Healthcare-Associated Infections: Reportable Exposures

BBPs are microorganisms that cause disease and are present in human blood. They include, but are not limited to:

• Human immunodeficiency virus (HIV)
• Hepatitis B virus (HBV)
• Hepatitis C virus (HCV)

In addition to blood, the following human body materials are considered to be potentially infectious with HIV, HBV, or HCV:

The Bloodborne Pathogens Standard 29 CFR Part 1910.1030 (opens external link) requires employers to write and implement an exposure control plan for employees with occupational exposure to blood and OPIM, using administrative, engineering, and work practice controls to prevent or minimize employee exposure.

The exposure control plan must contain at least the following elements:

What staff members are required to be in a BBP exposure control plan?

• If it is reasonable to anticipate skin, eye, mucous membrane, or parenteral contact with blood or OPIM 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.
• Medical records (such as hepatitis B vaccination status, exposure incidents, and follow-up), which are kept for the duration of employment plus 30 years.

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.
• Whenever there are new employee positions with occupational exposure.

Who can perform 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 people with knowledge of the subject matter required in the training.

Examples of knowledgeable staff include:

• Nurses.
• Nurse practitioners.
• Infection control professionals.
• Physician assistants.
• Occupational health professionals.
• Emergency medical technicians.

What constitutes an exposure to blood or 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:

• Getting input from employees with occupational exposure on developing effective engineering and work practice controls.
• Determining job classifications and job tasks that have occupational exposure.
• Writing and implementing a written exposure control plan that includes engineering and work.
• Practicing controls and use of personal protective equipment (PPE) to minimize occupational exposure.
• Providing handwashing facilities readily available to employees, and ensuring that employees wash hands immediately or as soon as feasible after removing gloves and after contact with blood and OPIM.
• Providing appropriate PPE, storing it in available locations, and maintaining PPE in good repair.
• Ensuring that employees use PPE appropriately.
• Ensuring that the worksite is clean and in sanitary condition.
• Providing for appropriate management of infectious waste.
• Using labels and signs to communicate hazards to employees.
• Making hepatitis B vaccine and post-vaccination antibody testing available.
• Providing post-exposure medical evaluation and follow-up.
• Providing training.
• Keeping medical and training records.

What employee responsibilities are required by the BBP standard?

Employers bear the entire responsibility of complying with the BBP standard. By properly doing the tasks below, staff can reduce their risk of BBP exposure:

• 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 supervisors immediately after experiencing 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 Best Practice Guidelines for Immunization, 2017 (PDF) (opens external link) 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.

Department of Health Services resources

Bloodborne Pathogens: What Does an IP Need to Know? (opens external video): Listen to the Wisconsin HAI Prevention Program Infection Preventionist Lunch and Learn session on bloodborne pathogens and other exposures. Bloodborne pathogens and other exposures presentation slides (PDF) are also available.

External resources

• Occupational Exposures to HIV and Recommendations for Post-Exposure Prophylaxis (opens external link): Guidelines and recommendations from CDC, updated 2013.
• Model Bloodborne Pathogens Exposure Control Plan (PDF) (opens external link): An OSHA form that can be filled in to create your own plan.