One needlestick. One untrained employee. One OSHA citation and a 6-month post-exposure protocol.

Any employee with occupational exposure risk must complete training annually under OSHA 29 CFR 1910.1030. Occupational exposure means a reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials. Clinical staff, dental staff, lab technicians, surgical techs, and phlebotomists are the core audience. Unlike HIPAA, this annual requirement is mandated by federal law - there is no ambiguity on frequency.

An exposure control plan (ECP) is a written document required by OSHA that must identify all exposed job classifications and describe compliance methods. It must cover engineering controls (safety needles, sharps containers), work practice controls, PPE requirements, hepatitis B vaccination policy, and post-exposure evaluation procedures. The plan must be reviewed annually and whenever new tasks or procedures are introduced. Employees must have access to the plan at all times.

OSHA requires Bloodborne Pathogens training at initial assignment and at least annually thereafter. Additional training is required when new exposure risks are identified or new procedures are introduced. Unlike HIPAA, this is a hard annual legal requirement under 29 CFR 1910.1030(g)(2)(ii)(A). The training must also be interactive - employees must have the opportunity to ask questions of a knowledgeable person.

Immediately wash the wound thoroughly, report the incident to your employer, and begin the post-exposure evaluation process. The employer must provide a confidential medical evaluation at no cost to the employee, including documentation of the route of exposure, identification of the source individual if possible, and testing with appropriate counseling. The evaluation must be performed by a licensed healthcare professional. Employees have confidentiality protections throughout the process.