6 Steps to Prepare a Bloodborne Pathogens Exposure Determination

Employers are required to protect workers in healthcare and other settings who are exposed to blood and other biologically infectious materials from becoming infected. The first thing to do is to carry out what’s called an exposure determination to determine which workers are at risk.

Step 1: Figure Out What Exposure You’re Looking for

The first thing you must do in carrying out your exposure determination is figure out which workers have such exposure.

“Occupational Exposure” means reasonably 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. To make sense of this definition, you need to understand these terms:

• “Blood,” means human blood, human blood components and products made from human blood;
• “Other potentially infectious materials” (OPIM), includes:
  The following human body fluids: 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, and 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); and
  HIV-containing cell or tissue cultures, organ cultures, and HIV- or HBV-containing culture medium or other solutions; and blood, organs, or other tissues from experimental animals infected with HIV or HBV
• “Parenteral,” piercing mucous membranes or the skin barrier through such events as needlesticks, human bites, cuts and abrasions.

Step 2: List Job Classifications in which All Employees Have Exposure

There are certain elements your exposure classification must include. The first is a list of all job classifications in which all employees covered by the classification have occupational exposure.

Step 3: List Job Classifications in which Some Employees Have Exposure

Next, make a separate list of all job classifications in which some employees covered by the classification have occupational exposure.

Step 4: List Job Tasks that Have Exposure

The third list you need is a list of all tasks and procedures in which occupational exposure occurs and that are performed by employees listed in the second list, i.e., job classifications in which some employees covered by the classification have occupational exposure.

Step 5: Don’t Consider PPE

In making up these lists, you’re not allowed to consider PPE. In other words, assume that the job classification or task has exposure even if the employee uses PPE while performing it.

Step 6: Select Appropriate Controls

Once you complete your lists of exposed job classifications and tasks, you must select measures to protect employees who have occupational exposure.