Does Cal/OSHA's Bloodborne Pathogens Rule Cover Janitors?

When does section 5193 apply to cleaning staff?

The test is reasonable anticipation, not job title. The standard defines occupational exposure as reasonably anticipated skin, eye, mucous membrane or parenteral contact with blood or other potentially infectious materials that results from an employee's duties. A cleaner who wipes exam tables, empties clinic trash or responds to blood spills meets that test.

Office janitors are a closer call. A crew that only cleans general offices may have no anticipated exposure, but the picture changes if the contract assigns them to clean up blood, if restroom trash in a public building regularly contains needles, or if they serve a medical suite inside the office building. The employer's exposure determination should list each job classification and the tasks that create exposure.

What does the cleaning contractor owe covered employees?

The employer of the cleaners carries the core duties, and on a contracted crew that employer is the cleaning company. The main obligations, and where they sit in the standard, are below.

Which cleaning tasks create exposure in a clinic?

The riskiest moments are the ones where a cleaner cannot see what they are touching. Trash compressed by hand, a liner pulled tight against the body and a reach into a bin to retrieve something dropped are the classic needlestick scenarios.

• Emptying exam room and procedure room trash that may hold misplaced sharps
• Wiping exam tables, chairs, counters and blood draw stations
• Cleaning patient restrooms, including specimen pass-throughs
• Responding to spills of blood or body fluids that contain blood
• Picking up broken glass in labs, which the standard bars doing by hand
• Cleaning floors and surfaces around sharps containers and biohazard bins

Who is responsible on a shared site: the clinic or the contractor?

Both, in different ways. The cleaning contractor owns the exposure control plan, training, vaccination and medical follow-up for its own employees. The clinic controls the site: where sharps containers sit, whether clinical staff segregate regulated waste properly, which rooms the crew may enter and how the crew learns about site-specific risks.

Cal/OSHA's multi-employer worksite rule, Title 8 section 336.10, allows citations against an employer that creates a hazard, exposes employees to it, is responsible for correcting it or controls the worksite. A clinic that lets sharps end up in regular trash can share responsibility for a contractor's needlestick. The practical fix is a short written agreement on waste handling, spill response and exposure incident reporting.

What to ask your cleaning contractor for

A clinic does not need to see employees' medical files and should not ask for them, since those records are confidential. It does need evidence that the program exists and reaches the people who clean its rooms.

• Confirmation that the exposure control plan covers your site and its cleaning tasks
• Training dates for the cleaners assigned to your building
• Confirmation that hepatitis B vaccination is offered, without individual medical records
• The procedure after a needlestick or splash, including who at the clinic is told
• The protective equipment the crew carries and where spill kits are stored
• The disinfectant used on blood spills, with its EPA registration number and contact time
• The rule for sharps found outside a container: stop, do not touch, report

How EBS cleans clinical spaces

EBS cleans medical offices and clinics using EPA-approved disinfection products on high-touch surfaces, and restricted rooms, waste handling and spill procedures are agreed at the walkthrough so crews never improvise in clinical areas. Team members are trained before a site assignment and are vetted, uniformed and background-checked. Supervisors check clinical rooms during routine inspections and log any corrective action, and the clinic has one contact for questions about the program.