Identify Who Has Occupational Exposure

A majority of workers in the health care field routinely come into contact with blood and body fluids that potentially contain bloodborne pathogens. These workers are known to be at-risk. Other occupations where workers may be exposed to BBP and must be covered by an employer's exposure control plan include the following.

Emergency Responders, Firefighters, And Law Enforcement Personnel

For emergency responders such as firefighters, law enforcement agents, and other emergency response personnel, the potential sources of contamination from bloodborne pathogens are varied. Emergency responders assist when there is illness and at accidents and fires where there frequently is trauma, such as open wounds. Also, exposure and potential infection can result from handling discarded emergency medical items such as needles and sharps, bandages, or gauze.

Today's firefighters and emergency responders play a greater role in emergency situations, frequently as health care providers, and are often the first to arrive at the scene of an accident. For example, up to 80 percent of all field emergency medical care today is provided by fire service personnel. Although not officially classified as health care workers, fire and rescue personnel are consistently faced with the potential for exposure to infectious blood, blood products, blood components, and body fluids.

Emergency responders frequently face unpredictable, uncontrollable, dangerous, and life-threatening circumstances. Anything can happen in an emergency situation, including exposure to blood and contaminated equipment. This especially applies to fire and rescue personnel and, in many instances, law enforcement personnel who often operate under hostile circumstances. There is an extremely diverse range of potential situations that can put law enforcement officers at risk.

At crime scenes, when processing suspects, or as a result of fights and/or assaults, law enforcement officers may be at risk of exposure. The informed judgment and awareness of the individual officer is critical when unusual circumstances or events arise that can jeopardize his/her safety or health. It is the responsibility of emergency responders' employers to ensure that their employees are properly informed and adequately protected at the work site and in emergency situations.

In-Plant First Aid Responders

Employees who are trained and designated as responsible for rendering first aid or medical assistance as part of their job duties have the potential for exposure and must receive bloodborne pathogens training.

Maintenance Workers

While OSHA does not generally consider maintenance personnel and janitorial staff employed in non-health care facilities to have occupational exposure, it is the employer's responsibility to determine which job classifications or specific tasks and procedures involve occupational exposure. For instance, if maintenance or janitorial personnel are required to clean up following an incident involving body fluids, they would need bloodborne pathogens training.

Also, OSHA expects products such as used sanitary napkins to be discarded into waste containers which are lined in such a way as to prevent contact with the contents. But at the same time, the employer must determine if employees can come into contact with blood during the normal handling of such products from initial pick-up through disposal in the outgoing trash.


Occupational exposure is defined as "reasonable anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee's duties." The definition of "other potentially infectious materials" includes any body fluid that is visibly contaminated with blood. Urine, feces, sweat, tears, nasal secretions, and vomitus which are not visibly contaminated with blood are not considered to by "other potentially infectious materials."

Personnel Service/Contract Workers

If your company uses personnel service workers and you, as the the host employer, exercise day-to-day supervision over those workers, then they are considered the employees of the host employer, as well as of the personnel service. In this situation, the host employer must comply with all provisions of the BBP standard with respect to these workers.

Regarding Hepatitis B vaccination, post-exposure evaluation and follow-up, recordkeeping, and generic training, the host employer's obligation is to take reasonable measures to assure that the personnel service firm has complied with these provisions.

Independent contractors that provide a service, such as a cleaning service, provide supervisory personnel, as well as rank-and-file workers to carry out the services. These companies and the host employers are responsible for complying with all provisions of the BBP standard according to OSHA's multi-employer worksite guidelines.

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