OSHA Bloodborne Pathogens Standard: A Plain-English Guide

Who it applies to

The standard covers every employer with an employee who has occupational exposure: reasonably anticipated contact with blood or other potentially infectious materials while doing their job. In a med spa that usually means injectors, nurses, anyone doing microneedling, PRP or IV therapy, and anyone who handles sharps or cleans contaminated equipment.

"Other potentially infectious materials" includes a list of body fluids, any body fluid visibly contaminated with blood, and all body fluids where you can't tell them apart, plus unfixed human tissue. There is no small-employer exemption.

What you need, at a glance

The exposure control plan

The written plan is the center of the standard. It has to contain the exposure determination, how and when you put each part of the standard in place, and your procedure for looking into an exposure incident. It must be reviewed and updated at least once a year, and whenever tasks or positions change.

Two details trip up small clinics. The annual review has to document that you considered safer medical devices, such as safety needles, and which you adopted. And you have to ask front-line staff who use sharps for their input on those devices, and document it.

Everyday controls OSHA spells out

• Handwashing facilities readily accessible, and hands washed right after removing gloves.
• Contaminated needles not bent, recapped or removed unless no alternative is feasible or a medical procedure requires it, and never sheared or broken.
• No eating, drinking, applying cosmetics or lip balm, or handling contact lenses where exposure is reasonably likely.
• No food or drink in fridges, freezers, shelves or counters where blood or other potentially infectious materials are kept. That includes the fridge your injectables live in.
• Sharps containers that are closable, puncture-resistant, leakproof and labeled, kept upright, replaced routinely and never overfilled.

Bloodborne pathogens training requirements

Training is required when someone is first assigned tasks with exposure, at least every 12 months after that (within one year of their last training), and when tasks change in a way that creates new exposure. It must be free, during working hours, and in language the staff understand. The trainer must know the subject as it applies to your workplace, and there must be a chance for interactive questions and answers with them, so a video alone doesn't meet the standard.

The standard lists what training must cover, including:

• Access to the text of the standard and an explanation of it.
• How bloodborne diseases spread, and their symptoms.
• Your exposure control plan and how to get a copy.
• Which tasks can cause exposure, and how to reduce it: controls, work practices and PPE.
• The hepatitis B vaccine: that it's effective, safe, free, and how it's given.
• What to do and who to contact after an exposure, and the follow-up that's available.
• The signs, labels and color coding used for biohazards.

Records to keep

• Training records for 3 years: dates, a summary of the content, the trainer's name and qualifications, and the names and job titles of attendees.
• A confidential medical record for each exposed employee, including hepatitis B vaccination status and any post-exposure evaluation, kept for the length of employment plus 30 years.
• A sharps injury log, if you're required to keep OSHA injury and illness records.