Tip: When documenting a bloodborne pathogen exposure incident, do not forget to document the circumstances surrounding the incident. This is not only required by the Standard, it helps to determine if policy was being followed and what might need to be changed.
Documentation must include:
- Engineering controls and work practices in use at the time of the incident
- A description of the device being used, including type and brand
- Protective equipment being worn at the time
- Location and procedure being performed when the incident occurred
- Employee’s training status at the time of the incident
Tip: Your bloodborne pathogen training documentation form must include:
- Dates of the training sessions
- Contents or a summary of the training sessions
- Names and qualifications of persons conducting the training
- Names and job titles of all persons attending the training sessions
Tip: Be sure to note in your Bloodborne Pathogens exposure control plan the date of its annual review and update. Even if there are no changes, you must review the plan and document that you have done so.
Tip: Do not make your bloodborne pathogens exposure control plan too specific. Even if your employees are following what OSHA says is OK, if your policy manual says something else, you may be fined. For example, do not designate the brand name of surface disinfectant you are currently using. Instead, state that you are using an EPA-registered tuberculocidal surface disinfectant. Then if you change brands in the middle of the year, you are still following your policy. (Hint: Make sure your disinfectant is EPA registered to kill Tb.)
Tip: Remember, training on the Bloodborne Pathogens Standard is required BEFORE a new employee begins any exposure potential tasks and one year from that employee’s training. If employees are to be trained annually as a group, be sure no employee goes over a year since her/his last training.
Tip: In addition to maintaining employee safety training sign-in sheets, tests, and certificates of completion, always keep a copy of the training content (training outline or a copy of the slides). This proves what training was actually provided. It is also a good idea to keep a copy of any outside trainer credentials/qualifications, as this is required by the Bloodborne Pathogens Standard. Maintain all these documents for at least three years from the date of training.