Does OSHA apply to tattoo shops?

Yes—if you have employees. OSHA’s Bloodborne Pathogens Standard exists to protect workers who may be exposed to blood or other potentially infectious materials (OPIM) on the job. That clearly includes tattoo artists, piercers, and support staff who handle sharps or contaminated surfaces. Some states run their own OSHA-approved “State Plans,” which must be at least as effective as the federal program and can be stricter.

Important nuance: even if you consider a worker an “independent contractor,” OSHA might not. See Question 2 in this Standard Interpretation Letter.

OSHA’s focus is worker safety. Passing a county health inspection is not a substitute for compliance with the Bloodborne Pathogens Standard.

See OSHA Fact Sheet at: https://www.osha.gov/sites/default/files/publications/factsheet-inspections.pdf

No OSHA endorsement is implied.

What belongs in an OSHA-compliant safety plan

OSHA requires a written Exposure Control Plan (ECP) that you review and update at least annually. The plan describes how your studio prevents exposure, what to do when incidents occur, and how you train and equip employees. While every shop is unique, strong plans usually cover:

1) Exposure determination & universal precautions

Identify which job classifications and tasks can involve exposure to blood or OPIM. Then apply universal precautions—treat all human blood and certain body fluids as if they are infectious.

2) Engineering and work-practice controls

Specify safe sharps practices, needle handling, and the use of puncture-resistant, labeled sharps containers placed at point of use. Include hand hygiene, no-recapping policies, and surface decontamination procedures aligned with disinfectant instructions.

3) Personal protective equipment (PPE)

Provide appropriate PPE (e.g., gloves, masks, protective eyewear, aprons) at no cost to employees, train on use and limitations, and ensure proper disposal or cleaning, depending on type.

4) Hepatitis B vaccination program

Offer the Hepatitis B vaccine to at-risk employees at no cost, document acceptance or declination, and maintain records per OSHA’s requirements. This is a core element of the Bloodborne Pathogens Standard and a proven protection against a serious occupational risk.

5) Post-exposure evaluation & follow-up

If an exposure incident occurs, you must provide a confidential medical evaluation and follow-up at no cost to the employee, including source testing (when feasible), employee testing, counseling, and prophylaxis as indicated.

6) Training—initial and annual

Conduct interactive bloodborne pathogens training at the time of assignment and at least annually thereafter. Make it studio-specific so it reflects your actual procedures, equipment, and waste handling.

7) Recordkeeping & sharps injury log

Maintain training records, vaccination offers/declinations, and—where required—a sharps injury log. Accurate records demonstrate compliance and help you target improvements.

8) Regulated waste management & hazard communication

Your plan should address labeling, storage, and disposal of regulated waste, plus Safety Data Sheets (SDS) and employee right-to-know under OSHA’s Hazard Communication Standard (29 CFR 1910.1200).

Business benefits that go beyond compliance

A safety plan isn’t just a binder for inspectors. It’s a leadership tool that improves your studio every day.

Fewer accidents, less downtime

Clear procedures and safer sharps practices reduce injuries, exposures, and costly disruptions. When incidents do happen, a defined post-exposure process minimizes uncertainty and time away from work.

Talent attraction and retention

Artists want to work where their health matters. Demonstrating a robust program—vaccination offers, PPE, training, and a respectful culture—signals professionalism and care.

Client trust & brand strength

Today’s clients do research and expect professional service. Displaying high-level safety commitments on your website and training front desk staff to confidently answer questions can convert inquiries into bookings.

Fewer surprises during inspections

Shops that document training, vaccination offers, and exposure controls rarely scramble when OSHA visits. Preparedness reduces stress and helps you achieve and maintain high standards of practice.

Common pitfalls (and how to fix them)

1) “We passed our county health department inspection—so we’re fine.”

Health departments focus heavily on client safety under state/local codes. OSHA focuses on employee safety under federal law. You need to comply with both.

2) A generic plan that no one follows

Plans copied from the internet usually ignore your actual procedures. Write yours in plain language, map it to your workflow, and train against it with demos and Q&A.

3) Skipping vaccination offers or documentation

The Hepatitis B vaccination offer, free of charge to at-risk employees, is not optional. Keep signed acceptance or declination on file.

4) Infrequent or non-interactive training

OSHA mandates interactive training at assignment and annually. Short videos alone won’t cut it; incorporate questions, demos, and shop-specific scenarios.

5) Missing or misplaced sharps containers

Sharps containers must be puncture-resistant, properly labeled, and placed at the point of use. Regularly check containers for fullness and replace them as needed to maintain a safe environment.

How OSHA inspections work (and how to be ready)

OSHA inspections can be triggered by imminent danger, severe injuries, referrals, programmed inspections, or employee complaints. In tattoo and piercing studios, complaints are a common trigger. A typical inspection includes:

• Opening conference: OSHA explains why they’re there and what they’ll review.
• Walkaround: The compliance officer observes conditions and practices, takes notes, and may interview staff.
• Document review: Expect to show your Exposure Control Plan, training records, Hepatitis B vaccination offers/declinations, sharps injury logs, Safety Data Sheets, and more.
• Closing conference: You’ll hear preliminary findings and next steps.

Preparation is your best protection. Keep your documents current and accessible, train staff to follow the plan, and designate a safety manager to communicate with inspectors.

Being inspection-ready is a daily practice—not a last-minute scramble.

A simple path to building your plan

You don’t need to start from a blank page. The most efficient approach is to map your workflow (client documentation → setup → procedure → teardown → cleanup) and draft controls for each step. Align those controls with OSHA’s requirements—exposure determination, universal precautions, engineering/work-practice controls, PPE, vaccination, training, post-exposure, recordkeeping, and waste management.

If your shop does out-of-state tattoo shows, or is located in an OSHA State Plan state, verify any additional requirements and incorporate them into your plan and training.

Consider assigning a safety lead who schedules annual reviews, tracks training, and ensures supplies (PPE, sharps containers, disinfectants) are stocked and compliant.

If you don't want to write a plan yourself, let us help. 

Use the Easy Wizard^® app to create an Exposure Control and Infection Prevention Plan to protect your clients, your artists, and your business.

The bottom line

An OSHA-compliant safety plan is more than a regulatory checkbox. It’s the framework that keeps your artists safe, your business protected, and your brand credible. By formalizing how your studio prevents exposure, trains staff, responds to incidents, and manages records and waste, you reduce risk and build trust—every single day. Start with your actual workflow, align it with OSHA’s Bloodborne Pathogens Standard, train your team, and keep improving. Your future self—and your staff—will thank you.