Most required in-services in a nursing home come from CMS. Bloodborne pathogens is the big exception: it is an OSHA requirement, enforced separately, and it is one a surveyor or an OSHA inspector will check. Because it is annual and applies to so much of the staff, it is usually one of the first in-services a Director of Staff Development schedules. This guide lays out what the standard requires, with the citation attached.
An OSHA rule, not a CMS one (29 CFR 1910.1030)
The Bloodborne Pathogens standard, 29 CFR 1910.1030, is an OSHA regulation that protects employees from exposure to blood and other potentially infectious materials. It applies to any employer with employees who have occupational exposure — which a nursing home clearly does. It sits alongside, but is separate from, the CMS infection-control training rule; see our infection prevention training guide for the CMS side.
Who, and how often
- Who: every employee with occupational exposure — in a facility, most direct-care staff plus others (housekeeping, laundry, maintenance) who may contact blood or soiled items;
- When: at the time of initial assignment, then at least annually (within one year of the last session), and again whenever a change in tasks or procedures affects exposure.
What the training must cover (§ 1910.1030(g)(2))
OSHA is specific about content. A compliant bloodborne pathogens in-service includes:
- An accessible copy of the standard and an explanation of it;
- The epidemiology, symptoms and transmission of bloodborne diseases;
- The facility’s Exposure Control Plan and how to access it;
- Engineering controls, work practices and PPE — their use, limits, and how to put on, take off, handle and dispose of PPE;
- The Hepatitis B vaccine — its efficacy, safety, and free availability;
- Emergency and exposure-incident procedures, including reporting and the post-exposure evaluation and follow-up;
- Signs, labels and color-coding; and
- An interactive question-and-answer session with the person conducting the training.
The Exposure Control Plan (§ 1910.1030(c))
The Hepatitis B vaccine offer
Separate from training, the employer must make the Hepatitis B vaccination series available free of charge, within 10 working days of initial assignment to every employee with occupational exposure. An employee may decline by signing OSHA’s declination statement — and may change their mind and accept the vaccine later at no cost. Tracking who was offered, who accepted, and who declined is part of the record.
California: Cal/OSHA § 5193
California runs its own OSHA program, and its bloodborne pathogens standard — 8 CCR § 5193 — mirrors the federal rule and in places goes further (notably on sharps-injury protections and the sharps injury log). A California nursing home follows § 5193; the training and Exposure Control Plan requirements are equivalent in structure. Confirm the current text, which Cal/OSHA maintains.
Documenting it so it survives inspection
OSHA requires training records that include the dates, contents, the trainer’s name and qualifications, and the names and job titles of attendees — kept for three years. As with every in-service, if it is not documented, it did not happen — and here the auditor may be OSHA, not just CMS.
Putting it together
- Maintain a written Exposure Control Plan, reviewed annually (§ 1910.1030(c)).
- Train every employee with occupational exposure at hire and annually (§ 1910.1030(g)(2)).
- Offer the Hepatitis B vaccine free within 10 working days.
- In California, follow Cal/OSHA § 5193, including the sharps injury log.
- Document training and keep the records three years.
Running that annual in-service and keeping the records is the Director of Staff Development’s job. Our DSD certification course teaches you to build and document a compliant training program from the regulation up; see also the full in-service topic list and infection prevention training.
Frequently asked questions
Is bloodborne pathogens training required in nursing homes?
Yes — by OSHA, not CMS. The Bloodborne Pathogens standard, 29 CFR 1910.1030, requires the employer to train every employee with occupational exposure to blood or other potentially infectious materials, at the time of initial assignment and at least annually thereafter.
How often is bloodborne pathogens training required?
At initial assignment to a job with occupational exposure, then at least once a year (within one year of the previous session), and again whenever tasks or procedures change in a way that affects exposure. Annual is the floor for most nursing-home staff.
Who has to be trained?
Every employee with occupational exposure — anyone whose job can reasonably be expected to bring them into contact with blood or other potentially infectious materials. In a nursing home that is most direct-care staff (nurses, aides) and others such as housekeeping and laundry who handle soiled items.
What must the training cover?
Per 1910.1030(g)(2): the standard itself; the epidemiology, symptoms and transmission of bloodborne diseases; the facility’s Exposure Control Plan; engineering controls, work practices and PPE (use, limits, and how to don/doff and dispose of it); the Hepatitis B vaccine; what to do in an emergency or after an exposure incident; labels and color-coding; and an interactive question-and-answer session with the trainer.
What is the Exposure Control Plan?
A written plan (1910.1030(c)) designed to eliminate or minimize employee exposure. It must be reviewed and updated at least annually — and whenever tasks change — and must document that the facility considered safer medical devices (e.g. safety-engineered sharps) that year.
Does the facility have to offer the Hepatitis B vaccine?
Yes. The Hepatitis B vaccination series must be made available free of charge, within 10 working days of initial assignment, to every employee with occupational exposure. An employee may decline by signing the standard declination statement, and may accept later at any time.
Does California have its own rule?
Yes. California is a state-plan state: Cal/OSHA’s bloodborne pathogens standard, 8 CCR § 5193, mirrors and in places exceeds the federal rule (for example on sharps injury protections). California nursing homes follow § 5193 — confirm the current text, which Cal/OSHA maintains.
Where can I get a bloodborne pathogens lesson plan?
Our In-Service Lesson-Plan Library includes a bloodborne pathogens / infection-control in-service — a CDPH-278 lesson plan, a handout, a quiz with an answer key and a slide deck — that you can teach or brand to your own Exposure Control Plan.