirements.

First and foremost, an exposure determination needs to be conducted to determine the job classifications, and tasks and procedures that fall under the standard.  This exposure determination needs to be documented, even if the evaluation shows that the bloodborne pathogen standard is not applicable to job tasks and procedures at your facility.   Among other requirements, an Exposure Control Plan needs to be written and implemented to eliminate or minimize employee exposure to bloodborne pathogens.  An evaluation of the required PPE, proper work practices, safer sharps options, and waste disposal practices should be conducted.  Be sure to comply with all of the timelines stipulated for employee training, offering a hepatitis B vaccination, and post-exposure evaluation.

The Bloodborne Pathogen Standard stipulates that training must be conducted at the time of initial assignment to tasks where occupational exposure may take place, and annual training must be provided within one year of the previous training.  Double check the refresher training deadlines for your affected employees, and be sure to hold refresher sessions before the one year mark!