No medical practice too small for bloodborne pathogens compliance

By: David LaHoda February 2nd, 2010

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 [Needlestick Safety and Prevention Act], applies to all employers who have employees with reasonably anticipated occupational exposure to blood or other potentially infectious materials.

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

If you found this Q&A helpful to your OSHA compliance program, download the special report OSHA FAQ: Compliance for Ambulatory Healthcare Settings featured in the special report section on the Tools page.

Comments(0) Ask the Expert—Bloodborne Pathogens