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Tips for Fleets to Avoid Bloodborne Pathogen OSHA Violations


As a fleet owner or manager, bloodborne pathogens are likely not high on your list of concerns. That doesn’t mean they don’t present a risk to your drivers, your company, or your bottom line, though.

Bloodborne pathogens, also known as BBPs, are microorganisms that are present in human blood and other bodily fluids. They can cause serious diseases and autoimmune disorders such as hepatitis and HIV.

Because BBPs are so dangerous, your workers are protected under OSHA from exposure. That means you have a legal obligation to meet certain requirements. If you don’t, you face the risk of hefty fines.

Luckily, covering the basics and protecting your employees is simple. You just need to implement the strategies we discuss below.

What is Your Risk as a Fleet Manager?

As this article points out, OSHA fines for employer bloodborne pathogen violations can be significant.

It only takes one to ruin your finances for a year or, for smaller fleets, put you out of business.

Your fleet drivers and employees are probably not at high risk for exposure to BBPs. Even so, if they work with other people, there is always some risk present. Moreover, even if none of your employees are actually exposed, being found to be in violation of OSHA standards will lead to fines regardless.

The OSHA standard for bloodborne pathogens can be found here. If you’re not aware of it, it’s wise to read up.

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What is Involved With OSHA’s BBP Standard?

The best way to understand the OSHA standard is through the lens of an Exposure Control Plan (ECP for short). An ECP is how your organization plans to prevent and respond to employee exposures to bloodborne pathogens as well as how your company will comply with the BBP OSHA standard. 

A proper ECP has 11 steps. This article provides helpful templates for how to implement each step, but we list and briefly explain each step below:

  • Policy

Step one is to create an official ECP policy. This document should be shared with all employees.

  • Program Administration

Your ECP must list the employees who are responsible for enacting the ECP throughout the company.

  • Employee Exposure Determination

You must list the various job requirements that could potentially expose employees to bloodborne pathogens.

  • Methods of Implementation and Control

This section lists the steps your company is taking in order to prevent and respond to exposure, such as universal precautions and sharps disposal containers.

  • Hepatitis B Vaccination

OSHA requires employers to offer a Hepatitis B vaccination within 24 hours of an employee being exposed. This part of your ECP explains how that will be enacted.

  • Post Exposure Evaluation and Follow-Up

You must document your process for how an employee will alert the company that he or she was exposed.

  • Administration of Post-Exposure Evaluation and Follow-up

You must document your process for responding to an employee that alerts you of exposure to a BBP.

  • Procedures for Evaluating the Circumstances Surrounding an Exposure Incident

This part of the ECP is how your company plans to re-evaluate policies and procedures in order to prevent future exposures.

  • Employee Training

OSHA mandates some amount of BBP training for certain industries. In this part of the ECP, you document how you will carry this out.

  • Recordkeeping

You must explain how you will store records for training, exposures, medical records, etc.

  • Hepatitis B Vaccination Decline

If an employee declines a hepatitis B vaccination after exposure, you must have an official document he or she signs.

How Can You Stay Compliant?

Knowing what bloodborne pathogens are, understanding the OSHA standard, and implementing an Exposure Control Plan are all great first steps. However, if you want to avoid costly fines, you need to do more to stay compliant.

We recommend taking the following action:

  1. Implementing Universal Precautions
  2. Internal Audits
  3. Employee training on BBP

Implement Universal Precautions

The best way for individuals to avoid bloodborne pathogens is to avoid exposure in the first place. That’s where universal precautions come into play.

Universal precautions are when employees assume that a potentially infectious substance (like blood, vomit, or other bodily fluid) is infected. This means your employees avoid exposure to any potentially infectious substances and always use personal protective equipment

If you educate and train your employees on universal precautions, their risk for exposure goes way down.

Internal Audits

Most OSHA violations don’t happen because a company got “busted”. Many companies just don’t realize they aren’t complying. That’s why you need to run internal OSHA audits.

Once per year, have someone on your team take a deep dive into all company procedures related to OSHA standards such as bloodborne pathogens.

This is a time-consuming process, but if this person catches something, the employee’s time is a lot cheaper than an OSHA fine.

Employee Training on Bloodborne Pathogens

Depending on your industry, you may be required to give your employees yearly training on bloodborne pathogens.

You can certainly create and implement your own, but that takes time and it isn’t always effective. Instead, you can invest in a cost-effective online training program that gives you much more than you pay for.

A program like The Fleet Safety Course includes:

  • Bloodborne pathogen courses and other OSHA topics
  • Defensive driving and safety subjects
  • Online access via a learning management system
  • The ability to upload your own content
  • Recordkeeping so you can track your training and prove it to OSHA

If you invest in a program like The Fleet Safety Course, you protect your employees, reduce your cost of loss, avoid OSHA violations, and protect yourself from frivolous lawsuits.

Take Action Before OSHA Does

As we pointed out earlier, most OSHA violations happen because a company didn’t even realize it wasn’t complying with OSHA standards.

Take action today before OSHA does.

Create your ECP, implement universal precautions, run internal audits, and invest in OSHA topic training for employees.

These loss-prevention measures will be a worthwhile investment when your accidents, injuries, and fines go way down.

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