Do You Have an OSHA Exposure Control Plan?

As part of the OSHA Bloodborne Pathogen Standard, employers are required to have an exposure control plan in place. It should detail, in writing, your plan for reducing exposure to bloodborne pathogens and explain what steps will be taken when an exposure occurs.

Why an Exposure Control Plan Is Important

First — and most important — your exposure control plan helps protect frontline workers from exposure to bloodborne pathogens. Second, if your workers are at risk for exposure to bloodborne pathogens, you are required by law to have a written exposure control plan. Third, the costs of an exposure incident can be significant, including post-exposure treatment and counseling, loss of employee work time and increased worker’s compensation. Having a exposure control plan can help your business avoid these expenses.

Exposure Control Plan: 10 Best Practices to Follow

Make sure your plan is compliant by following these tips.

1. During required initial and annual bloodborne pathogens training, inform workers about the exposure control plan and where it’s located.
2. Designate one person to implement the plan.
3. Complete an “employee exposure determination.” Make a list of job titles that may have reasonably anticipated contact with blood or other potentially infectious materials and another list of job titles where specified tasks or procedures put some employees at risk of exposure.
4. Provide safety devices engineered to prevent needlesticks and other sharps injuries to employees who use these devices.
5. Get input from frontline employees in the evaluation and selection of safety devices. Document the selection process in your exposure control plan.
6. Be specific about how to implement controls. For example, the plan should cover the decontamination of work surfaces and equipment, and the inspection and replacement of sharps disposal containers, including who is responsible for doing these tasks.
7. Clarify how personal protective equipment (PPE) can help. The plan should provide guidelines on when and how to use different types of PPE, including disposable gloves, face and eye protection, and ventilation devices.
8. Encourage hepatitis B protection by offering the vaccination series at no cost to employees. The plan must document who is responsible for the vaccination program and include a vaccination declination form.
9. Train employees on the procedure for reporting exposures and have a plan for immediate medical evaluation and follow-up. Psychological counselling should also be considered.
10. Update your exposure control plan every year.