Exposure Control Plan

November 11, 2023

Bloodborne Pathogens (BBP) Exposure Control Plan 101

In compliance with the OSHA Bloodborne Pathogens Standard, any organization with employees facing occupational exposure to Bloodborne Pathogens (BBPs) is mandated to possess a written plan and provide necessary training.

The Bloodborne Pathogens Standard is one OSHA regulation that healthcare organizations must comply with to prevent contamination post exposure. As required by these rules, each employer who has employees with occupational exposure to blood and/or other potentially infectious materials (OPIM) should maintain an Exposure Control Plan (ECP).

A safe and efficient healthcare workplace can help lay the foundation for employee satisfaction and productivity. The Occupational Safety and Health Administration (OSHA) develops regulations to help organizations prevent injuries and protect the safety of their staff.[S.1]

Whether you operate in healthcare, hospitality, healthcare-related research, or emergency public services/first responders, our guide helps your organization and staff stay safe and compliant.

What Is an Exposure Control Plan for Bloodborne Pathogens?

An Exposure Control Plan (ECP) is a written document that details how an organization will identify and mitigate risks of exposure to bloodborne pathogens (BBPs), along with how the workplace will respond in the event of actual exposure. This plan will vary for every organization to align with the specific type of work and environmental health and safety requirements.

Preparing an ECP is not only a best practice for helping to protect employee well-being, but the BBP Standard also requires it. OSHA inspectors often evaluate ECPs during on-site visits, so organizations should be sure that their plans are accessible and current. When leaders construct an ECP, they can refer to the OSHA model template for guidance. Stericycle also has an ECP template available to customers as part of its Steri-Safe offering. It includes a safety plan builder that guides you through a step-by-step set up process.

What Organizations Are Required To Prepare an Exposure Control Plan?

The OSHA Bloodborne Pathogens Standard requires any organization where employees have occupational exposure to BBPs to have a written plan and provide training to those employees. In addition to healthcare organizations, there are other types of industries with occupational exposure, including companies in hospitality, healthcare-related research, and emergency public services/first responders.

Key Components of an Effective ECP: 

Some of the main topics an ECP should cover include:

  1. Clear Exposure Determination
    When creating an ECP, it’s crucial to precisely identify job roles where employees might encounter Bloodborne Pathogens (BBPs). This clarity ensures that everyone understands the risks associated with their work. The exposure determination should list specific tasks and procedures where BBP exposure is likely, whether occasionally or intermittently.
  2. Thorough Risk Assessment 
    A thorough risk assessment helps select the right Personal Protective Equipment (PPE) and implement effective controls. By evaluating all aspects of the workplace environment, organizations can accurately identify potential hazards. Consider engineering controls, work practices, and administrative measures during this process.
  3. Training and Education 
    Educating your workforce is essential for BBP exposure prevention. Regular training sessions should cover critical aspects like BBP transmission modes and protective measures outlined in the ECP. Ensuring that all employees, especially those with direct exposure risks, receive comprehensive education promotes safety and compliance.
  4. Hepatitis B Vaccination Protocol 
    Criteria for Vaccination
    : Clearly define who is eligible for Hepatitis B vaccination. Consider factors such as job roles, exposure risks, and medical history.
    Procedure for Declination: Explain how employees can decline the vaccination if they choose to. This process should be respectful and confidential.
  5. Response Protocol
    In the event of exposure incidents, employees need to act promptly.
    Evaluate the Situation: Assess the risk and severity of exposure.
    Immediate Response: Provide first aid or seek medical attention as necessary.
    Reporting: Employees should know how to report incidents to their supervisor or designated personnel.
  6. Regular Review and Updates
    An ECP is not static—it evolves with the workplace.
    Annual Reviews: Regularly assess the ECP to ensure it remains relevant.
    Reflecting Changes: Update the plan to account for any modifications in tasks, procedures, or regulations.
    Accessibility: Make sure all employees know where to find the ECP.
  7. Incorporating Worker Input
    Workers’ insights matter. Encourage active participation in ECP development and device selection. Their feedback enhances safety protocols and ensures practicality.
  8. Refer to Authoritative Resources When in Doubt
    Refer to trusted sources like the Centers for Disease Control and Prevention (CDC), National Institute for Occupational Safety and Health (NIOSH), and OSHA. These organizations provide valuable guidance on ECP development, training materials, and compliance requirements.

What are the Annual BBP Training Requirements? 

Organizations must provide training to any employee who has anticipated exposure to blood or OPIM. Some examples include nurses, nursing assistants, physicians, housekeeping staff, and other clinical and operational employees. The annual training should cover topics such as:

  • The epidemiology and symptoms of bloodborne diseases
  • How bloodborne pathogens may be transmitted
  • The steps workers can take to protect themselves from exposure
  • An overview of the site’s ECP
  • Information on the Hepatitis B vaccine
  • What steps to take in an exposure incident

Benefits of Opting for Our Exposure Control Plan:

  • Extend comprehensive protection beyond bloodborne pathogens, addressing the unique challenges posed by diverse occupational exposures.
  • Prove your commitment to surpassing regulatory standards in the US, protecting your organization from legal risks and fines, irrespective of the industry you operate in.
  • Minimize disruptions caused by workplace incidents, ensuring the smooth operation of your organization.
  • Instill a culture of safety and empowerment among employees, enhancing morale, productivity, and retention.

Why Choose Stericycle to Implement the Exposure Control Plan:

Tailored for Diverse Facilities & Clinical Settings

Holistic Risk Management of all waste streams

Engaging Training Resources

Strategic Implementation of Robust ECP Framework

BBP training should happen at the time of the initial assignment to jobs where exposure may occur and at least annually after. Stericycle’s online training modules can help your staff understand the BBP standard and can help you meet the standard’s training requirements. Stericycle’s SteriSafe OSHA Compliance Training can help organizations remain compliant and promote workplace safety through employee education. Learn more and contact Stericycle to get started. 

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