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OSHA Bloodborne Pathogen Standard

What are Bloodborne Pathogens?

Bloodborne pathogens (BBP) are infectious microorganisms in human blood that can cause life-threatening diseases and pose severe risks to humans. These pathogens include but are not limited to, hepatitis B (HBV), hepatitis C (HCV), and human immunodeficiency virus (HIV).

What is required?

OSHA regulations require employers to ensure that their workers receive regular training that covers all elements of the standard, including, but not limited to:

  • Information on bloodborne pathogens and diseases  
  • Methods used to control occupational exposure 
  • Hepatitis B vaccine 
  • Medical evaluation and post-exposure follow-up procedures  

This mandatory bloodborne pathogen training aims to teach employers and employees how to reduce the risk of exposure to bloodborne pathogens and control those risks if they occur. 

How long does training last?

Employers who have workers exposed to blood or other potentially infectious materials (OPIM) are required by OSHA's bloodborne pathogens regulations to annually train all workers, regardless of their past education or training.

The bloodborne pathogens standard requires initial and annual training of employees and when new or modified tasks or procedures affect a worker’s occupational exposure. [29 CFR 1910.1030(g)(2)(ii)]. Refresher training only needs to cover the topics listed in the standard to the extent required and does not need to be an exact repetition of the previous annual training. 

How does the IBC help labs remain compliant with the BBP standards?

The IBC oversees any research or teaching activities that use human blood, or other potentially infectious material (OPIM). These include human blood, human serum, semen, vaginal secretions, human cell lines, or other bodily fluids defined by OSHA as being potentially contaminated (amniotic, cerebrospinal, pleural, pericardial, synovial).

IBC oversight is meant to ensure that the following four methods of compliance are implemented:

  1. Exposure Control Plan (ECP): Develop and maintain a written plan detailing how the workplace will achieve compliance. This plan should be regularly reviewed and updated, especially when new procedures or tasks that affect occupational exposure are introduced. 
  2. Universal Precautions: Treat all human blood and certain human body fluids as if they were known to be infectious for HIV, HBV, and other bloodborne pathogens. It's a preventive measure to minimize risk. 
  3. Personal Protective Equipment (PPE): Provide, at no cost to the workers, appropriate PPE such as gloves, gowns, face shields, masks, and eye protection. Ensure that they are readily accessible, and that staff are trained in their use and disposal. 
  4. Training and Education: Conduct regular training for all employees who may encounter blood or other potentially infectious materials. The training should be comprehensive, covering the basics of bloodborne pathogens, methods of transmission, prevention measures, and the specifics of the company's ECP. 

The IBC may also recommend other methods for compliance such as vaccination programs (like offering Hepatitis B vaccinations), post-exposure procedures, and proper waste disposal procedures.

How does BYU IBC manage BBP oversight?

The Institutional Biosafety Committee (IBC) provides oversight of research involving human blood and other potentially infectious materials (OPIM) in accordance with the NIH Guidelines for Research Involving Recombinant or Synthetic Nucleic Acid Molecules, as applicable, and the OSHA Bloodborne Pathogens Standard (29 CFR 1910.1030). Oversight is conducted using a risk-based approach consistent with NIH expectations for institutional biosafety programs.

Investigators conducting research or teaching activities involving human blood or OPIM are required to complete a standardized registration form (see below). This form captures essential information needed for biosafety review, including:

  • A description of the proposed work 
  • The nature and source of human-derived materials (e.g., blood, serum, established or primary human cell lines, or other OPIM as defined by OSHA) 
  • The location and duration of the work 
  • Containment practices, including use of primary containment devices (e.g., biosafety cabinets) 
  • Submission of a laboratory-specific Exposure Control Plan (ECP), as required under the OSHA Bloodborne Pathogens Standard 

Upon submission, the Biosafety Officer (BSO) conducts an initial review to assess risks associated with the work and to determine appropriate containment in accordance with Biosafety in Microbiological and Biomedical Laboratories (BMBL) guidance. The review evaluates:

  • Appropriate biosafety level (typically BSL-2 for work involving human materials) 
  • Use of containment equipment and facility practices 
  • Personal protective equipment (PPE) and work practices 
  • Training and compliance with bloodborne pathogen requirements 
  • Adequacy of the Exposure Control Plan based on the specific procedures performed 

Consistent with NIH Guidelines provisions allowing delegated review, the BSO is authorized to approve research activities that are routine, well-characterized, and conducted at appropriate containment levels without requiring full committee review. Research that involves additional risk factors (e.g., recombinant or synthetic nucleic acids, RG2 or higher agents, or novel procedures) is referred to the full IBC for review and approval.

Example of Bloodborne Pathogen form. This form needs to be filled out and submitted in OneAegis.

OSHA Blood Form