Does Your Workplace Have An Exposure Control Plan?
The Occupational Safety and Health Administration (OSHA) requires all employers who expect their employees to be exposed to either blood or other bodily fluids in the workplace to have an Exposure Control Plan (ECP). The plan’s purpose is to eliminate or minimize the possibility of workers becoming exposed or infected with bloodborne pathogens.
29 CFR 1910.1030 (US Code of Federal Regulations) provides detailed and specific criteria for an ECP that complies with OSHA’s Bloodborne Pathogen Standard. It is the sole authority.
What Is An Exposure Control Plan?
The basic components of an ECP are:
Exposure Determination – A list of all job classifications in which some or all employees can expect the possibility of exposure to blood or other bodily fluids.
Methods of Exposure Control – This can include but is not limited to:
- Universal precautions. The safe assumption is that all body fluids, open wounds, and mucus membranes contain pathogenic microorganisms which can expose a person to the transmission of an infectious disease such as Hepatitis B, Hepatitis C, or HIV. That assumption suggests some appropriate precautions. Some of those universal precautions are handwashing, conforming to engineering and work practice controls, and the use of personal protective equipment.
- Engineering and work practice controls. Engineering controls may include placing sharps disposal units at strategic places in the workplace, installing hand sanitizing stations, and using needle safety devices. Examples of work practice controls are the proper use of personal protective equipment and protocols for handling and disposal of potentially infectious material.
- Personal Protective Equipment. This can be safety glasses, latex gloves, puncture-resistant gloves, Tyvek suits, or other items.
- Housekeeping. How spills and contaminations are sanitized and the regular disinfecting maintenance of appropriate surfaces.
Hepatitis B Vaccination – The vaccination series must be available to all workers within ten days of completing bloodborne pathogen training. Employees may decline the vaccination, but they must sign a statement to do so.
Post-exposure Evaluation and Follow-up – This includes how to provide immediate medical treatment of potential exposure. It establishes first-aid procedures. It also requires periodic evaluations and testing and treatment of exposures, including psychological care.
Communication of Hazards to Employees and Training – At a minimum, employees must be given a copy of OSHA’s Bloodborne Pathogens Standards, know where to access the ECP, and have the opportunity for a question-and-answer session with a knowledgeable person. More stringent requirements are necessary when workers have an increased chance of exposure, such as lab technicians.
Record-Keeping – Includes but is not limited to training records, medical records, OSHA recordkeeping, Sharps injury log, and Hepatitis B Vaccine Declination.
Evaluating Circumstances Surrounding Exposure Incidents – This is a case-by-case study of exposures to determine what parts of the ECP worked, what details failed, and what revisions, if any, need to be made.
Who Should Have an Exposure Control Plan?
Do you have a break room? A table might become contaminated with saliva. Do you have a restroom? All sorts of possible contaminations could happen there. Are there any sharp objects in the workplace? Do you collect dirty uniforms for laundering?
ECPs are written to be specific for their workplaces. There isn’t any “one size fits all” form. Each workplace has its unique collection of potential hazards, and it may be valid to argue that no workplace is completely free from all possible exposures.
Do You Have Medical Waste?
If so, you will probably need an ECP if you haven’t already got one. You will also need a waste disposal service that operates at the top of the industry, and Medical Waste Pros is your source for the services you need. Call us at (888) 755-6370 or fill out the contact form to receive free quotes on our medical waste disposal services and training programs today.