Kevin Noel

Exposure Control Plan Compliance Guide

Having a compliant exposure control plan is a necessity under OSHA’s Occupational Exposure to Bloodborne Pathogens Standard. The OSHA standard for bloodborne pathogens regulates employers to ensure that workers are safe when dealing with potential exposure to blood or OPIMs.

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Key Takeaways

What Does an Exposure Control Plan Consist of?

Exposure Plan Definition



It’s best to think of an exposure control plan like a playbook for how your facility will reduce the risks of exposure to potentially infectious materials
.

An exposure control plan must be created to minimize occupational exposure to bloodborne pathogens in accordance with OSHA’s standards.

Exposure Control Plan Best Practices:

Under OSHA regulations, any facility with employees who have occupational risk of exposure to blood or other potentially infectious materials must have an exposure control plan.

It is a good idea to use OSHA’s model for an exposure control plan to make sure you do not miss anything.

An exposure control plan should include all of the following:

✔ Identification of Hazards and Tasks with Potential Exposure

This should clearly outline all hazards present in the workplace and every job-related task that could result in exposure for employees.

✔  Evaluation of Exposure

Evaluate potential exposures in the workplace, both potential and realized.

In the event of an exposure, you must document how it occurred and testing for the employee who was exposed should begin immediately. The results of this should be given to the employee as soon as feasible.

✔  Implement Workplace Controls and Engineering Controls to Minimize Risk

All waste containers must be clearly labeled, compliant, and quickly accessible to employees.

You must provide Hepatitis B vaccinations and proper training, including OSHA Bloodborne Pathogens Training which should be repeated at least annually.

The employer should outline and instruct on ways to reduce likelihood of injury.

For example, employers should be instructing employees to cap a needle in a way found to reduce injury.

Also, handwashing stations and personal protective equipment should be available to all employees with occupational risk.

✔  Clear Record Keeping

An accurate record should be kept for every single employee with occupational risk including their name, vaccination details, training logs, all exam results, and more.

✔ Regular Review of your Plan

Your exposure control plan must document changes in technology that could aid in reducing risks, consideration / implementation of safer devices, and should have input from employees who have direct patient care.

This should be readily available upon request, so keep it updated and make sure to renew it at least annually!

Exposure Control Plan Summary:

With something as potentially dangerous as bloodborne pathogens, it is very important to follow regulations to keep everyone safe. OSHA’s standard can be confusing, so we highly recommend utilizing their model exposure control plan to make sure you aren’t missing everything.

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