Exposure Control Plan
The California Occupational Safety and Health Administration (CalOSHA) Bloodborne Pathogens (8 CCR 5193) applies to all employees who could "reasonably anticipate," as a result of performing their job tasks, contact with blood or other potentially infectious materials (OPIM). The Cal/OSHA BBP Standard protects employees who work in occupations where they are at risk of exposure to blood or other potentially infectious material.
Job Classifications Subject to BBP
Cal/OSHA requires employers to identify job classifications where some or all employees in those jobs have occupational exposure to bloodborne pathogens. Below is a partial list of these job categories. For a complete list of identified Category 1 and Category 2 job classifications see the University Bloodborne Pathogen Exposure Control Plan.
| Physician | Physician Assistant | Uniformed Police Officer |
| Registered Nurse | Medical Assistant | Designated First Aid Provider |
| Nurse Practitioner | Custodian | Waste Management Laborer |
| Nursing Students/ Interns | Athletics Trainers | Plumber |
| Instructional Faculty | Research Faculty | EH&S Staff |
| Teaching Associates | Research Associates | Instructional Support Technicians |
| Graduate Teaching Assistants | Post-Doctoral Candidates | Student Assistants |
Exposure Control Plan Documents
The Exposure Control Plan (ECP) must be in writing and is designed to eliminate or minimize employee exposure to blood or other potentially infectious materials. The Exposure Control Plan must be accessible to employees and must be reviewed and updated at least annually.
Certain separate administrative units are required to have a group-specific ECP that meets the requirements in the University BBP ECP.
Laboratories and Bloodborne Pathogens
Work with human blood, blood products, and associated other potentially infectious materials triggers compliance with the Cal/OSHA BBP standard. However, work with other unfixed human tissues and fluids can require compliance with this standard as well. For example, human cell lines (established and primary) are subject to the Bloodborne Pathogen Standard. At SF State, departments that do laboratory research or teaching with these materials include Biology, Center for Laboratory Science, and Kinesiology or occasionally other human health-related research projects or programs.
OSHA has issued an interpretation stating that all lab work with human tissues, body fluids, and cell lines are covered by the Bloodborne Pathogen Standard. In order to be exempt from the Bloodborne Pathogen Standard, a lab may choose to have their established human cell lines "characterized" as free of contamination from human hepatitis viruses, human immunodeficiency viruses, and other recognized bloodborne pathogens. Contact the EH&S Biosafety Programs Coordinator for more information.
Occupational exposure is defined as reasonably anticipated skin, eye, mucous membrane or parenteral (injection) contact with blood or other potentially infectious materials that may result from the performance of an employee’s duties.
Blood is defined as human blood, human blood components and products made from human blood.
Other potentially infectious materials (OPIM) is defined as the following: saliva in dental procedures; semen; vaginal secretions; cerebrospinal, synovial, pleural, pericardial, peritoneal and amniotic fluids; body fluids visibly contaminated with blood; along with all body fluids in situations where it is difficult or impossible to differentiate between body fluids; unfixed human tissues or organs (other than intact skin); HIV-containing cell or tissue cultures, organ cultures and HIV- or HBV-containing culture media or other solutions; and blood, organs or other tissues from experimental animals infected with HIV or HBV.
According to the concept of Universal Precautions, all human blood and certain human body fluids are treated as if known to be infectious for HIV, HBV, and other bloodborne pathogens." Therefore, blood and tissue must be handled in the same manner regardless of perceived or known risk.
In other words, treat all human blood as if it were infectious by using established exposure prevention protocols, such as wearing gloves and disinfecting contaminated surfaces.
