Published by Houlton Medical Office Cleaning | (866) 958-8773
OSHA's Bloodborne Pathogens Standard (29 CFR 1910.1030) applies to any employee who may reasonably be expected to encounter blood or other potentially infectious materials (OPIM) in the course of their work. That includes cleaning crews working in medical and dental facilities. If you hire a cleaning contractor for your clinic, the standard's requirements follow them into your building.
A cleaning contractor working in a clinical facility must have an Exposure Control Plan that identifies employees with potential exposure, documents the protective measures in place, and is updated annually. Training on bloodborne pathogen risks, routes of transmission, and proper handling procedures must be provided to exposed employees annually and when they are initially assigned to covered tasks. Personal protective equipment — gloves at minimum, eye protection and gowns where splash risk exists — must be provided at no cost to the employee.
Practices that hire cleaning contractors are not automatically responsible for the contractor's compliance with these requirements, but they do have an obligation to inform contractors of potential exposure hazards in the facility. A cleaning company that does not ask about OPIM exposure risks before sending crews into your exam rooms is not meeting its standard of care.
Regulated medical waste — sharps, contaminated materials, pathological waste — is subject to its own disposal requirements and is handled by licensed waste haulers, not cleaning crews. The cleaning contractor's scope adjacent to regulated waste containers is limited to disinfecting the external surfaces of those containers and the surrounding floor area. A cleaning crew should never be asked to handle, transport, or dispose of sharps or regulated waste containers. If your scope of work or verbal instructions suggest they should, that is a compliance problem.
A contractor who cannot answer these questions in plain terms is not a contractor who should be in your clinical space, regardless of price.
OSHA requires medical records for employees with exposure incidents and training records for bloodborne pathogen training. These records must be retained for the duration of employment plus 30 years (medical records) or three years (training records). As the facility operator, you do not hold the contractor's records — but you should be able to confirm they maintain them.
If your practice is subject to periodic inspection by a licensing board or accrediting organization, the cleaning contractor's compliance posture can be part of your inspection readiness. A written scope of work that documents disinfection protocols and product specifications is useful evidence during such reviews.