Bloodborne Pathogens OSHA Guide and Best Practices

By Kathleen Clair, CSP, MS, SMS

This post provides a high-level overview of what are bloodborne pathogens are, who can be exposed, what is required by OSHA, and general safety best practices. Always review applicable information from reputable sources prior to implementing any changes in your company’s safety program.

What are Bloodborne Pathogens?

You may have heard the term “bloodborne pathogens” (BBP) before but maybe you weren’t sure exactly what they are. Bloodborne pathogens are infectious microorganisms present in blood and other potentially infectious materials (OPIM) that can cause disease in humans.

The most common bloodborne pathogens are hepatitis B virus (HBV), hepatitis C virus (HCV), and human immunodeficiency virus (HIV), the virus that causes AIDS.

What are Some of the Common Bloodborne Pathogens?

While HIV, HBV, and HCV are the most commonly known bloodborne pathogens, there are over 20 other pathogens that can be transmitted through the blood and OPIM. Some of the other common and not so common BBPs include:

• Syphilis
• Malaria
• Babesiosis
• Brucellosis
• Leptospirosis
• Arboviral infections (especially Colorado tick fever)
• Relapsing fever
• Creutzfeldt-Jakob disease
• Human T-lymphotropic virus type I
• Viral hemorrhagic fever

Is COVID-19 (SARS-CoV-2) a Bloodborne Pathogen?

Since the SARS-CoV-2 virus can be detected in the blood (via serum blood testing), there is some confusion about whether that means it can be transmitted via blood as a bloodborne pathogen. According to the National Institute of Environmental Health Sciences (NIEHS), it is not considered a BBP because COVID-19 is not a “bloodborne” virus per se, but that it can replicate in blood cells and affect the blood and its organelles’ (red and white blood cells, hemoglobin) ability to work effectively.

However, one similarity between BBPs and SARS-CoV-2 is that they can both be transmitted via mucus membrane exposures to the eyes, nose, and/or mouth. Accordingly, the precautions workers take, and the protective measures employers use for COVID-19 are the same as for BBPs.

What Body Fluids Contain BBP?

Some body fluids can contain BBPs that infect humans and can spread from person to person. They include:

• Blood
• Blood serum
• Vaginal secretions
• Semen
• Cerebrospinal fluid (A clear fluid that is found in the brain and spine.)
• Pleural fluid (Fluid that is found between the layers of membranes that surround the lungs.)
• Peritoneal, and other joint capsule or organ fluids
• Amniotic fluid
• Synovial fluid (Fluid found in the cavities of synovial joints.)

Who is at Risk for Exposure?

People who work in hospitals, clinical labs, housekeeping, first responders and any other work settings where they may come in contact with bodily fluids are at risk of BBPs. Workers who are exposed to bloodborne pathogens can be at risk for serious or life-threatening illnesses like HBV, HCV, and HIV.

What is the Risk of Exposure?

Contact with bloodborne pathogens can result in the contraction of infectious diseases such as human HIV, HBV, HCV, and many others. The following information describes each of the 3 most common BBPs, how they are spread and how to prevent exposure.

HIV

HIV weakens a person’s immune system by destroying important cells that fight disease and infection. There is currently no effective cure for HIV. But with proper medical care, HIV can be controlled. Some people in the US are more likely to get HIV than others because of their lifestyles.

Some people have flu-like symptoms within 2 to 4 weeks after infection (called acute HIV infection). These symptoms may last for a few days or several weeks.

Possible symptoms include:

• Fever                                                    Chills
• Rash                                                     Night sweats
• Muscle aches                                      Sore throat
• Fatigue                                                 Swollen lymph nodes
• Mouth ulcers

HBV

Hepatitis B is a liver infection caused by the hepatitis B virus (HBV). HBV is spread when blood, semen, or other body fluids from a person infected with the virus enters the body of someone who is not infected. This can happen through sexual contact; sharing needles, syringes, or other drug-injection equipment; or from mother to baby at birth.

Not all people newly infected with HBV have symptoms, but for those that do, symptoms can include fatigue, poor appetite, stomach pain, nausea, and jaundice. For some people, HBV is a short-term illness. For others, it can become a long-term, chronic infection that can lead to serious, even life-threatening health issues like cirrhosis or liver cancer.

The risk of chronic infection is related to a person’s age at infection: about 90% of infants with hepatitis B go on to develop chronic infection, while only 2%–6% of people who get hepatitis B as adults become chronically infected.

The best way to prevent hepatitis B is to get vaccinated.

HCV

Hepatitis C is a liver infection caused by the hepatitis C virus (HCV). HCV is spread through contact with blood from an infected person. Most people become infected with HCV by sharing needles or other equipment used to inject drugs.

For some people, HCV is a short-term illness, but for more than half who become infected with HCV, it becomes a long-term, chronic infection. Chronic HCV can result in serious, even life-threatening health problems like cirrhosis and liver cancer. People with chronic HCV can often have no symptoms and don’t feel sick. Symptoms appear as advanced liver disease.

There is no vaccine for HCV. The best way to prevent HCV is to avoid behaviors that can spread the disease, especially injecting drugs. Getting tested for HCV is important because treatments can cure most people with HCV in 8 to 12 weeks.

OSHA’s Bloodborne Pathogens Standard and Requirements

OSHA, also known as the Occupational Safety and Health Administration, first published its bloodborne pathogens standard in 1991. The standard’s requirements state what employers must do to protect workers who are or could be occupationally exposed to blood or OPIM, In other words, the standard protects workers who can reasonably be anticipated to come into contact with blood or OPIM as a result of doing their job duties.

The standard details a description of workers who are covered by the standard. It also includes definitions of words used in the standard that describe what’s required of employers.

Employer Requirements 

The OSHA BBP standard requires employers to do the following:

Create a written “Exposure Control Plan”.

This is a written plan designed to eliminate or minimize occupational exposures. The employer must prepare an exposure determination that contains a list of job classifications in which all workers have occupational exposure as well as a list of job classifications in which some workers have occupational exposure, along with a list of the tasks and procedures performed by those workers that could result in their exposure.

The plan must be reviewed and updated each year.

Enforce the use of universal (standard) precautions.

This means treating all human blood and OPIM as if it is known to be infectious for BBPs.

Ensure the use of engineering precautions, including the operation of effective, safe medical equipment like sharps disposal bins, self-sheathing needles, and needleless operations.

These are devices that isolate or remove the bloodborne pathogens hazard from the workplace.

Ensure that work practices are performed to minimize exposure, like proper practices for handling and discarding contaminated laundry and sanitizing infectious surfaces.

These are practices that reduce the possibility of exposure by changing the way a task is performed, like using appropriate practices for handling and disposing of contaminated sharps, handling of specimens, handling laundry, and cleaning contaminated surfaces and items.

Provide warning labels and/or red biohazard bags.

OSHA requires that warning labels be affixed to containers of regulated waste; containers of contaminated reusable sharps; refrigerators and freezers containing blood or OPIM; other containers used to store, transport, or ship blood or OPIM; contaminated equipment that is being shipped or serviced; and bags or containers of contaminated laundry, except as provided in the standard.

Facilities may use red bags or red containers instead of labels. In HIV and HBV research laboratories and production facilities, signs must be posted at all access doors when OPIM or infected animals are present in the work area or containment module.

Provide personal protective equipment (PPE) like eye protection, gloves, gowns, and masks.

These items should be provided at no cost to workers.

Provide free hepatitis B vaccinations to workers.

The vaccination must be offered after the worker has received the required bloodborne pathogens training and within 10 days of initial assignment to a job with occupational exposure.

Provide post-exposure examinations per the CDC guidelines after any occupational exposure accident or incident for employees.

According to OSHA, an exposure incident is a specific eye, mouth, other mucous membranes, non-intact skin, or parenteral contact with blood or OPIM. This evaluation and follow-up must be at no cost to the worker and includes documenting the route(s) of exposure and the circumstances under which the exposure incident occurred.

The evaluation also includes:

• Identifying and testing the source individual for HBV and HIV infectivity, if the source individual consents or the law does not require consent;
• collecting and testing the exposed worker’s blood, if the worker consents;
• offering post-exposure prophylaxis (treatment);
• offering counseling; and
• evaluating reported illnesses.

The healthcare professional will provide a limited written opinion to the employer and all diagnoses must remain confidential.

Train employees on the hazards of bloodborne pathogens and the use of signage and labels.

Training should be performed at the time of hire, if BBPs become a hazard for an employee when it previously was not, and annually thereafter.

Document all injuries and maintain medical records for injured employees.

Employers must keep certain records for employees exposed to bloodborne pathogens, including specific medical records, injury and illness records, and a sharps injury log. More details on recordkeeping are provided further down in this post.

Preventing Exposure to BBPs

All employers are required to take concrete action to protect employees from exposure to BBPs. OSHA states that all actual or possibly contaminated equipment should be disinfected. that there should be a bloodborne pathogen exposure control plan in place.

Some ways that companies can prevent exposure include:

• Communicate hazards to employees.
• Use good hygiene practices.
• Clean work surfaces with germicidal products.
• Post warning labels.
• Ensure safe handling and disposal of sharp objects.
• Provide Hepatitis B vaccinations.
• Provide post-exposure follow-up.
• Ensure use of personal protective equipment (PPE).
• Use safe work practices to minimize or completely eliminate possible exposure to blood and OPIM. For healthcare workers in particular, it is important to remember that sharps safety is necessary to protect themselves from bloodborne illnesses.

HBV Vaccine

The HBV vaccine can prevent hepatitis B and its consequences, like liver cancer and cirrhosis. The Hepatitis B vaccine is made from parts of the hepatitis B virus. It does not cause hepatitis B infection. The vaccine is usually given as 2, 3, or 4 shots over 1 to 6 months.

According to the World Health Organization (WHO), the vaccine offers 98% to 100% protection against hepatitis B.

Preventing Needlesticks

The National Institute of Occupational Safety and Health (NIOSH) recommends that health care facilities use safer medical devices to protect workers from needlestick and other sharps injuries. NIOSH passed the Needlestick Safety and Prevention Act in 2000. The Act, along with a revision of the OSHA Bloodborne Pathogen Standard, all health care facilities are required to use safer medical devices.

• NIOSH encourages healthcare facilities to use safer medical devices through:
• Form a sharps injury prevention team
• Identify priorities
• Identify and screen safer medical devices
• Evaluate safer medical device(s)
• Implement and monitor the use of the new safer medical device

Post-Exposure

There are steps to take in the event of exposure to reduce the risk for disease and illness. Also, a post-medical evaluation is vital in the event of exposure. These evaluations can help to prevent or mitigate severe illness when exposure does occur.

In the event of an exposure, the person exposed should:

• Wash needlesticks and cuts with soap and water.
• Flush exposures to the nose, mouth, or skin with water.
• Irrigate eyes with clean water, saline, or sterile wash.
• Report all exposures promptly to ensure that you receive appropriate follow-up care.

In the event of an exposure, the employer should:

• Document the route of exposure and other circumstances.
• Identify the source individual where feasible.
• Offer post-exposure medical evaluation by a healthcare professional at no cost to employees.
• Test the source individual’s blood for BBPs where possible, and test the exposed employee’s blood after consent is obtained.
• Ensure the provision of post-exposure medication when medically indicated and as recommended by the Department of Health & Human Services.
• After exposure to HBV, appropriate and timely prophylaxis can prevent HBV infection and later development of chronic infection or liver disease.

Bloodborne Pathogens Training Requirements

Employers must make sure that workers receive regular training that covers all elements of the standard including:

• Information on bloodborne pathogens and diseases
• Methods used to control occupational exposure
• The hepatitis B vaccine,
• The medical evaluation and post-exposure follow-up procedures
• What to do and whom to contact after an exposure.
• An opportunity for interactive questions and answers.

When is Training for Employees Required?

Employers must offer this training when workers join the company, and then at least annually, and when new or modified tasks or procedures affect a worker’s occupational exposure. Lab and production workers must receive specialized initial training, in addition to the training provided to all workers with occupational exposure. Workers should have the opportunity to ask the trainer questions. And the training must be presented at a level and in a language that workers understand.

Who Can Provide Training?

OSHA’s BBP Standard does not specify a particular job classification for qualified trainers. But it does require that the trainer be “knowledgeable in the subject matter covered by the elements contained in the training program”.

According to OSHA, trainers may include a variety of healthcare professionals such as infection control practitioners, nurse practitioners, registered nurses, occupational health professionals, physician’s assistants, and emergency medical technicians, industrial hygienists, epidemiologists, or professional trainers as long as they are knowledgeable in the subject matter covered by the elements contained in the training program as it relates to the workplace.

Recordkeeping Requirements

OSHA requires employers with more than 10 employees to maintain Occupational Injury and Illness Recording and Reporting forms. Additionally, employers must keep certain records for employees exposed to bloodborne pathogens, including specific medical records, injury and illness records, and a sharps injury log.

• Medical records – Confidential employee medical records for workers who have exposure to BBPs must be maintained for the duration of employment plus 30 years.
• Injury and illness records – If work-related needlestick injuries and cuts from sharp objects that are contaminated with another person’s blood or other potentially infectious material occur, employers must record these events. Instructions are available on the OSHA website on recordkeeping.
• Sharps injury log – The sharps injury log is used to record all needlestick injuries. The sharps injury log is intended to be used as a tool for identifying high-risk areas and providing information that may be helpful in evaluating safer devices. It should be reviewed regularly during the review and update of the Exposure Control Plan.

Summary

In summary, all companies should identify and implement an exposure control plan for bloodborne pathogen exposure control. The plan should be communicated to employees who are expected to have contact with blood or bodily fluids.

There should be guidelines for safe work practices for everyone who comes into contact or may come into contact with BBPs. Companies that take preventive action can help reduce the risk of their employees’ exposure to infectious diseases.

Sources: OSHA, CDC, NIEHS, NIOSH, WHO