As you may well know, maintaining compliance within the Bloodborne Pathogens (BBP) standard continues to be the most troubling aspect of OSHA (76% of fines). Let’s not also forget about the ever-enjoyable Hazard Communication requirements, record keeping forms, recordkeeping summaries, personal protective equipment, and respiratory protection.

So without further ado, here are the top 10 most cited areas you will want to address:

  1. Failure to implement and maintain an Exposure Control Plan under the BBP standard.
  2. Failure to train under the BBP standard.
  3. Failure to follow proper hand washing protocol under the BBP standard.
  4. Poor housekeeping under the BBP standard.
  5. Failure to implement and maintain a written Hazard Communication Program.
  6. Failure to make the Hepatitis B vaccination available under the BBP standard.
  7. Failure to prepare Exposure Determinations under the BBP standard.
  8. Failure to use Personal Protective Equipment (PPE) under the BBP standard.
  9. Failure to provide post-exposure Hepatitis B vaccination under the BBP standard.
  10. Failure to train employees under the Hazard Communication standard

 So what do you need to do? First, know this. With OSHA it can seem impossible at times to be in compliance, but the worst thing you can do is give the impression you aren’t serious about this. If an OSHA inspector comes in and you can prove that due diligence is being done, the fine may be lowered or written off altogether. However, negligence makes them mad and OSHA inspectors aren’t typically gifted with a sense of humor.


  • Audit – You need to audit your practice and focus on the areas where non-compliance is most likely to occur, perhaps the list above or any other areas you may feel uncertain about.  Create an “audit policy” for your practice that states when internal and/or external audits are to be done.  Include how they are done, what is covered, who does them, etc.
  • Logs – review how your practice reports injuries.  Do you have your OSHA 300 logs and workers compensation records?  Are there any patterns to previous injuries that need to be addressed?  If any injuries occurred, was the risk that caused the injury mitigated if possible?
  • Training, training, training – Did I mention training?  It’s very important to have a training schedule for OSHA, especially pertaining to the BBP standard.  Always document any training you give or receive and have the employees sign off.   In fact, I would recommend writing a formal policy regarding OSHA training (frequency, duration, internal or external, specific subject matter, etc.)
  • SDS – do you have everything labeled?  Do you need more labels?
  • Common sense – It would be a good idea to conduct an occasional walk-through, putting yourself in an inspectors shoes.  Do you see any smoking guns?  Any obvious areas you may have overlooked?
  • Document – document everything.  Having written history of your actions offers a better defense and jogs the memory.

In conclusion, not all hazards can be eliminated. Taking the above steps and knowing the areas where medical practices tend to struggle will help minimize your exposure and potential risk. Always try to put yourself in an inspector’s shoes.

OSHA Compliance can be a daunting task. The California Medical Compliance (CMC) plan will assure that our training program will fully train the entire staff at your facilities. We are confident that our services will be invaluable to your entire organization.


For further details, call California Medical Compliance at:
310-890-5119  or  702-220-8621
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