Bloodborne Pathogens

Bloodborne Pathogens Training

Bloodborne pathogens are microorganisms present in human blood and other potentially infectious materials (OPIM) that can cause disease in people who are exposed to them. In Texas school districts and other public sector workplaces, employees who may be exposed to blood or bodily fluids in the course of their duties are required to receive training and follow specific safety protocols. This training covers the major pathogens, transmission routes, regulatory requirements, prevention measures, and what to do if an exposure occurs.

---

Bloodborne Pathogens of Concern

The three primary bloodborne pathogens of occupational concern are:

• Hepatitis B Virus (HBV) — A serious liver infection. HBV is highly resilient and can survive outside the body on surfaces for up to 7 days. Without vaccination, exposure to HBV-infected blood carries a significant risk of infection. Chronic HBV infection can lead to cirrhosis, liver failure, and liver cancer.
• Hepatitis C Virus (HCV) — The leading cause of chronic liver disease in the United States. There is no vaccine for HCV. Chronic HCV infection frequently progresses to serious liver damage. Transmission is primarily through blood-to-blood contact.
• Human Immunodeficiency Virus (HIV) — The virus that causes AIDS. HIV attacks the immune system and, if untreated, eventually leaves the body unable to fight infection. While occupational transmission risk is lower than for HBV, exposure to HIV-infected blood remains a serious concern.

Other pathogens including Ebola, Zika virus, and certain bacteria can also be transmitted through blood and bodily fluids. All of these are addressed by the same prevention framework.

Transmission Routes

Bloodborne pathogens spread through direct contact with infected blood or other potentially infectious materials (OPIM), including: blood, saliva, vomit, mucus, urine, feces, semen, and vaginal secretions. Transmission can occur through needlesticks or sharps injuries, splashes to the eyes, nose, or mouth, contact with broken or non-intact skin (cuts, abrasions, rashes, or chapped skin), and sexual contact.

Important: Dried blood can remain infectious for up to one week. A surface that appears clean and dry may still harbor viable pathogens. This is why cleaning and disinfection procedures and PPE use are required even when blood appears to have dried.

---

Regulatory Framework

Bloodborne pathogen safety in Texas is governed by two overlapping regulatory frameworks:

• OSHA Bloodborne Pathogens Standard (29 CFR 1910.1030) — The federal standard establishing employer obligations for protecting workers with occupational exposure. Federal OSHA applies to all Texas workplaces.
• Texas Department of State Health Services (DSHS) — The regulatory authority for bloodborne pathogen compliance in Texas. DSHS rules are codified at 25 TAC Chapter 96, Subchapter T. DSHS has authority to conduct compliance audits in educational facilities and other workplaces. For Texas public school districts, the DSHS Bloodborne Pathogen Control in Texas Schools rule establishes specific requirements for exposure control planning, training, and incident management.

DSHS can conduct compliance audits of educational facilities. Employers should regularly assess their written programs, training records, and implementation of safety measures.

---

Universal Precautions

Universal Precautions is the foundational concept of bloodborne pathogen prevention. It requires that all blood and potentially infectious bodily fluids be treated as if they are infectious, regardless of whether the person is known or believed to be infected. You cannot determine whether blood or other body fluids are infectious by looking at them. The only safe practice is to assume every exposure carries risk and respond accordingly.

Universal Precautions apply to all employees with potential occupational exposure — not just nurses or health aides. Custodians cleaning up blood spills, coaches assisting injured athletes, special education staff providing personal care, and any other employee who may contact blood or OPIM must follow Universal Precautions.

---

The Exposure Control Plan

OSHA and Texas DSHS require every employer with employees who have occupational exposure to develop and implement a written Exposure Control Plan (ECP). The ECP must be accessible to all employees and must include:

• Identification of all job classifications with occupational exposure (e.g., nurses, custodians, coaches, special education aides)
• Methods of compliance, including engineering controls, work practice controls, and PPE requirements
• Hepatitis B vaccination procedures, including how employees request the vaccine
• Post-exposure evaluation and follow-up procedures
• Hazard communication to employees (labels, signs, training)
• Recordkeeping protocols

The ECP must be reviewed and updated at least annually and whenever new job classifications, tasks, or procedures are introduced that affect occupational exposure. Employees must know where to find the ECP and how to use it.

---

Prevention: Engineering Controls

Engineering controls are physical or mechanical measures that eliminate or reduce exposure at the source — without relying on employee behavior. They are the preferred method of hazard control. Examples include:

• Safer medical devices — Needleless systems, shielded or retractable needle devices, and self-sheathing syringes reduce needlestick injuries significantly
• Sharps disposal containers — Puncture-resistant, leak-proof containers for disposing of needles, lancets, and other sharps; must be located at or near the point of use, kept upright, and replaced before they are completely full (typically when three-quarters full)
• Biological safety cabinets — Where procedures involving blood or OPIM create splash or aerosol risk in laboratory or clinical settings

Employees must participate in the selection and evaluation of safer needle devices. Their input is required under the OSHA standard, and their firsthand experience with devices is invaluable for identifying what actually works in practice.

---

Prevention: Work Practice Controls

Work practice controls change the way tasks are performed to reduce exposure risk. They include:

• Universal Precautions — Treat all blood and OPIM as infectious at all times
• Hand hygiene — Wash hands with soap and running water for at least 20 seconds immediately after removing gloves or any other PPE, after contact with blood or OPIM, and before eating, drinking, or touching your face. When soap and water are not immediately available, use an alcohol-based hand sanitizer as a temporary measure and wash with soap and water as soon as possible.
• No recapping of needles by hand — Never recap a used needle using two hands; if recapping is necessary, use a one-handed scoop technique or a mechanical device
• No bending, breaking, or removing needles from syringes by hand
• No eating, drinking, smoking, or applying cosmetics in areas where exposure to blood or OPIM is possible
• Minimize splashing and spraying when handling blood or OPIM
• Decontaminate work surfaces with an appropriate disinfectant after any spill of blood or OPIM and at the end of each work shift

---

Personal Protective Equipment (PPE)

PPE creates a barrier between the employee and potentially infectious materials. The employer must provide PPE at no cost to employees, and employees must use it whenever occupational exposure may occur. Required PPE includes:

• Disposable gloves — Required whenever touching blood, OPIM, mucous membranes, or non-intact skin; when performing vascular access procedures; and when handling contaminated items or surfaces. Replace gloves immediately if torn, punctured, or contaminated. Never wash or reuse disposable gloves. Offer latex-free alternatives to employees or students with latex allergies.
• Protective goggles or face shields — Required when splashes, sprays, or spatters of blood or OPIM are reasonably anticipated to reach the eyes, nose, or mouth
• Gowns or aprons — Required when clothing may be soiled with blood or OPIM; remove and bag contaminated garments before leaving the work area
• Masks — Required when splashes or sprays could reach the mouth or nose; worn in combination with eye protection

Select PPE appropriate to the anticipated exposure. For a routine blood spill cleanup, gloves are the minimum. If the spill involves a large amount of blood or there is a reasonable likelihood of splashing, add eye protection and a gown. PPE must be removed carefully to avoid self-contamination — peel gloves inside-out from the wrist, avoid touching the outer contaminated surface.

---

Hepatitis B Vaccination

Employers must offer the complete Hepatitis B vaccination series free of charge to all employees with occupational exposure. This offer must be made within 10 working days of initial assignment to a position with occupational exposure, after training has been completed, and during working hours.

The Hepatitis B vaccine series consists of three doses given over a 6-month period and provides long-lasting protection. Employees who decline the vaccine must sign a declination statement acknowledging they were offered the vaccine and chose not to receive it. They may reconsider and request the vaccine at any time at no charge.

Post-vaccination antibody testing is recommended to confirm immunity. Employees who do not develop immunity after the initial series should be tested for existing HBV infection and offered additional vaccine doses. Hepatitis B vaccination is one of the most effective preventive measures available — the vaccine is safe, effective, and fully covered by the employer.

---

Post-Exposure Procedures

Even with all precautions in place, exposures can occur. A prompt, systematic response is essential. If you are exposed to blood or OPIM through a needlestick, cut, splash to the eyes or mouth, or contact with non-intact skin:

1. Clean the exposed area immediately: For skin exposures, wash thoroughly with soap and running water. For eye or mucous membrane exposures, flush with clean water, saline, or sterile irrigant for at least 15 minutes. Do not use caustic agents or bleach directly on wounds.
2. Report the incident immediately to your supervisor. Prompt reporting is critical because post-exposure medications (PEP — post-exposure prophylaxis) are most effective when started within hours of exposure, ideally within 2 hours for HIV.
3. Seek medical evaluation and follow-up. A healthcare provider will assess the source of exposure if known, order baseline blood tests, prescribe post-exposure prophylaxis if appropriate, and schedule follow-up testing at 6 weeks, 3 months, and 6 months post-exposure.
4. Document the exposure incident in writing. Documentation must include the date and time of exposure, how and where it occurred, what PPE was in use, and the source individual’s identity if known. Confidentiality of the source individual’s medical information must be maintained.

Post-exposure evaluation and follow-up are provided at no cost to the employee. Do not delay seeking care due to concerns about cost or inconvenience. Time is critical, particularly for potential HIV exposure.

---

Cleanup of Blood Spills

All blood spills must be cleaned up promptly and properly. The correct procedure is:

1. Don appropriate PPE before approaching the spill (gloves minimum; add eye protection and gown if splashing is possible)
2. Absorb the spill with disposable absorbent material (paper towels, absorbent pads) — do not sweep or vacuum dried blood, as this can aerosolize particles
3. Discard absorbed material in a biohazard bag or, if not available, a sealed plastic bag
4. Clean the area with detergent and water
5. Disinfect with an appropriate disinfectant — a freshly prepared solution of household bleach diluted 1:10 (1 part bleach to 9 parts water) is effective against HBV, HCV, and HIV; allow adequate contact time per product instructions
6. Dispose of all contaminated materials in appropriate waste containers
7. Remove PPE carefully and wash hands immediately

---

Labeling and Waste Disposal

Containers holding blood, OPIM, or contaminated sharps must be labeled with the biohazard symbol in fluorescent orange or orange-red. Labels must be affixed to containers of regulated waste, refrigerators and freezers containing blood or OPIM, and other containers used to store or transport infectious materials. Red bags or red containers may be substituted for labels. Regulated medical waste must be disposed of in compliance with Texas DSHS requirements and local ordinances — contact your district’s safety coordinator for disposal procedures specific to your facility.

---

Special Requirements for Texas School Districts

Texas public school districts are specifically required under DSHS rules (25 TAC Chapter 96, Subchapter T) to implement bloodborne pathogen exposure control programs. Key district-specific requirements include:

• Universal Precautions must be followed by all staff in all situations involving potential contact with bodily fluids — this includes staff who are not medically trained, such as teachers, coaches, and custodians
• PPE must be available and used whenever contact with bodily fluids is possible — districts must stock and maintain adequate supplies at all campus locations
• Annual training is required for all staff with occupational exposure; training records must be maintained for at least 3 years
• All exposure incidents must be reported and properly managed per the district’s ECP
• Medical records related to bloodborne pathogen exposure must be maintained for the duration of employment plus 30 years
• DSHS has authority to conduct compliance audits of school facilities; districts should maintain current written programs and training records at all times

Employees in the following school roles commonly have occupational exposure and must be included in the ECP: school nurses and health aides, special education and personal care aides, coaches and athletic trainers, custodians and maintenance staff, and any staff member responding to injuries or medical emergencies.

---

Training Requirements

Bloodborne pathogen training is mandatory for all employees with occupational exposure and must be provided:

• Upon initial assignment to a position with occupational exposure (before beginning work)
• At least annually thereafter
• Whenever new or modified tasks or procedures affect the nature or degree of occupational exposure

Training must be provided during working hours at no cost to the employee. Training records must document the date, content, trainer’s name and qualifications, and the names of employees who attended. Records must be maintained for at least 3 years.

---

Additional Resources

• Texas DSHS — Bloodborne Pathogens
• Texas DSHS — Bloodborne Pathogen Control in Texas Schools
• OSHA — Bloodborne Pathogens Standard (29 CFR 1910.1030)
• TASB Risk Management Fund — Bloodborne Pathogen Compliance