Ask the expert—Bloodborne pathogens and small medical practice exemption

By: October 23rd, 2008 Email This Post Print This Post

Q: Is there a magic number of employees that exempts a medical practice from having to follow the OSHA bloodborne pathogens standard and safety needle rules?

A: That the OSHA bloodborne pathogens standard does not apply to small medical practices is a lingering misconception. But a January 20, 2004, OSHA letter of interpretation makes things perfectly clear: “OSHA’s bloodborne pathogens standard, including its 2001 revisions, applies to all employers who have employees with reasonably anticipated occupational exposure to blood or other potentially infectious materials (OPIM).”

The letter notes a recordkeeping exemption for certain types of healthcare facilities, including offices and clinics of doctors and dentists, medical and dental laboratories, and specialty outpatient facilities. But there is no exemption to the bloodborne pathogens standard based on the number of employees.

For more frequently asked questions about OSHA, download OSHA FAQ: Compliance for Ambulatory Healthcare Settings from the Tools section.


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