Bloodborne Pathogen Standard Control Plan

Bloodborne Control Plan

We have recently reviewed the OSHA Bloodborne Pathogen Standard basics, about who is covered and what entails an exposure. A control plan must be in place in order to reduce the chance of such bloodborne pathogen exposures in the workplace, which is certainly a possibility in any health and fitness center. Read more about what is required about controlling exposures, decontaminating equipment after an exposure, and maintaining cleanliness.

Exposure Control Plan

The exposure control plan may be part of another document, such as the facility’s health and safety manual, as long as all components are included. In order for the plan to be accessible to employees, it must be a cohesive entity by itself or there must be a guiding document that states the overall policy and goals and references the elements of the existing separate policies that comprise the plan. For small facilities the plan’s schedule and method of implementation of the standard may be an annotated copy of the final standard that states on the document when and how the provisions of the standard will be implemented. Larger facilities could develop a broad facility program, incorporating provisions from the standard that apply to their establishments.

Exposure Control Plan elements

  • Exposure Determination
  • Implementation methods and Controls
  • Hepatitis B vaccine
  • Post-exposure Evaluation and Follow-up
  • Communication of Hazards to Employees
  • Record Keeping
  • Annual Review
  • Location of the Exposure Control Plan

Review of Exposure Control Plan

The standard requires an annual review of the exposure control plan. In addition, whenever changes in tasks, procedures, or employee positions affect or create new occupational exposure, the existing plan must be reviewed and updated accordingly.

The exposure control plan must be accessible to employees, as well as to OSHA and NIOSH representatives. The location of the plan may be adapted to the circumstances of a particular workplace, provided that the employees can access a copy at the workplace during the worksheet. If the plan is maintained solely on a computer, employees must be trained to operate the computer.

Contaminated Equipment

The standard requires that all equipment that may be contaminated must be examined and decontaminated as necessary prior to servicing or shipping. If complete decontamination is not feasible, the equipment must be labeled with the required biohazard label which also specifically identifies which portions of the equipment remain contaminated. In addition, the employer must ensure that this information is conveyed to the affected employees, the servicing representative, and/or the manufacturer, as appropriate, prior to handling, servicing, or shipping.


EPA (Environmental Protection Agency) registered tuberculocidal disinfectants are appropriate for cleaning blood or OPIM. A solution of 5.25 percent sodium hypochlorite, (household bleach), diluted between 1:10 and 1:100 with water, is also acceptable for cleaning contaminated surfaces.

Quaternary ammonium products are appropriate for use in general housekeeping procedures that do not involve the cleanup of contaminated items or surfaces.

The particular disinfectant used, as well as the frequency with which it is used, will depend upon the circumstances in which the given housekeeping task occurs (i.e., location within the facility, type of surface to be cleaned, type of soil present, and tasks and procedures being performed). The employer’s written schedule for cleaning and decontamination should identify such specifics on a task-by-task basis.


Fitness Centers that lease their facility to CPTs should require the lessees be trained in CPR/AED, be required to render first aid and know the substantive requirements of the OSHA’s Bloodborne Pathogen Standard. This includes, but is not limited to: what entails an exposure incident, availability of personal protective equipment, physical placement of the Facility’s Exposure Control Plan, and location of registered tuberculocidal disinfectants are appropriate for cleaning blood or OPIM.

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Dr. Brancato’s cumulative experience in nutrition, alternative medicine, chemistry, toxicology, physiology directed him to holistic approaches in human physiology to correct system imbalances. He maintains his professional certifications as a Naturopath from the American Naturopathic Medical Certification and Accreditation Board; the National Federation of Professional Trainers; Black belts in Kick Boxing and Kenpo.
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