OSHA Bloodborne Pathogen Rules Your Cleaner Must Follow

OSHA's Bloodborne Pathogen standard, 29 CFR 1910.1030, applies to workers who have occupational exposure to blood or other potentially infectious materials. Cleaning crews working in medical and dental facilities fall within this scope when their work brings them into contact with patient areas, waste receptacles, exam surfaces or any space where bloodborne pathogen exposure is reasonably anticipated.

The standard does not apply to cleaning contractors automatically — it applies when the facility allows them to work in areas of potential exposure. A practice that brings in an untrained cleaning crew and allows them to clean exam rooms has, in practical terms, failed to ensure their contractors meet the OSHA requirement.

What the Standard Requires of Cleaning Crew

• Annual training. Documented training on the hazards of bloodborne pathogens, methods of transmission, personal protective equipment, exposure incidents and post-exposure procedures. This training must occur before the worker begins tasks involving occupational exposure.
• Written Exposure Control Plan access. Workers must have access to the facility's Exposure Control Plan. Cleaning contractors working on-site should be informed of relevant components before beginning work.
• Personal protective equipment. Gloves are required when cleaning surfaces that may be contaminated with blood or OPIM. The standard specifies that PPE must be provided at no cost to the worker and must be used.
• Hepatitis B vaccination offer. Employers must offer Hepatitis B vaccination to workers with occupational exposure. This applies to the cleaning contractor, not the medical facility — but practice managers should confirm contractors have addressed this with their crew.
• Exposure incident protocol. Workers must know what to do if an exposure incident occurs. A needle stick during sharps disposal, contact with a contaminated surface through broken skin, or splash to the eye or mucous membrane are all reportable exposure incidents.

What to Ask Your Cleaning Contractor

Before signing a cleaning contract for clinical space in Rosemount or the South Metro, ask the contractor to confirm in writing:

1. That crew assigned to your account have completed OSHA BBP training in the past 12 months.
2. That training records are maintained and available for inspection.
3. That crew are provided with appropriate PPE for clinical cleaning tasks.
4. That the contractor has a documented exposure incident procedure.

A contractor who cannot answer all four questions should not be cleaning your exam rooms.

Sharps and Biohazard Waste

Cleaning contractors are generally not responsible for sharps disposal or biohazard waste removal. Those tasks fall within the facility's own regulated waste program. Where this becomes ambiguous is in the cleaning of surfaces around sharps containers and biohazard receptacles — that cleaning is within cleaning contractor scope and does require BBP training.

This article is for general informational purposes. OSHA regulations are specific to employer-employee relationships; how they apply to your facility and contractor arrangement should be confirmed with your compliance officer or legal counsel.