Post-Exposure Evaluation and Follow-up
A post-exposure evaluation and follow-up is a critical step in protecting the health of an employee who may have been exposed to bloodborne pathogens (BBPs), such as HIV, HBV, or HCV. OSHA’s Bloodborne Pathogens Standard (29 CFR 1910.1030(f)(3)) mandates that employers respond immediately and thoroughly to any exposure incident.
An exposure incident is defined as:
A specific eye, mouth, other mucous membrane, non-intact skin, or parenteral contact (e.g., needlestick, puncture, cut) with blood or other potentially infectious materials (OPIM) that results from the performance of an employee’s duties.
Immediate Employee Actions After an Exposure
- Clean the Affected Area Immediately
- Skin exposure: Wash the area with soap and water for several minutes.
- Eye exposure: Rinse with clean water or saline for at least 15 minutes.
- Mouth/nose exposure: Rinse with water and spit several times without swallowing.
- Puncture wounds: Encourage bleeding, then wash thoroughly.
- Remove Contaminated PPE and Clothing
- Place any contaminated items in a designated biohazard bag or labeled container.
- Report the Incident Immediately
- Notify a supervisor or designated safety contact as soon as possible.
- Prompt reporting ensures timely medical evaluation, exposure tracking, and regulatory compliance.
Employer Responsibilities After an Exposure
Once an exposure incident is reported, the employer must act immediately to initiate a formal evaluation and follow-up:
- Provide a Confidential Medical Evaluation and Follow-up
This must include:
- Documentation of the exposure incident, including:
- The route(s) of exposure
- Circumstances under which the exposure occurred
- Identification and testing of the source individual, if consent is obtained (or required by law)
- Testing of the exposed employee, including baseline blood collection and testing for
- HBV, HCV, and HIV (with employee consent)
- Post-exposure prophylaxis (PEP) when medically indicated, initiated as soon as possible (ideally within hours)
- Counseling and psychological support
- Evaluation of reported illnesses during the follow-up period
This process must be conducted by or under the supervision of a licensed healthcare professional.
Provide Medical Care at No Cost
- All evaluations, testing, counseling, and follow-up procedures must be provided at no cost to the employee, and during normal working hours.
- No cost-sharing, insurance billing, or deductibles may be required.
Documentation Requirements
Employers must maintain a confidential medical record for each exposed employee that includes:
- Name and social security number
- A copy of the employee’s HBV vaccination status
- Documentation of the exposure incident
- All examination findings, test results, medical opinions, and treatment records
- Signed declinations, if applicable
These records must be:
- Kept confidential
- Not disclosed or reported to anyone without the employee’s written consent (except as required by law)
- Maintained for the duration of employment plus 30 years, per OSHA 1910.1020
Written Opinion from Healthcare Provider
The employer must obtain a written opinion from the evaluating healthcare professional within 15 days of the completion of the evaluation. This opinion must be limited to:
- Whether the employee has been informed of the results
- Whether the employee has been told about any medical conditions resulting from exposure that require further evaluation or treatment
The opinion must not include any personal medical findings or diagnoses.
Importance of Timeliness
The faster an exposure is reported and treated, the greater the likelihood of preventing infection:
- Post-exposure prophylaxis (PEP) for HIV must begin within hours to be effective.
- Baseline testing provides a reference point to track infection status over time.
- Early counseling reduces anxiety and improves adherence to follow-up care.
Summary
Post-exposure follow-up is a cornerstone of BBP protection. It ensures:
- Immediate care and support for exposed workers
- Long-term monitoring for infections
- Legal compliance for employers
- Strong workplace safety culture
Every employee must understand the importance of rapid reporting and proper post-exposure procedures, because every minute counts.