Elements of a Bloodborne Pathogens Program Part Four.


This is the fourth and final part of the Elements of a Bloodborne Pathogens Program. In this last section, I address post-exposure evaluation and follow-up, and recordkeeping.

“Following a report of an exposure incident” the exposed employee will be provided “a confidential medical evaluation and follow-up, including at least the following elements” (Bloodborne, 2016):

  • “Documentation of the route(s) of exposure, and the circumstances under which the exposure incident occurred” (Compliance, 2016).
  • “Identification and documentation of the source individual, unless the employer can establish that identification is infeasible or prohibited by state or local law” (Compliance, 2016).
  • The source individual’s blood shall be tested as soon as feasible and after consent is obtained to determine HBV and HIV infectivity. If consent is not obtained, the employer shall establish that legally required consent cannot be obtained. When the source individual’s consent is not obliged by law, the source individual’s blood, if available, shall be tested and the results documented.  When the source individual is already known to be infected with HBV or HIV, testing for the person of origin is known HBV or HIV status need not be repeated (Bloodborne, 2016).
  • “Results of the source individual’s testing shall be made available to the exposed employee, and the employee shall be informed of applicable laws and regulations concerning disclosure of the identity and infectious status of the source individual” (Bloodborne, 2016).
  • “The exposed employee’s blood shall be collected as soon as feasible and tested after consent is obtained” Bloodborne, 2016).
  • “If the employee consents to baseline blood collection but does not give consent at that time for HIV serologic testing, the sample shall be preserved for at least 90 days. If within 90 days of the exposure incident, the employee elects to have the baseline sample tested, such testing shall be done as soon as feasible” (Bloodborne Pathogens, 3026).
  • Post-exposure follow-up will include counseling and evaluation of reported illnesses.

“The healthcare professional evaluating an employee after an exposure incident is provided the following information” (Bloodborne, 2016).

  • A copy of corporate or company regulation.
  • “A description of the exposed employee’s duties as they relate to the exposure incident” (Hepatitis, 2016).
  • “Documentation of the route(s) of exposure and circumstances under which exposure occurred” (Hepatitis, 2016).
  • Results of the source individual’s blood testing, if available.
  • All medical records are relevant to the appropriate treatment of the employee including vaccination status which is the employer’s responsibility to maintain.
  • The Healthcare Professional’s Written Opinion shall be provided to the unit or organization of the service member, and a copy will be given to the service member or employee within 15 days of the completion of the evaluation (Compliance, 2016).

The healthcare professional’s written opinion for post-exposure evaluation and follow-up shall be limited to the following information (Healthcare, 2016):

  • “That the employee has been informed of the results of the” assessment (Bloodborne, 2016).
  • “That the employee has been told about any medical conditions resulting from exposure to blood or other potentially infectious materials which require further evaluation or treatment” (Bloodborne, 2016).
  • All other findings or diagnoses shall remain confidential and shall not be included in the written report.

The employer shall establish and maintain an accurate record for each employee with occupational exposure, by 29 CFR 1910.1020. This record shall include:

  • “The name and social security number of the” employee (Exposure, 2016);
  • A copy of the employee’s hepatitis B vaccination status including the dates of all the hepatitis B vaccinations and any medical records about the employee’s ability to receive the vaccination.
  • A copy of all results of examinations, medical testing, and follow-up procedures.
  • The employer’s copy of the healthcare professional is written an opinion.
  • “A copy of the information provided to the healthcare professional” (Bloodborne Pathogens, 2016).

Confidentiality must be maintained. The employer shall ensure that employee medical records are (Bloodborne, 2016):

  • Kept confidential.
  • Not disclosed or reported without the employee’s express written consent of any person within or outside the workplace except as required by this section or as may be necessary by law (Bloodborne, 2016).
  • Maintained for at least the duration of employment plus 30 years by 29 CFR 1910.1020.

“Training records shall include the following information” (Heartsave, 2016):

  • The dates of the training sessions.
  • The contents or a summary of the training sessions.
  • The names and qualifications of persons conducting the training.
  • The names and job titles of all persons attending the training sessions.

Training records shall be maintained for three years from the date on which the training occurred.


Bloodborne pathogens. – 1910.1030, https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10051&p_table=ST (accessed September 29, 2016).

Bloodborne Pathogens Exposure Control Plan, https://luna.edu/media/page_files/Bloodborne_Pathogens_Exposure_Control_Plan.pdf (accessed September 29, 2016).

Compliance with OSHA Regulation, https://www.ndhealth.gov/disease/hai/Presentation/CompliancewithOSHA%20Regulatio (accessed September 29, 2016).

Healthcare Professional’s Written Opinion Post Blood Exposure, http://www.usbioclean.com/hepatitis-b-vaccination-and-post-exposure-evaluation-a (accessed September 29, 2016).

Heartsaver? Bloodborne Pathogens Online? OnlineAHA.org .., https://www.onlineaha.org/courses/27 (accessed September 29, 2016).

Hepatitis B Vaccination – Explosure Control Plan, https://daf.csulb.edu/offices/ppfm/ehs/programs/exp/collection_testing.html (accessed September 29, 2016).

Recordkeeping – Exposure Control Plan, https://daf.csulb.edu/offices/ppfm/ehs/programs/exp/recordkeeping.html (accessed September 29, 2016).

About Fred Fanning Author

Fred Fanning currently writes biweekly on his blog fredefanningauthor.com. His published works include the peer-reviewed book Basic Safety Administration-A Handbook for the New Safety Specialist. Fred also authored two editions of the peer-reviewed chapter Safety Training and Documentation Principles that was published in the bestselling Safety Professional Handbook and the Safety Professional Handbook Management Applications. He coauthored the peer-reviewed chapter Safety Training with Christine Fiori, Ph.D., PE, published in the bestselling Construction Safety Management and Engineering, second edition edited by Darryl C. Hill, Ph.D., CSP. Fred also has several self-published books. He has a series called Fred’s Safety Shorts. This is a collection of twelve books on topics related to safety published with Kindle Direct Publishing. Fred self-published another six books using both CreateSpace Independent Publishing Platform and Kindle Direct Publishing. He has authored fifty-eight articles in various publications on the topics of safety and health and project management. Fred has earned several writing awards for his non-fiction work. Fred has two novels A Walk Among the Dead and Mystery at Devil’s Elbow.
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