Do Cleaning and Custodial Staff Need Bloodborne Pathogens Training?

If you've ever been sent on training about blood safety, you'll have noticed that all the pictures are of hospitals. Gloves in a treatment room, a nurse, a needle, a ward. It's a reasonable thing to sit through and conclude that none of it's about you, because you clean offices.

The rules weren't written about hospitals, though. They were written about blood — and about who is expected to deal with it, which in most buildings is the cleaning crew.

Cleaning offices, cleaning blood

Sometimes, and the thing it depends on isn't the one people expect. It isn't whether the building is medical, and it isn't whether anybody has been ill. It's whether dealing with blood is a reasonably anticipated part of the job you've been given.

In practice the crews most often covered are the ones working somewhere blood turns up predictably: schools and colleges, gyms and rec centers, medical and dental practices, care settings, correctional facilities, transit, and anywhere with a first-aid room and a regular flow of people through it. If your contract includes being called when there has been an accident, that's the answer.

And if the answer has always seemed obviously no, that isn't carelessness. Everything you'd ever seen about this training — every poster, every course photo — told you it was about hospitals.

Assigned to it, or just standing there?

This is the boundary that catches people, and it's worth understanding because it changes what you're owed rather than only what you should do.

Cleaning up a spill as part of your job is covered work, and everything in the next section follows from it. Stepping in to help at an incident outside your assigned duties — going to somebody who has fallen in the parking lot, say — is generally treated differently, and a good-Samaritan act of that kind is generally not covered by the standard.

It's a real distinction and it's a narrow one, so it's worth being careful with it in both directions. It doesn't mean helping is discouraged, and it doesn't mean an employer who routinely relies on you to deal with blood can call that helping out. If it happens regularly and everybody expects it of you, that's the job — whatever it says in the contract.

Who you tell

Every covered employer has a written plan, and that plan names a specific person to contact when someone encounters blood or is exposed. Knowing who that is, before anything happens, is most of what this lesson is for.

It matters because the moment you need them is the worst moment to find out nobody knows. If you get stuck by something in a bag at nine in the evening, the useful thing is a name and a number — not a search through a folder in an office that's locked.

And if you ask who it's and nobody can tell you, you've found a problem that isn't yours. A plan that can't be produced when asked for is, in every way that affects you, a plan that doesn't exist. That's worth raising as a question rather than filing away as an oddity. What happens after you report — the evaluation, the testing, the follow-up — is a process you're entitled to, and it starts with telling somebody.

What your employer has to give you

If your work is covered, this is a list of things you're owed rather than a list of rules you've to keep. The distinction is worth holding on to, because this is an industry where people are more often given too little than asked for too much.

• Training when you start, and at least once a year after that — at no cost to you and during working hours.

• Protective equipment provided at no cost, in a size that fits and accessible where the work is, then cleaned, repaired or replaced as needed. What you should be given depends on the task.

• The hepatitis B vaccine, offered at no cost — within 10 working days of being assigned to covered work. You can decline, and you can change your mind later and still receive it at no cost.

• The written plan, available for you to read.

• A confidential medical evaluation and follow-up if you're ever exposed — also at no cost.

None of that's a favor and none of it comes out of your pay. The full set of obligations is longer, but those five are the ones that show up in a cleaning crew's working life.

If an agency placed you

Here is the question this audience has that almost nothing written on the subject answers: if an agency employs you and you work at a client's site, who is "your employer" for the purposes of all of the above?

The short answer is that it usually involves both, and the arrangement is a shared responsibility rather than a handover. The division that holds most reliably is this one: whatever is specific to the site you're working in belongs to the business that runs it — site-specific training, the exposure control plan you work under, and the protective equipment for the tasks you're given there. Your agency remains your employer for the general obligations that travel with you.

Beyond that the details get genuinely intricate, and this page isn't going to pretend otherwise — a confident division of duties written here would be more likely to send you to the wrong party than to help. Ask both, in writing if you can, and take your state or federal occupational-safety agency as the authority on how the responsibility actually splits in your arrangement.

What is worth knowing is the practical failure it produces. When two organizations each assume the other has handled it, the result is a worker who gets neither — no training from the agency because you work at the site, and none from the site because you're the agency's. If you're placed, ask both, and treat "that will be the other one" as an answer that needs following up rather than one that settles anything. Your state or federal occupational-safety agency can tell you how the duties actually divide.

What this job puts you near

Most bloodborne material assumes you're the person holding the needle. Cleaning work has its own exposures, and they aren't the ones in the pictures.

• What is in the bag — needles, blades, broken glass, and no way to know from the outside. A trash bag isn't a barrier and never was.

• Never compress a bag to fit more in. Pressing down with a hand or a knee is how people get stuck by something they couldn't see, and it's the single most avoidable injury in this work.

• Carrying bags against your body — hold them away from you, by the neck, not hugged to your side.

• Restrooms, changing rooms and first-aid rooms, where discarded dressings and sharps turn up in ordinary trash cans.

• Spills nobody reported. You often arrive after the event with no idea what happened, which is the normal case rather than the exception — and the reason the precautions don't depend on knowing.

The spill itself

There's a right way to clean up blood, and it's a procedure worth reading before you need it rather than something to work out at the time.

The one thing that belongs here rather than there's about what you're owed, not about technique: don't start until you've what you need. If there's no kit, no gloves in your size, or nothing to put the waste in, that's a stop — not a prompt to improvise with what is on the cart. Being asked to do covered work without the equipment for it's exactly the gap the previous sections are about, and improvising quietly is what allows it to continue.

Put it into practice

Training scenario:

You clean a college campus on an evening shift. Crossing the parking lot between buildings, you come across a student sitting on the curb with a badly cut hand and blood on the asphalt beside him. You aren't on a call-out and nobody has asked you to do anything; you have a cart with you because you were on your way to the next block. Your first-aid trained supervisor is somewhere in the science building and you have a radio.

Walking it through:

Two different questions are tangled together here and they have different answers. What you should do isn't in doubt: get help on the radio, keep other people back, and if you help him directly, use gloves — helping isn't discouraged by any of this and never was.

Whether it's covered work is a different question, and this is close to the boundary. Nobody assigned it, you were passing, and stepping in on your own initiative looks like the good-Samaritan case. Cleaning the asphalt afterward, if that gets radioed in as a job, doesn't — that's assigned work, and everything in this lesson applies to it.

The practical upshot is the bit worth taking away. Do not let the ambiguity stop you doing the sensible thing — but do report it afterward, including if anything reached your skin, and don't accept "you weren't supposed to be doing that anyway" as an answer if it did. And if you find yourself in this position regularly — passing, being nearest, dealing with it because you're there — then it has stopped being a good-Samaritan act and become part of the job, which means the training, the equipment and the vaccine come with it.