Are you in compliance with the
Bloodborne Pathogens Standard?
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When you have a bloodborne pathogen exposure incident, it is not required that you document the circumstances surrounding the incident, including the engineering controls and work practices used. *

This is false. When documenting a bloodborne pathogen exposure incident, do not forget to document the circumstances surrounding the incident. This is not only required by OSHA’s Bloodborne Pathogens Standard, it helps to determine if policy was being followed and what might need to be changed.

Employers must establish and maintain an accurate record for each employee with occupational exposure and maintain this record for three years. *

This is false. The employer shall maintain employee medical records for at least the duration of employment plus 30 years.

Bloodborne Pathogens training for employees shall occur during working hours, at no charge to the employee, and at an educational level and language the employees will understand. *

This is true. The Bloodborne Pathogens Standard training must be performed during employee work hours. Training must be provided in a format that is understood by employees. For example, if there is a concern that an employee may not be able to read English proficiently, test questions would need to be written in their native language.

In addition to maintaining employee safety training sign-in sheets, tests, and certificates of completion, always keep a copy of the training content (training outline or a copy of the slides). *

This is true. Keeping a copy of the training content proves what training was actually provided. The employer is also required by the Bloodborne Pathogens Standard to keep a copy of all trainer credentials/qualifications.

Training on the Bloodborne Pathogens Standard is required after a new employee begins any exposure potential tasks and one year from that employee’s training. *

This is false. Initial training on the Bloodborne Pathogens Standard is required before a new employee begins any exposure potential tasks and then one year from that employee’s initial training. If employees are trained annually as a group, be sure no employee goes over a year since his/her last training.

Facility management, not employees, is responsible for the evaluation and selection of sharps safety devices, such as safety syringes to be used at the facility. *

This is false. Non-managerial employees with direct patient care MUST be a part of the process for the selection of safety devices used at the facility initially and during annual update of the Exposure Control Plan. This obligation can be met by listing the employees involved and describing the process by which input was requested; or presenting other documentation, including references to the minutes of meetings, copies of documents used to request employee participation, or records of responses received from employees.

Maintain all bloodborne pathogen training documents for at least three years from the date of training. *

This is true.  Bloodborne pathogens initial, updated, and annual employee training sign-in sheets that include the employee name, signature, job title, and date of training, as well as trainer qualifications and a description of the training content must be maintained for three years in hardcopy or electronic format. It must be made available, upon request, to OSHA.

Your Bloodborne Pathogens Exposure Control Plan only needs to be updated if changes to employee exposure tasks have occurred over the last year. *

This is false. Your Bloodborne Pathogens Exposure Control Plan must be reviewed annually, and updated if indicated, to reflect changes in tasks, procedures, and positions as well as the technological changes that eliminate or reduce occupational exposure such as safety syringes. However, even if there are no changes, you must review the plan and document that you have done so.

The hepatitis B vaccine must be made available at no charge to all employees with occupational exposure risk within 10 days of beginning exposure risk tasks. *

This is true. Employees must be offered the hepatitis B series within 10 days of starting bloodborne pathogen tasks. “No charge” includes not requiring any insurance deductibles or copays. Employees may refuse the series but must sign a declination form and can choose to receive it at any later time.

If you only have one employee who performs tasks that could result in an occupational exposure to bloodborne pathogens, the Bloodborne Pathogens Standard and Needlestick Safety and Prevention Act do not apply to your organization. *

This is false. OSHA's Bloodborne Pathogens Standard applies to all employers who have an employee(s) with occupational exposure (i.e., reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials (OPIM) that may result from the performance of the employee's duties).

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