The federal Occupational Health and Safety Administration’s (OSHA) laws protect the health and safety of workers. OSHA laws, or “standards,” ensure that employers protect their employees from work-related hazards, including exposure to diseases carried in the blood.
The NC Department of Labor protects North Carolina citizens by enforcing OSHA laws and provides education about creating a safe workplace. Their website explains more about the Bloodborne Pathogens Standard.
Bloodborne Pathogens
Early educators are at risk of exposure to several infectious diseases carried in blood or other body fluids (called other potentially infectious materials). Germs that cause diseases are “bloodborne pathogens”. OSHA developed the Bloodborne Pathogens Standard 29 CFR 1910.1030 to prevent the transmission of human immunodeficiency virus (HIV), Hepatitis B virus, and others (Hepatitis C virus, Ebola, Hantavirus).
Covered Employees
North Carolina child care regulations requires CPR and First Aid training for all staff who:
- provide direct care
- accompany children when off premises
Performing first aid or CPR puts early educators at risk for exposure to blood or other potentially infectious body fluids while at work. Because of the this risk, the Bloodborne Pathogens (BBP) standard, applies to all staff who receive CPR and First Aid training.
Requirements of the Standard:
According to OSHA’s Bloodborne Pathogens Factsheet, the standard requires employers to:
- Establish an Exposure Control Plan which outlines the steps taken to protect employees from exposure to bloodborne pathogens
- Treat all blood and other potentially infectious material as if it is infected with bloodborne pathogens
- Use devices that are engineered for safety, such as puncture proof needle disposal containers
- Implement work practices that reduce the risk of exposure, such as the methods used to clean up blood or handle used needles
- Provide and ensure the use of Personal Protective Equipment (PPE), such as gloves, and eye protection for cleaning up blood spills
- Make Hepatitis B vaccinations available to all employees at risk of exposure (i.e. all staff who are responsible for direct care or accompany children when they are off premises)
- Offer medical evaluation and follow-up after any blood exposure at no cost to the worker
- Use labels and signs to communicate hazards
- Provide information and training to workers
- Maintain worker medical and training records.
Written Exposure Control Plan
The Bloodborne Pathogen Standard requires child care facilities to protect employees by following a written Exposure Control plan. The plan includes:
- which employees may be at risk
- how the program will reduce this risk, and
- what the program will do if a situation occurs that puts an employee at risk.
Download a sample Exposure Control Plan from the NC Department of Labor.
The Exposure Control Plan must be reviewed, and updated if necessary, yearly.
Hepatitis B vaccination protection
Employers must offer employees education about the Hepatitis B vaccine, including
- how well the vaccine works,
- safety information,
- how it is administrated and
- the benefits of vaccination.
They must offer the hepatitis B vaccine at no cost to the employee. It must be offered within 10 days of starting employment. If the employee declines the vaccination, they must sign a standardized declination form.
If providing first aid and CPR is not the primary job responsibility for an employee, employers are allowed – if their plan for doing so is detailed in their ECP – to offer the Hepatitis B vaccine after any incident involving blood exposure rather at the beginning of employment.
More information is available on the OSHA Fact Sheet – Hepatitis B Vaccination Protection.
Required Training
The OSHA standard requires that employees receive training on bloodborne pathogens[10] when they begin work and annually thereafter. This training should cover:
- how HIV, hepatitis B, and other bloodborne diseases are spread
- how to use standard precautions[11]
- an orientation to the program’s Exposure Control plan
- reporting procedures and any other program policies
For more information and assistance:
- Read the Guide to bloodborne pathogens in the workplace from the NC Department of Labor.
- Contact the NC Department of Labor at for assistance regarding any workplace safety and health requirements in North Carolina.
- Contact your Child Care Health Consultant or the NC Health and Safety Resource Center.
The Occupational Safety and Health Administration (OSHA) requires that workplaces across numerous industries ensure employee safety and prevent incidents that could cause harm to workers. The Bloodborne Pathogens (BBP) Standard is an OSHA requirement for healthcare organizations because it deals with preventing the spread of viruses, bacteria, and other microorganisms that may be present in blood or body fluids and that could cause harm if an employee comes in contact with them. The standard requires organizations to put measures in place that prevent the transmission of these bloodborne pathogen. Transmission can occur when workers are stuck or cut with a contaminated sharp object, such as a needle or scalpel, or have an open wound that comes into contact with bio-contaminated material. OSHA’s BBP standard applies to any workplace setting where employees are regularly exposed to blood or other potentially infectious material as part of their jobs, including hospitals, clinics, doctors’ offices, and other healthcare settings.
Proper training is a key component of regulatory compliance. Organizations must provide bloodborne pathogens training to any employee who is determined to be at risk for exposure. This may include nurses, nursing assistants, physicians, housekeeping staff, and other clinical and operational employees. Training should be part of orientation and take place at least annually as a refresher. In addition, employees should receive supplemental training if and when they assume new or modified roles that increase their exposure risk.
Training should cover a range of topics, including:
- The epidemiology and symptoms of bloodborne diseases
- How BBPs may be transmitted
- The steps workers can take to protect themselves from exposure
- The safety measures in place to prevent exposure, such as personal protective equipment, proactive vaccination, and sharps disposal solutions
- How to report an exposure incident
- What steps to take in the event someone is exposed
Online training modules can be especially helpful in meeting the standard’s training requirements because staff can access the content at their convenience, and modules can be regularly updated to ensure they remain current with the latest guidance. Stericycle offers a comprehensive, online BBP training module that is easy to access and use. Presented by a disease control and prevention expert, each session guides staff through the standard and helps them understand their role in preserving safety and maintaining compliance. Sessions are available in English and Spanish—and staff can complete the training in less than an hour.
In addition to BBP training, organizations must create and maintain an Exposure Control Plan that details how they prevent staff exposure to bloodborne pathogens, as well as what happens if an incident occurs. This plan is one of the first things an OSHA inspector will ask for during an inspection, so it is essential to keep the plan accessible and up to date. Healthcare organizations must review their plans annually and document when reviews take place. As part of the review process, organizations are required to consider whether there are safer medical devices that could prevent worker exposure and whether requiring the use of those devices is warranted. This process should also be documented.
Other strategies to ensure BBP standard compliance involve creating a vaccination program for hepatitis B and other dangerous pathogens, ensuring proper labeling of hazardous materials, and using effective waste management solutions that ensure safe and secure sharps disposal to minimize staff injury.
Meeting the requirements of OSHA’s Bloodborne Pathogens standard requires a focused effort. Here are the 5 most frequently asked questions:
What Is Bloodborne Pathogens Training?
Bloodborne pathogens training is education provided to healthcare workers about dangerous viruses, bacteria, or other microorganisms that could cause serious illness if exposure occurs. An employer must provide this training to any employee who is determined to be at risk for bloodborne pathogen exposure. Depending on the organization, this may include nurses, physicians, housekeeping staff, and other clinical and operational employees.
What Information Is Included in Training about Bloodborne Pathogens?
The information included in training about bloodborne pathogens covers a range of topics, such as the standard’s requirements, the risks of pathogen exposure, how to prevent exposure, how to recognize if someone has come in contact with bloodborne pathogens, and what to do in the event this occurs.
How Often Is Bloodborne Pathogens Training Required?
Bloodborne pathogens training is required during orientation and at least annually as a refresher. In addition, employees should receive supplemental training if and when they assume new or modified roles that increase their exposure risk.
What Is an Exposure Control Plan?
An exposure control plan is a written document that details how an organization prevents exposure to bloodborne pathogens and what’s involved in responding to an exposure incident should one occur. The document should describe training programs, proactive vaccination efforts, engineering controls that reduce risk, and so on.
How Often is an Exposure Control Plan Reviewed?
Healthcare organizations must review their exposure control plans annually and document when reviews take place. As part of the process, organizations must consider whether there are safer medical devices that could prevent worker exposure and whether requiring the use of those devices is warranted. This process should also be documented.
Learn more about how Stericycle can help you deliver comprehensive bloodborne pathogens training and develop detailed policies that safeguard staff.