Infection control and prevention
Infection control principles and practices for local public health
| Policy issues |
PPE | Respiratory
protection | TB
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
- 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
- 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
- splashes or sprays of blood or OPIM into the eyes, nose,
- contact with blood or OPIM onto an open wound, an oozing
lesion, or other area where there is significant skin
- What employer responsibilities are required by the BBP
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
- determine job classifications and job tasks that have
- write and implement a written exposure control plan that
includes engineering and work
- practice controls and use of PPE to minimize occupational
- 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
- 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
- provide for appropriate management of infectious waste
- use labels and signs to communicate hazards to employees
- make available hepatitis B vaccine and post-vaccination
- provide post-exposure medical evaluation and follow-up
- provide training
- keep medical and training records
- What employee responsibilities are required by the BBP
Employers bear the entire responsibility of complying with the
standard, but the tasks listed below need to be done properly by
- wear appropriate PPE for tasks and procedures in which
occupational exposure may occur
- use and activate safety devices when handling needles and
- dispose of infectious waste properly
- notify their supervisors immediately after they experience an
- 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
- 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.
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)
January 23, 2014