Bloodborne Pathogens Policy

Bloodborne Pathogens training is required annually for all faculty, staff, and students who work with bloodborne pathogens or human source material in a laboratory or clinical setting.  Bloodborne diseases, risk assessment, recommended work practices, engineering controls and personal protection as well as an update of waste disposal and emergency procedures are discussed. Web based training is available through Workday Learning. 

Due to your occupational exposure to blood and other potentially infectious materials, you may be at risk of acquiring hepatitis B virus (HBV) infection. Hepatitis B vaccination is available to you at no charge from Occupational Medicine. To request a vaccine, fill out the Hepatitis B Vaccination Request Form. Additionally, request a Letter of Authorization from your Business Administrator which includes your name and outlines a list of authorized services. Send the letter to Tim McInnes, MHA, Practice Administrator at OccupationalMedicine@pennmedicine.upenn.edu to schedule an appointment. Once services have been rendered, Occupational Medicine will issue an invoice to your Business Administrator. 

If you have any additional questions about the Hepatitis B Vaccination, please contact EHRS at 215-898-4453.

All Penn faculty, staff and students in clinical, research, and non-research areas who may reasonably anticipate occupational exposure to human bloodborne pathogens (BBP) or other potentially infectious materials (OPIM) must comply with the OSHA Bloodborne Pathogen Standard.

All research personnel who have the potential to be exposed to BBP or human source material, including primary and established cell lines, blood products, body fluids, and tissue must have a lab-specific ECP on file with EHRS.

Non-research personnel may include, but are not limited to individuals working within: Department of Recreation, Facilities & Real Estate Services, Housekeeping staff, Intercollegiate Athletics, Penn Children’s Center, and University of Pennsylvania Police Department, Clinical Research, and Dental Clinics.

In addition to annual training, each group must have on file a site-specific, BBP, Exposure Control Plan (ECP) that is available on demand.  The University of Pennsylvania Bloodborne Pathogen Exposure Control Plan (ECP) is provided as a customizable template to assist you in creating this site-specific compliance document. Your ECP must be updated annually, reviewed and signed by all who are listed in the ECP.

In order to fill out the Exposure Control Plan form, save the pdf to your desktop. Make sure that the signature page (page 2) and Appendix C (pages 20-22) have been completed (if questions do not apply, please make sure to put N/A).  For guidance filling out Appendix C of the Exposure Control Plan, please refer to Penn's Biosafety Manual or contact a biosafety officer: biohazreg@ehrs.upenn.edu.

For resubmissions, if there are no changes, submit last year's plan with a current date and an updated signature page. Follow these instructions for submission:

• Non-research personnel: Please email a PDF of your completed ECP to ehrs@ehrs.upenn.edu.
• Research labs: PIs and LSCs can upload ECPs directly to the lab's "Documents" section in BioRAFT. Upload the document as a "general" file type using the suggested naming convention "Lab Name_ECP_Date of Signatures." The document will be available to all personnel listed in the "Lab Members" section of the lab's profile.