Bloodborne Pathogens in Canada — Risks, Rules & Worker Protection

Bloodborne pathogens (BBP) are infectious microorganisms carried in human blood that can cause serious disease if they enter another person's body. In Canadian workplaces, the three of primary concern are hepatitis B (HBV), hepatitis C (HCV) and HIV 1. They spread through direct contact with infected blood or certain body fluids: a needlestick, a splash to the eyes, nose or mouth, or contact with broken skin. They do not spread through the air, through coughing or sneezing, or through casual contact 2. Canada has no single “bloodborne pathogens standard” the way the United States does. Instead, protection comes from federal and provincial occupational health and safety law. This guide explains the risks, how exposure actually happens, the rules that apply across Canada, and who needs training.

What are bloodborne pathogens?

Bloodborne pathogens are infectious microorganisms carried in human blood and certain other body fluids that can cause disease in people. In Canadian workplaces the bloodborne pathogens of primary concern are hepatitis B (HBV), hepatitis C (HCV) and HIV 1.

What are the types of bloodborne pathogens?

These three types of bloodborne pathogens behave differently, and the protection available for each is different:

• Hepatitis B (HBV) attacks the liver. It is the most readily transmitted of the three through occupational blood exposure, and it is the only one of the three with a vaccine — 90 to 95 per cent of healthy people who are vaccinated develop resistance to it 5.
• Hepatitis C (HCV) also attacks the liver. There is no vaccine, but Health Canada has approved drug combinations that treat and cure it, which is why prompt testing after an exposure matters 6,11.
• HIV attacks the immune system and, left untreated, leads to AIDS. Treatment is highly effective, and post-exposure prophylaxis can reduce the risk of infection when it is started quickly after an exposure 7,8.

Other pathogens — syphilis, brucellosis and malaria among them — can also be carried in blood, but CCOHS records those as rare, isolated occupational events, which is why they are not the focus of a workplace program 4.

How does exposure to bloodborne pathogens happen, and how does it not?

Bloodborne pathogens are not airborne. In the workplace, transmission requires infected blood or body fluid to reach another person's bloodstream, usually through a needlestick, a splash to the eyes, nose or mouth, or broken skin.

That is a narrower set of routes than most people assume, and the distinction matters, because “bloodborne” and “airborne” are two different transmission categories in infection control. Respiratory spread through coughing and sneezing belongs to a different class of pathogen, such as tuberculosis or influenza.

How can bloodborne pathogens be transmitted in the workplace?

• Needlestick injuries and other injuries from sharps, including scalpels, lancets, broken glass and contaminated instruments 4
• Splashes of blood or body fluid onto mucous membranes, meaning the eyes, nose or mouth
• Contact with non-intact skin, such as cuts, abrasions, chapped skin or dermatitis

How are bloodborne pathogens not transmitted?

• Through the air, or by coughing or sneezing
• By casual contact such as handshakes, hugging or sharing a workspace
• Through food, water or shared utensils
• Through intact skin

Not every body fluid carries the same risk. For HIV, only five body fluids contain enough virus to transmit it: blood, semen including pre-ejaculate, rectal fluid, vaginal fluid and breast milk. HIV is not transmitted by saliva, tears, sweat, urine or feces, and it does not survive well outside the human body 2. Even so, workplace precautions treat all blood and body fluids as potentially infectious, because you cannot tell by looking what a fluid contains or who is carrying an infection.

Who is at risk from bloodborne pathogens, and who must be trained?

Bloodborne pathogen training is for anyone whose job can reasonably be expected to involve contact with blood or other potentially infectious materials (OPIM), meaning the body fluids and other materials that can carry these pathogens. That is a much wider group than healthcare alone.

The following are the audiences most often covered by a workplace program:

• Healthcare and long-term care workers
• First-aid attendants and designated first responders
• Tattoo, piercing and body-art artists
• Corrections and law-enforcement officers
• Waste, sanitation and wastewater handlers
• Cleaners and custodians
• Funeral and mortuary staff
• Laboratory and research personnel
• Education and childcare staff who act as first-aiders
• Anyone else whose work is reasonably expected to involve contact with blood or other potentially infectious body fluids

The duty to arrange that training sits with the employer. Occupational health and safety law across Canada requires employers to assess the hazards present in their workplace, put controls in place, and make sure that workers who may be exposed are informed, instructed and trained. Where the hazard is blood or another biological agent, that general duty is what requires bloodborne pathogen training. The legal basis is set out in the federal and provincial sections below.

How do Routine Practices and exposure control plans protect workers?

What are Routine Practices?

Routine Practices are the foundation of bloodborne pathogen safety in Canada. The principle is straightforward: treat all blood, body fluids, secretions, excretions, mucous membranes, non-intact skin and soiled items as potentially infectious, no matter what is known about the person they came from 3,15.

Routine Practices combine two older ideas — Universal Precautions, which focused on blood, and body substance isolation — and they reach further than either, covering all body fluids, excretions, mucous membranes, non-intact skin and soiled items. Standard Precautions is the comparable term used in United States guidance 3.

What is an exposure control plan?

An exposure control plan is the employer's written plan for identifying which workers may be exposed to blood or other biological agents and for the controls, training and follow-up that protect them. The named "exposure control plan" requirement belongs to British Columbia. WorkSafeBC's OHS Regulation requires an exposure control plan meeting the requirements of s. 5.54 where a worker has or may have occupational exposure to a biological agent (s. 6.34), supported by provisions on controls (s. 6.36), vaccination (s. 6.39) and medical evaluation (s. 6.40) 9,10. The plan must cover a statement of purpose and responsibilities, risk identification, assessment and control, education and training, written work procedures, hygiene and decontamination, health monitoring and documentation, and it must be reviewed at least annually. Other jurisdictions reach a similar result through general hazard-assessment and prevention-program duties rather than through a rule that carries that name. If you operate outside BC, you still need a program. It may be called something else.

Whatever it is called where you work, a workable program covers the following:

• Risk assessment: identifying which tasks, which locations and which workers can bring a person into contact with blood or other potentially infectious body fluids.
• Engineering controls: safety-engineered needles, sharps containers, splash guards and any other equipment that removes or reduces the hazard at source.
• Personal protective equipment: gloves, eye and face protection and gowns, supplied by the employer and matched to the task.
• Safe work procedures and training: sharps handling and disposal, spill and cleanup procedures, and instruction for every worker who may be exposed.
• Vaccination and medical follow-up: hepatitis B vaccination where it is indicated, and a defined route to medical assessment after an exposure.
• Records: training records, exposure incident records, and the written plan itself.
• Review: reassessing the program at set intervals, and whenever tasks, equipment or incidents indicate something has changed.

What should a worker do after a bloodborne pathogen exposure?

1. Report it. Tell your supervisor right away and record the incident through your workplace's reporting procedure, even if the exposure seems minor. What the employer must do next depends on the jurisdiction. Manitoba, for example, requires the employer to investigate every needlestick injury in a medical workplace, and Saskatchewan's regulations require an injury log (see the table below).
2. Follow through. Complete your employer's exposure-response procedure, attend any follow-up testing that is recommended, and meet any provincial reporting duty that applies to your workplace; in Ontario, for example, the employer reports to the WSIB within three business days of learning that a worker needs health care or loses time 31.

What does federal law say about bloodborne pathogens?

There is no federal bloodborne pathogens regulation. Federal occupational health and safety law covers federally regulated workplaces: banking, telecommunications, broadcasting, interprovincial and international transport, ports, pipelines, federal Crown corporations and the federal public service 12. Every other workplace in Canada is covered by its province or territory.

The Canada Occupational Health and Safety Regulations (SOR/86-304) do not contain a dedicated bloodborne pathogens standard comparable to the United States OSHA rule. Federally regulated employers protect workers through two general instruments applied to biological hazards:

• The general duty under section 124 of the Canada Labour Code (Part II), which requires every employer to ensure that the health and safety at work of every person employed by them is protected 12.
• The Hazard Prevention Program under sections 19.1 to 19.8 of the COHSR (Part XIX), which requires employers to identify and assess hazards, apply preventive measures in a set order of priority, and train workers on the hazards they face 13. Applied to blood and other biological agents, this is what drives a bloodborne pathogen program in a federally regulated workplace.

Unlike the United States, which has a single federal Bloodborne Pathogens Standard (OSHA 29 CFR 1910.1030), Canada regulates bloodborne pathogens through general occupational health and safety law: federal law for federally regulated workplaces, and provincial or territorial law for everyone else. If you have come across a training program or a compliance checklist built around “the Bloodborne Pathogens Standard”, it is describing the American rule, not a Canadian one.

CSA Z317.13 is an infection-control standard, but not a training standard. Its official title is Infection control during construction, renovation, and maintenance of health care facilities, its scope is exactly that, and it sets no bloodborne pathogen training requirements for employers 14.

What are the provincial and territorial rules for bloodborne pathogens?

Every province and territory protects workers from bloodborne pathogens through its general occupational health and safety duty. Six jurisdictions add an explicit safety-engineered needle or sharps requirement: British Columbia, Alberta, Saskatchewan, Manitoba, Ontario and Nova Scotia.

Some of those sit in a standalone statute, others are provisions inside a broader occupational health and safety regulation. The remaining jurisdictions apply the general occupational health and safety duty to identify biological hazards and protect exposed workers. That general duty is a real and enforceable obligation. It is not a bloodborne-pathogen-specific rule, and it should not be described as one.

Can the training be done online?

Yes — the knowledge part of bloodborne pathogen training can be completed online. The workers who need it are the ones identified in the employer's risk assessment; the list in the section on who is at risk shows who those workers usually are. Where a worker has an employer, arranging the training is the employer's responsibility. A self-employed person arranges their own. The worker has to actually receive it and understand it, which is why a signed attendance sheet is not the same thing as a trained workforce.

The material is knowledge-based rather than a hands-on physical skill, so it transfers to a self-paced format without losing anything, and an online course lets an employer train shift workers and multi-site teams without pulling everyone into a classroom on the same day. Employers remain responsible for any workplace-specific instruction, procedures, equipment training and supervision required by the jurisdiction they operate in. In British Columbia, for example, the requirement is adequate education, training and supervision tied to the employer's exposure control plan and to the worker's actual occupational exposure 9. A generic certificate on its own does not discharge that duty.

A course worth taking should leave a worker able to:

• Name the bloodborne pathogens of concern in Canadian workplaces and explain what they do
• Describe how transmission actually happens at work, and how it does not
• Apply Routine Practices to every task involving blood or body fluids
• Use engineering controls and personal protective equipment correctly, including safe sharps handling and disposal
• Clean up a blood or body-fluid spill safely
• Follow the workplace exposure-response procedure, including immediate first aid, reporting and prompt medical assessment
• Know where the employer's exposure control plan or equivalent program is kept, and what it asks of them

The online course takes about 40 minutes.

Does the law set an expiry date for the training?

No Canadian law fixes an expiry date or a refresher interval for bloodborne pathogen training, no standard fixes one, and there is no certification regime that sets one. What the law does fix in some places is the review of the program itself — in British Columbia, for example, the exposure control plan has to be reviewed at least once a year 9.

On top of that legal floor, training providers set their own cycle. The eSafetyFirst Bloodborne Pathogens certificate carries a printed expiry of two years from completion; that is our program's practice, not a legal requirement, and other providers may do it differently. Your own program may call for refreshers more often, and it should: if a worker's tasks change, if new devices are introduced, or if an incident review shows a gap, retrain at that point rather than waiting for the calendar. If you are a worker, check what your own employer requires.

Key takeaways

The bloodborne pathogens that matter in Canadian workplaces are hepatitis B, hepatitis C and HIV. They spread through blood contact rather than through the air. Protection comes from the general employer duty under occupational health and safety law. In some jurisdictions it is reinforced by specific rules, such as British Columbia's exposure control plan requirement and the explicit safety-engineered needle requirements in six jurisdictions. If your workers can reasonably be expected to come into contact with blood or other potentially infectious body fluids, assess the hazard, put controls in place, and make sure they are trained.