OSHA's Bloodborne Pathogen Standard — what it requires from your cleaning contractor
OSHA's Bloodborne Pathogen Standard (29 CFR 1910.1030) applies to employees who have occupational exposure to blood or other potentially infectious materials. Cleaning staff working in medical offices, dental practices, and clinical facilities fall under this standard — and the medical practice is responsible for ensuring that any contractor working on their premises is compliant.
Most practice managers know they need an insured cleaner. Fewer know they are responsible for confirming that the cleaning contractor's employees have received OSHA-mandated bloodborne pathogen training, have access to personal protective equipment, and follow the required exposure control procedures. A cleaning contractor whose staff haven't had this training is a liability exposure for your practice, not just for the contractor.
What the standard requires from cleaning staff
Under the standard, employees with potential occupational exposure must receive training that includes:
- How bloodborne pathogens are transmitted and which diseases are of concern
- The employer's exposure control plan and how to locate it
- Use of engineering controls, work practices, and personal protective equipment
- Procedures for handling and disposing of regulated waste
- How to respond to an exposure incident
This training must be provided at the time of initial assignment, annually thereafter, and when tasks or procedures affecting occupational exposure change. The training must be specific enough to apply to the tasks the employee actually performs — a general safety video doesn't satisfy the standard for a cleaning crew entering a procedure room.
Personal protective equipment requirements
Cleaning staff in clinical areas must have appropriate PPE available and must use it when exposure is reasonably anticipated. For a cleaner working in an exam room that has seen patients that day, that anticipation is reasonable. At minimum this means gloves; in procedure rooms or where blood or body fluid is visible, it means gloves, eye protection, and potentially a gown.
The employer (your cleaning contractor) must provide this equipment at no cost to the employee, ensure it fits, and have procedures in place when equipment is damaged or malfunctioning. A cleaner bringing their own gloves from home does not satisfy the standard.
Regulated waste handling
Regulated medical waste — including sharps, contaminated materials, and blood-soaked items — must be handled according to specific OSHA and Wisconsin DNR requirements. Cleaning staff should not be emptying sharps containers or handling regulated waste containers; that handling is the clinical team's responsibility. But a cleaning contractor whose crew doesn't know the difference between a regulated waste bin and a regular trash can is a compliance problem.
What to ask your cleaning contractor
When evaluating a cleaning contractor for a medical facility in Roberts or the surrounding area, ask specifically:
- Do your employees receive OSHA bloodborne pathogen training before working in medical facilities?
- How frequently is that training refreshed?
- Do your crews carry their own PPE, or is it provided by the contractor?
- What is your exposure incident protocol?
- Have any of your employees in this region had a reportable exposure in the past two years?
A contractor who can't answer these questions directly isn't the right choice for a clinical facility, regardless of price.