The top OSHA citation in healthcare settings is violation of the Bloodborne Pathogens (BBP) standard. These rules are designed to protect employees from exposure to infectious materials—but because healthcare work often moves fast, they can be overlooked. When that happens, the consequences can be life-changing.
Bloodborne pathogens include HIV, Hepatitis B, Hepatitis C, and other microorganisms that can cause serious illness. Exposure often occurs when employees come into contact with blood or other potentially infectious materials (OPIM), especially during patient care, cleaning tasks, and waste handling.
Some of the most common accidents occur when an employee attempts tasks such as recapping needles, disposing of sharps incorrectly, or cleaning spills without proper personal protective equipment (PPE). A single needlestick injury can result in exposure to serious infectious diseases.
OSHA defines a bloodborne pathogens risk as the reasonably anticipated exposure to blood or OPIM as a result of job duties. In simple terms, healthcare employees can get hurt when they perform clinical tasks without appropriate protection, procedures, or equipment in place.
There are limited exceptions—such as when a device is completely non-contaminated and unused—but in nearly all clinical settings, standard precautions must be followed every time, regardless of perceived risk.
Employees fall into two main categories:
Occupationally Exposed Employee
- An employee whose job duties reasonably anticipate contact with blood or OPIM
- Includes nurses, physicians, phlebotomists, EMTs, lab techs, CNAs, and many others
- Must receive full BBP training and protections
Non-Exposed Employee
- An employee who works in the facility but does not have anticipated contact with blood or OPIM
- Still must understand emergency procedures and workplace expectations
Bloodborne pathogens rules apply to all forms of exposure, not just needlesticks. This includes contact with mucous membranes, broken skin, sharps, contaminated equipment, and soiled materials.
OSHA Requires Every Employer to Maintain a Bloodborne Pathogens Program That Includes:
Exposure Control Plan (ECP)
- A written plan that identifies jobs and tasks with potential exposure
- Must detail methods of protection, engineering controls, and work practices
- Must be reviewed and updated annually or whenever tasks change
Employee Training
- Required at initial assignment and at least annually thereafter
- Must cover hazards, protective equipment, engineering controls, vaccinations, and emergency actions
Universal Precautions
- Treat every specimen of blood or OPIM as if infectious
- Applies to every patient and every task
Engineering Controls
Common examples:
- Sharps disposal containers
- Needleless systems
- Self-sheathing needles
- Splash guards
Work Practice Controls
Examples include:
- Safe sharps handling
- Proper hand hygiene
- No recapping of needles
- Correct PPE use
Personal Protective Equipment (PPE)
- Gloves, face shields, gowns, masks, eye protection
- Employer must provide PPE at no cost and ensure availability
Hepatitis B Vaccination
- Must be offered free of charge to all occupationally exposed employees
- Must be offered within 10 days of initial assignment
Post-Exposure Evaluation and Follow-Up
- Immediate medical evaluation after an exposure incident
- Confidential treatment, documentation, and follow-up testing
- Must be provided at no cost to the employee
Recordkeeping
- Training records
- Sharps injury logs
- Exposure incident documentation