February 2011- Bloodborne Pathogens (BBP) & Tier II's

To whom does this standard apply?

The Bloodborne Pathogens Standard applies to all employees who may have occupational exposure to blood or other potentially infectious materials. Occupational exposure is defined as reasonably anticipated contact with blood or other potentially infectious materials that may result from the performance of an employee's duties.

What are the major diseases the Bloodborne Pathogens standard is concerned with?

The three most common bloodborne pathogens (BBPs) are human immunodeficiency virus (HIV), hepatitis B virus (HBV), and hepatitis C virus (HCV).

What is an Exposure Control Plan?

Employers who have employees with occupational exposure to BBPs are required to have a written Exposure Control Plan that is accessible to employees and is reviewed annually. The purpose of the plan is to eliminate or minimize employee exposure to bloodborne pathogens. The plan should include, but is not limited to, an exposure determination, schedule and methods of implementation, input from employees and procedures for exposure incidents. All elements that must be included in the plan are in OSHA’s BBP standard.

What kind of Safety Devices should we choose?

Employers should evaluate and implement use of medical devices with engineered sharps injury protections (safety devices). They should use only appropriate, effective, and commercially available safety devices. Front-line employees should be involved in the evaluation and selection process and this process should be documented annually.

Who needs the hepatitis B vaccination?

The employer must offer free hepatitis B vaccinations to all employees with occupational exposure to blood or other potentially infectious materials (OPIM).

What are other ways to control BBP hazards?

BBP hazards can be controlled in many ways such as ensuring employees comply with Universal Precautions, using engineering and work practice controls to eliminate or minimize employee exposure, providing and ensuring the use of appropriate personal protective equipment, and ensuring that contaminated sharps are disposed of in proper sharps disposal containers.

What if someone has an exposure?

The employer must have a procedure established for post-exposure evaluation and follow-up. The procedure should include, but not be limited to, documentation of the route of exposure and other circumstances, identification of the source individual where feasible and testing of that individual’s blood for BBPs where possible, and an offer of post-exposure medical evaluations at no cost to the employee.

What should employee training contain?

Employees who have occupational exposure to BBPs must be trained at initial assignment and at least annually by a knowledgeable person. Training must include a number of elements, such as:
• An accessible copy of the BBP standard (29 CFR 1910.1030)
• Information on the epidemiology and symptoms of bloodborne diseases
• Information on modes of transmission of BBPs
• Description of employer’s Exposure Control Plan and how to get a copy
• How to recognize tasks that may involve exposure to blood or OPIM
• Use and limitations of methods to reduce exposure, including engineering controls, work practices, and personal protective equipment
• Information on the hepatitis B vaccine
• What to do and whom to contact after an exposure
• Information on post-exposure evaluation and follow-up
• An opportunity for interactive questions and answers

More Information

OSHA Bloodborne Pathogens Standard
OSHA Bloodborne Pathogens and Needlestick Prevention

Do I need to file Tier II's before March 1st?

If you can answer “No” to any of the following questions then you may be in the clear:

Question #1: Do you do any one of the following; manufacture, use, store or process chemicals? (The simplified definition for “chemical”, pertaining to these regulations, is a product that you are required to maintain a MSDS. They include solids, liquids and gases.)

Question #2: Do you have chemicals contained within these products that contain any of the extremely hazardous chemical (EHS) list?

Question #3: Do any of these “Chemicals”, either by themselves or aggregated (based on your maximum amounts on any given day), meet or exceed the EHS Threshold Planning Quantities (TPQ) or 500 lbs.? (The only way that we can help you with this one is to screen for them.)

Note: Even if you answered “No” to either question 2 or 3 you still may have a requirement if you have any chemical that exceeds 10,000 lbs on hand any given day at you facility.

What are my state Tier II reporting requirements?

Every state has different reporting requirements.  For a complete list of instructions for what your state requires go here.

Upcoming EPA Deadlines

 Topic  Brief Overview  Deadline  Links
SARA Title III, 301-312
Emergency Planning and Community Right-to-Know Act (EPCRA)
Tier II reporting is a snapshot of a facilities hazardous materials storage activities. A report detailing the chemical and hazardous materials storage activities must be sent to the state and local authorities. SARA reports must be submitted for chemicals that meet the following criteria.

  • Extremely Hazardous Substances (EHS) in excess of 500 lbs or the listed Threshold Planning Quantity (TPQ) whichever is lower.
  • Hazardous substances in excess of 10,000 lbs.
Tier II Reports due March 1st of each year Laws and Regs

EPCRA – Local Emergency Planning Requirements

State Tier II Reporting Requirements

EPA Lists of Lists Home Page

E&SSG Solution
Annual / Biennial Haz Waste Reporting
Facilities generating hazardous waste must submit annual and biannual reports to the state. Reporting frequency varies by state. Annual Reporting
March 1 of every year
Biennial Reporting
March 1 of even numbered years covering generator activities for the previous year.

Basic Info

Guidance, Policy and Resources

RCRA Online Brochure

Training requirements question


Air Permitting (Title V Mj Source, Mn Source, Emissions Inventory Reporting)
Facilities that exceed specific emissions limits must apply for and maintain an air emissions permit. Annual reports are also required to report the emissions to the regulating authority (EPA, State or local depending on location).

Semi-annual reports and compliance certifications may also be required depending on your location and specific permit requirements.
Emissions reports due April 1st (will vary by state)

Semi-annual reports and compliance certifications typically due January 31st and July 31st. May vary by state.

State Environmental Agencies

Laws and Regs

Plain English Guide to Clean Air Act

Air Pollution Operating Permit Program: Key Features and Benefits

PDF of above

Who has to get a permit

EPA List of HAPs

E&SSG Solution

Storm Water Runoff Permit and Annual Inspection Report
Facilities must develop and implement a SWPPP to outline the procedures and equipment in place to prevent contaminants from getting into the run-off from storm water. A Storm Water permit must also be obtained from the state or local regulatory entity. Depending on your local regulations and SIC Code periodic reports may be required.
Annual Inspection Report due dates varies by state. Many states require them by March, 31st, however, some states are due by January, 31st.

Visual or analytical monitoring (typically quarterly -but some industries monthly)

Stormwater Discharges From Industrial Facilities

Annual Reporting Form

MSGP Industrial Discharge Monitoring Report (MDMR)

E&SSG Solution

Disclaimer: These Regulatory Reminders are not intended to be an exhaustive source for all of your particular facility’s compliance issues. They are designed to address the basics requirements with which most companies are required to comply. Following the Regulatory Reminder’s deadlines and Monthly Focus will not guarantee your compliance as these reminders are simply designed to help in your environmental/safety compliance efforts. You should always refer to the federal and your state’s regulations for all your requirements. Ultimately, your compliance with federal and state regulations is your responsibility. E&SSG assumes no liability for your compliance or the resources provided in these “Reminders”.

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