Bloodborne Pathogens

“Do I need a bloodborne pathogens (BBP) program for my construction company?”

Of course, the answer depends, . But, OSHA does have a letter of interpretation.bloodborne kit

The basics are: do your employees have DAILY exposure (anticipated exposure) to blood, or blood containing substances? Further defined as; “today we are going to pick up these bloody needles. Or, “this afternoon we are going into this live sewer, which is coming from the treatment plant”.

Here is OSHA Bloodborne construction letter of interp, but interpret the letter of interpretation yourself. 🙂

“…while the bloodborne pathogens standard does not apply to construction work, as defined in 29 CFR 1910.12(b), it does apply to employees performing maintenance activities who experience occupational exposure to blood or other potentially infectious materials. OSHA expects the construction employer performing maintenance activities to take the following precautions as required by the following referenced standards: Section 29 CFR 1926.21(b)(2) requires that the employer instruct each employee in the recognition and avoidance of unsafe condition…”

In summary, most construction firms do NOT need a full blown bloodborne pathogen program. However, you should still train your employees on the hazards they might incur. This might include the hazards of bloodborne pathogens. There may be a time and project where they wished they had the training.


I regret I don’t have the energy to post every question and situation on this site.

However, occasionally there are very unique questions. I won’t say how I answered them, but I will offer some considerations. Here’s are my two favorites from the recent past:

  1. My construction crew is working on a “special TI (tenant improvement)”, alongside an elephant who has Turberculosis (TB). What personal protective equipment (PPE) do my workers need to wear?
    • Is the TB active
    • Does TB transfer from people to animal, and/or vice versa
    • How much contact (distance, time, amount of touching, etc) will the workers have with animal?
    • Will you offer prophylactic shots? (to the employees, of course)
  1. We are going to be excavating the carcasses of dead sheep. What type of PPE will my excavator operators need to wear while performing these tasks?
    • How large of an area (2-3 football fields)
    • How long have the carcasses been in this area
    • Any additives to the soil/area
    • Will workers be in contact with dead animals?
    • Will workers need to enter the excavation?
    • Will you use a multigas meter (4 gas)?


I’d love to hear your best (or worst) questions.

Construction and exposure to Hepatitis B (or C or HIV) doesn’t arise very often since construction workers are usually not around blood, bodily fluids, or patients. There are times when construction must occur at wastewater treatment facilities, municipals, or in active sewers. Occasionally exposure can come from illegal drug use or the remnants of it (think of a project underneath a downtown bridge).

Currently there is not a specific rule for bloodborne pathogens in construction (1926). However, if it is reasonably anticipated that an employee might have exposure, you should take precaution.

What are the dangers? First, you must have occupational exposure to skin, eye, or mucous membrane with contact to blood or infected material.  Exposure may then cause the employee the diseases of Hepatitis B, C and HIV. Occasionally construction companies want to know if they need to offer their employees the Hep B vaccine.

The real-threat is contact with blood. Here is a question to ask… Do you anticipate seeing any blood on the jobsite? If the answer is NO…then you probably are under what is called the COLLATERAL DUTY clause. In this case, the hepatitis B vaccination does not need to be given…until the presence of blood. Once this happens (and employees must be trained beforehand) you have certain steps to take in order to offer the Hep B vaccination. Oregon OSHA (and others) have adopted this stance.

If you have probable exposures you must:

  • make an exposure control plan
  • train your employees
  • universal precautions – google it…there’s a lot to know
  • protect your employees (engineering controls, work practices)
  • housekeeping – cleanup
  • label
  • keep records

Oregon OSHA has some good info here.