Bloodborne Pathogens Program

For Assistance with:

  • Bloodborne Pathogen Program, Haley Sinn 335-9553
  • Bloodborne Pathogen Program, train the trainer, Haley Sinn 335-9553
  • Bloodborne Pathogen Program, training materials, Haley Sinn 335-9553
  • Medical Consultation & Examinations (Contact UEHC 356-3631)

The Occupational Safety and Health Administration (OSHA) issued the Bloodborne Pathogens (BBP) Standard to protect workers from occupational exposure to hepatitis B virus (HBV), hepatitis C virus (HCV), human immunodeficiency virus (HIV), and other bloodborne pathogens. The Standard requires that employees regard blood and certain other bodily fluids from any individual as potentially infectious, thus applying the concept of universal precautions. Reasonably anticipated contact with blood and other potentially infectious materials is what places an individual "at risk" of exposure to bloodborne pathogens.


The BBP Standard applies to any employee whose job entails reasonably anticipated contact with blood, blood products, and other potentially infectious materials (semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva in dental procedures, any body fluid that is visibly contaminated with blood, all body fluids in situations where it is difficult or impossible to differentiate between body fluids; any unfixed tissue or organ (other than intact skin) from a human (living or dead); HIV-containing cell or tissue cultures, organ cultures, and HIV- or HBV-containing culture medium or other solutions; blood, organs or other tissues from experimental animals infected with HIV or HBV). A wide variety of jobs involve a potential for exposure, including patient contact, laundry workers, custodians cleaning blood spills and transporting biohazard waste containers, laboratorians, first aiders, equipment repairers, athletic trainers, etc.  
Cell lines from ATCC are not tested sufficiently to exempt them from possible BBP exposure and as a result, all employees who work with human cell lines are also considered “at risk”.
Researchers working with non-human primate (NHP) blood, tissues, or other bodily fluids are recommended to use universal precautions when handling this material.  

Program Elements – Departmental Responsibilities

  • Initially departments must:  

    • identify all "at risk" employees; 
    • designate an Exposure Control Officer (ECO);
    • provide BBP training for all "at risk" employees annually; and 
    • offer "at risk" employees Hepatitis B Virus vaccination within 10 working days of initial assignment and training.
  • Written Program

  • ​​​​​A written Exposure Control Plan (ECP) must be prepared and implemented that includes:
    • exposure determinations;
    • methods of compliance, e.g. use of Universal Precautions, work practice controls, engineering controls and personal protective equipment (PPE); 
    • medical surveillance; 
    • training; and 
    • post-exposure procedures.

EHS has developed a Bloodborne Pathogens Exposure Control Plan template to assist departments in completing their Exposure Control Plans. This word document provides a standard format and guides departments where department/area specific information must be added, or where appropriate, sections can be deleted.

Exposure Control Officer (ECO)

Each department will designate an individual as their ECO.  Responsibilities of the ECO include:

  • reviewing and updating the exposure determination for the department, identifying all “at risk” employees;
  • annually reviewing and updating the Exposure Control Plan, communicating all changes to personnel;
  • ensuring all persons “at risk” of BBP exposure within their department receive the necessary training and vaccinations; and
  • providing all persons “at risk” of BBP exposure within their department the location of the written program 

Periodically, EHS will offer a training session for the ECO’s.

Medical Surveillance

Departments must provide the Hepatitis B vaccine series to employees who are "at risk" for Bloodborne Pathogen exposure, at no cost to the employee. This service is provided by University Employee Health Clinic (UEHC) at 356-3631. All “At Risk” employees should initially complete an online Hepatitis B vaccination survey provided through UEHC’s patient software, ReadySet, regardless of whether the employee is accepting or declining the vaccination. Instructions for creating a ReadySet account and completing the Hepatitis B vaccination survey is available on the EHS website. 

Post-exposure evaluation and follow-up are provided by UEHC, call 356-3631.


Each department is responsible for training its employees who are determined to be at risk of occupational exposure. Training courses for “at risk” employees are available.  There are 5 different BBP courses available, make sure the employee(s) takes the course appropriate for each department: 

  • BBP for Lab Workers is designed for laboratory employees and students upon initial training.
  • BBP for Non-lab Workers Bis designed for non-laboratory staff, such as Athletics, Residence Services, Public Safety, etc. upon initial and annual refresher training.
  • BBP for Facilities Management and University Housing and Dining Employees is designed for personnel employed by Facilities Management and University Housing and Dining departments, who have been identified by their department administrators as being “at risk”.
  • BBP Refresher is designed as a refresher course for laboratory employees and students across campus (CPH and others).  The refresher course may be taken annually only if staff has already completed the BBP for Lab Workers or BBP for CPH courses during their initial training.

If you have any questions as to which course should be completed, please call EHS (5-9553).

When completing BBP for Lab Workers and BBP for Non-lab Workers courses online, additional, site-specific, departmental information must be provided in order to be in regulatory compliance with OSHA.  A site-specific training form is available within the course content; it is the responsibility of the employee, along with their supervisor or designated work area trainer, to complete the site-specific training and maintain a copy of this record.

A few departments on campus offer BBP training from within the department.  Staff and students attending this training do not need to complete EHS’s online BBP course.

General requirements for training are that it must be: 

  • at the time of initial assignment to tasks where occupational exposure may take place; 
  • conducted annually thereafter; and
  • given when changes or modifications in procedures occur that affect the employee's occupational exposure. 

Topics to be covered in all information and training programs include: 

  • regulatory text of the standard; 
  • Exposure Control Plan, including location; 
  • epidemiology and symptoms of bloodborne pathogens; 
  • modes of transmission of bloodborne pathogens; 
  • methods for recognizing tasks and activities that place employees at risk; 
  • use and limitations of methods of control to prevent occupational exposure; 
  • basis for selection of PPE and information on the types, proper use, location, removal, handling, decontamination, and disposal of PPE; 
  • information on the HBV vaccine and benefits of being vaccinated; 
  • post-exposure follow-up procedures and evaluation the employer must provide for the employee; 
  • explanation of signs, labels, and tags used to denote biohazards; and
  • spill response procedures.

Additional training is required for personnel working in HIV and HBV Research Laboratories and Production Facilities.


Accurate records must be maintained of: 

  • the written Exposure Control Plan; 
  • Incident Investigation Forms;
  • training syllabus and attendance records; and 
  • medical surveillance.