Environmental Health & Safety

In Compliance with 29 CFR 1910.1030 OSHA Standard for Occupational Exposure to Bloodborne Pathogens

Bloodborne Pathogens Exposure Control Plan

Printable files are available in two parts with Adobe Acrobat Reader:

• PDF Version of Exposure Control Plan for Bloodborne Pathogens
• PDF Version of Appendices

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4. Methods of Compliance
10. Recordkeeping
1. Medical Records: For each employee with occupational exposure, the University is required to establish and maintain an accurate record which includes the employee's name, social security number, hepatitis B vaccination status, and any information related to exposure follow-up. These records are confidential and will be retained for the duration of employment plus 30 years. University Health Service will maintain such medical records for all University employees. SMH employee records shall be maintained by SMH Employee Health.
2. Training Records: Training records shall include dates of the training sessions, contents of the training sessions, names and job titles of all persons attending the training sessions. These records shall be maintained for 3 years from the date on which the training occurred.
3. Exposure information (Post-Exposure, Evaluation and Follow Up) is kept by SMH Employee Health for 5 years plus the current year.
4. Sharps Injury Log: All percutaneous injuries from contaminated sharps are recorded in the OSHA 300 Log and the Sharps Injury Log. Records of all instances include:
1. the date of the injury
2. the type and brand of the device involved
3. the department or work area where the incident occurred
4. an explanation of how the incident occurred

Worker's Compensation is responsible for maintaining both the OSHA 300 Log and the Sharps Injury Log. The Sharps Injury Log is reviewed at least annually by Environmental Health & Safety, and entries in the Log are maintained for at least 5 years following the incidents they cover. If a copy of the Sharps Injury Log is requested by anyone, it must have any personal identifiers removed from the report.

The source for the collection of sharps injury information for the University is the Employee Incident on-line reporting system. Employee Incident reports must be completed for all exposure incidents. The link to the reporting system is located at www.safety.rochester.edu/SMH115.html. A link to this page can also be found on the Nursing webpage.

11. Monitoring For Compliance

The University will monitor for compliance through spot checks and scheduled inspections in areas where employees may be potentially exposed. Checks will be performed by area supervisors. Consultation will be provided by SMH Infection Control, Eastman Institute for Oral Health Infection Control, and Environmental Health & Safety.

12. Enforcement

All employees defined in the Exposure Determination section of this Exposure Control Plan are required to comply with the Plan. Failure to comply may result in corrective disciplinary action as defined in the University's Personnel Policies.

Continue to Section V - Post-Exposure, Evaluation and Follow-up

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QUESTIONS? Contact EH&S at (585) 275-3241 or e-mail EH&S Questions.

This page last updated 8/22/2019. Disclaimer