Bloodborne Pathogen Exposure Plan

It is important to remember that an employee expected to render first aid as part of his or her job duties must comply with the OSHA provision "Occupational Exposure to Bloodborne Pathogens" (29 CFR 1910.1030), which states that each employer having employees that may be potentially exposed to blood or other bodily fluids must establish a written Exposure Control Plan designed to eliminate or minimize employee exposure.

The Exposure Control Plan must contain the following elements:

• A list of all job classifications in which all employees in those job classifications have occupational exposure
• A list of job classifications in which some employees have occupational exposure
• A list of all tasks and procedures or groups of closely related task and procedures in which occupational exposure to employees occurs (this exposure determination must be made without considering the use of personal protective equipment, or PPE).
• Engineering and work practice controls used to eliminate or minimize employee exposure

Personal protective equipment (PPE) must be used in instances where occupational exposure to bodily fluids remains after instituting the exposure plan. When there is occupational exposure, OSHA requires an employer to provide appropriate personal protective equipment such as (but not limited to) gloves, gowns, laboratory coats, face shields or masks and eye protection, and mouthpieces, resuscitation bags, pocket masks, or other ventilation devices at no cost to the employee. Personal protective equipment will be considered "appropriate" only if it does not allow blood or other potentially infectious materials to pass through or reach the employee's work clothes, street clothes, undergarments, skin, eyes, mouth, or other mucous membranes under normal conditions of use and for the duration of time which the protective equipment will be used.

OSHA encourages "universal precaution" be observed to prevent contact with blood or other potentially infectious materials. In situations where the differentiation between body fluid types is difficult or impossible, all bodily fluids must be considered potentially infectious.

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