Exposure Control Plan

November 23, 2022

BBP Exposure Control Plan FAQ

As healthcare organizations and other companies continue to navigate the staffing challenges of the “Great Reshuffle,” employers are prioritizing worker well-being to boost their recruitment and retention efforts. However, organizations may still be impacted by resignations if their staff does not feel safe at work. 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.

The Bloodborne Pathogens Standard is one OSHA regulation that healthcare organizations must follow. 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).

What Is an Exposure Control Plan?

An 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 environment.

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.

What Should an Exposure Control Plan Include?

Some of the main topics an ECP should cover include:

  • An exposure determination list, provides a list of all job classifications and employees that have occupational exposure. An exposure determination includes tasks and procedures in which occupational exposure occurs for those employees that have anticipated exposure on an occasional or intermittent basis.
  • A workplace hazard assessment to determine what types of personal protective equipment (PPE) will be selected to prevent or mitigate exposure.
  • The other types of engineering controls, work practice controls, and administrative controls, beyond PPE, that an organization will use to prevent or mitigate exposure.
  • An explanation of the organization’s BBP training requirements.
  • Policies outlining the offering of Hepatitis B vaccinations, including when it’s warranted for an employee to be vaccinated.
  • How to evaluate and properly respond to exposure incidents. This aspect is of high importance as it will guide an employer through the necessary procedures to take following an incident.

Staff should assist in developing the plan to help ensure policies are relevant to their specific work conditions. ECPs are required to be reviewed and updated annually and whenever necessary to reflect new or modified tasks and procedures or revised employee positions with occupational exposure.

What are the Annual 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

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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