Infection control and prevention

Infection control principles and practices for local public health agencies

Frequently Asked Questions
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Bloodborne pathogens - exposure control

• What staff members are required to be in a bloodborne pathogens exposure control plan? 
  • If it is reasonable to anticipate skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials during job duties and tasks, the staff member must be included in an exposure control plan. For example, a public health nurse assigned to administer immunizations may have contact with blood or body fluids.
  • Persons who give first aid as a “good Samaritan” act are not covered under the BBP exposure control plan unless they perform these duties as a part of their jobs. However, it is recommended that employers provide the hepatitis B vaccine if needed and other post-exposure follow-up due to liability issues, and to help prevent disease transmission among staff even in non-occupational exposures. 

• How often do we have to train staff?
  • All staff need to have training at the time they are initially assigned duties with occupational exposure, and annually thereafter. Training must be at the educational level and in the language of the employee.

• What records do we need to keep?
  • Training records, which are kept for three years from the date on which the training occurred, and medical records (e.g. hepatitis B vaccination status, exposure incidents and follow-up) which are kept for the duration of employment plus 30 years [29 CFR Part 1910.1030 (h)].

• How often does the BBP exposure control plan need to be reviewed and updated?
  • The plan must be reviewed annually and whenever new or modified tasks or procedures affect occupational exposure or there are new employee positions with occupational exposure.

• Who can perform the training?
  • There are no official requirements for persons doing training for BBP exposure control programs, but it is in the best interest of the employer to choose persons with knowledge in the subject matter that is required in the training. Examples of knowledgeable staff include nurses, nurse practitioners, infection control professionals, physician assistants, occupational health professionals, and emergency medical technicians.

• What constitutes an exposure to blood or other potentially infectious material (OPIM)? 
  Any of the following is an exposure and should be given immediate medical attention:
  • a puncture of the skin with a used needle, lancet, or other sharp item, whether or not there is visible blood or OPIM present 
  • splashes or sprays of blood or OPIM into the eyes, nose, or mouth 
  • contact with blood or OPIM onto an open wound, an oozing lesion, or other area where there is significant skin breakdown

• What employer responsibilities are required by the BBP standard? 
  Employers are required to implement the entire standard which includes but is not limited to: 
  • get input from employees with occupational exposure on developing effective engineering and work practice controls 
  • determine job classifications and job tasks that have occupational exposure 
  • write and implement a written exposure control plan that includes engineering and work 
  • practice controls and use of PPE to minimize occupational exposure 
  • provide hand washing facilities readily available to employees ensure that employees wash hands immediately or as soon as feasible after removing gloves and after contact with blood and OPIM 
  • provide appropriate PPE, store in available locations, and maintain PPE in good repair 
  • ensure that employees use PPE appropriately 
  • ensure that the worksite is clean and in sanitary condition 
  • provide for appropriate management of infectious waste 
  • use labels and signs to communicate hazards to employees 
  • make available hepatitis B vaccine and post-vaccination antibody testing 
  • provide post-exposure medical evaluation and follow-up 
  • provide training 
  • keep medical and training records 

• What employee responsibilities are required by the BBP standard? 
  Employers bear the entire responsibility of complying with the standard, but the tasks listed below need to be done properly by staff:
  • wear appropriate PPE for tasks and procedures in which occupational exposure may occur 
  • use and activate safety devices when handling needles and lancets 
  • dispose of infectious waste properly 
  • notify their supervisors immediately after they experience an exposure 
  •  complete the required initial and annual training 
  • comply with all other aspects of the BBP exposure control plan 

• Do I need to wear gloves while administering immunizations?
  • The decision to wear PPE is based on the worker’s assessment of whether there is “reasonable anticipation” of an exposure to blood or OPIM. If exposure does not usually occur when giving immunizations, gloves are not necessary but workers may choose to wear gloves if they wish. 
  • Gloves should always be available in case of emergency situations that result in contact with blood or OPIM. 
  • The General Recommendations on Immunization, December 1, 2006 MMWR Vol 55/No RR-15  (Exit DHS) recommend washing hands with soap and water or waterless alcohol gel between each client in the immunization setting. 
  • If gloves are worn, they should be removed after each client, and hand hygiene should be performed. 

• How should gloves that were used in immunization clinics be discarded?
  • Gloves and other PPE may be placed in regular plastic bags for disposal. If they are saturated or dripping with blood or OPIM, they should be placed in a red biohazard bag.

Contacts

Gwen Borlaug, Infection Control Epidemiologist
Wisconsin Division of Public Health 
Bureau of Communicable Diseases and Emergency Response
(Phone 608-267-7711)  (Fax 608-261-4976)

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Last Revised: June 18, 2012