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Ask the expert: What occupations are subject to bloodborne pathogens regulations?

Q: What healthcare occupations does the OSHA Bloodborne Pathogens standard cover?

A: The Bloodborne Pathogens standard [1] does not list occupations that are automatically covered. Instead, the standard identifies the condition of occupational exposure under which the standard would apply.

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.

As a guide for OSHA inspectors, Enforcement Procedures for the Occupational Exposure to Bloodborne Pathogens [2], under the scope and applications heading, lists 38 occupations or job types that could be covered under the standard. Not all items on the list are licensed healthcare professions or even positions in healthcare settings.

An OSHA letter of interpretation [3] on the applicability of the Bloodborne Pathogens standard to the hazards of tagging guns in retail clothing stores shows that “the standard addresses the broad issue of occupational exposure to blood and other potentially infectious materials and is not meant solely for employees in health care settings.”