A study found that some American healthcare workers are not adequately trained for, nor protected from bloodborne pathogens.
The report discovered specifically that 28% of privately owned dental practices did not have a site-specific written bloodborne pathogens exposure control plan (ECP). Of this 28% – half of that number declared no intention to implement an ECP within the next 12 months.
OSHA’s 29 CFR 1910.1030 bloodborne pathogens standard was created to safeguard workers in the United States from infectious diseases found in blood and other potentially infectious materials (OPIM). The standard mandates an exposure control plan be in place to protect workers.
What is a bloodborne pathogens exposure control plan?
An exposure control plan (ECP) is basically a written plan created by the employer that outlines how they will protect their workers from bloodborne pathogens.
This written plan is a requirement for compliance with the bloodborne pathogens standard. Without an ECP, the employer has no program and there is little hope of properly protecting their employees.
Additionally, not having an ECP is a violation of Federal law, so the employer will be deemed ‘non-compliant’ and potentially fined.
With all of this in mind, you have probably realized that if you are an employer, it’s critical that you have an ECP. But what do you need to put in it? Below there is a short Exposure Control Plan FAQ that tells you what, at a minimum, you need to include.
What to include in a bloodborne pathogen exposure control plan
Exposure determination
The plan should include the names, department and tasks of each employee where the potential for occupational exposure to human blood or OPIM exists.
Methods of implementation and control
There are several components that you will need to include in your ECP to reduce the potential exposure risk for employees including:
- Exposure control plan: A written plan outlining processes and procedures to prevent and mitigate exposure to potential infectious diseases and provide employee training.
- Engineering controls and work practices - Methods including sharps disposal, review of work practices, employee involvement and awareness should all be included.
- Personal protective equipment (PPE) - Correct PPE supplies are provided to employees who fall under the plan coverage, including gloves, gowns, face protection, goggles and the training, education and use of PPE as appropriate.
- Housekeeping - Outline the proper use and procedures to handle, clean, and dispose of contaminated materials like clothing, basins, sharpsl, towels and rags that are considered potentially infectious. Biohazard clean-up kits are commonly used for spill applications.
- Laundry - Clothing that may have been exposed must be disposed of or treated appropriately, being placed in red, leak-proof bags marked with biohazard symbols.
- Labels - Equipment including waste receptacles, refrigerators and other locations where potentially infectious materials are located must be labeled with identifying tags, stickers or markings according to the standard to help identify them as hazardous and warn employees. Red biohazard bags are commonly used for disposal.
Hepatitis B Vaccination
The employer will provide both bloodborne pathogens certification training and vaccinations to employees who, as part of their duties, will be exposed to blood and/or OPIM. There are a number of reasons why an employee may not be required to be, or may decide to decline, being vaccinated but generally, all employees should be. Any employee who declines the vaccination must sign a document of refusal which must be stored with the other bloodborne pathogens program records.If an employee changes their mind at any time, for any reason, the offer of free HBV vaccination must be extended by the employer immediately.
Post-Exposure evaluation and follow-up
Immediately following an exposure event, a confidential medical evaluation and follow-up should be conducted. The evaluation must include details such as documenting how the exposure occurred, being tested for infection, blood collection for evaluation and further testing and more. See the standard for more details.
Communication of hazards and training
Every worker who has occupational exposure risk must receive bloodborne pathogens training covering the minimum mandated OSHA topics. These include what BBP are, symptoms, and transmission of these diseases. As well as training, employees must have an opportunity to ask questions and get answers from the person who is conducting the training.
Record keeping
There are 4 types of records OSHA requires.
- Training,
- Medical,
- Incident
- Sharps injury records
All of these must be managed and maintained by the employer. The length of time the records must be maintained varies based on the record type. As an example, training records must be kept for three years whilst medical records must be kept for thirty years after the employee is no longer employed at that organization.
Administration of post exposure incidents
In a case of employee exposure, the employer is required to examine the plan, process and procedures surrounding the employee for the purpose of preventing future exposure.
The study mentioned in the beginning of this article focused on the dental industry, but we can safely assume that there are many other organizations who are not bloodborne pathogens compliant across multiple industries.
BBP Exposure Control Plan Model
You can take a close look at OSHA’s model exposure control plan and begin to create your exposure control plan. If you have already created an exposure control plan but it has been tucked away in a desk for years, it may be time to update it.
Reach out to your employees and put your plan back into action. These steps will help protect your company’s most important asset, your workers.
How the OSHA Model Plan can Help
As mentioned above, OSHA does try and help employers by providing a model bloodborne pathogens exposure control plan. The only issue is that this is only available as a PDF which makes it quite difficult to use as a quick and easy exposure control plan template.
With this in mind, we present the bloodborne pathogens ECP here. It;s important to note that this is just a model – ultimately as the employer you have the responsibility to develop a compliant ECP, but following this template should get you most of the way there.
Here is what OSHA have to say about the model plan:
“The Model Exposure Control Plan is intended to serve employers as an example exposure control plan which is required by the Bloodborne Pathogens Standard. A central component of the requirements of the standard is the development of an exposure control plan (ECP).
The intent of this model is to provide small employers with an easy-to-use format for developing a written exposure control plan. Each employer will need to adjust or adapt the model for their specific use.
The information contained in this publication is not considered a substitute for the OSH Act or any provisions of OSHA standards. It provides general guidance on a particular standard-related topic but should not be considered a definitive interpretation for compliance with OSHA requirements. The reader should consult the OSHA standard in its entirety for specific compliance requirements.”
-OSHA-
OSHA Bloodborne Pathogens Exposure Control Plan Sample
Here is the full bloodborne pathogens exposure plan model as provided by OSHA – you can copy and paste sections of the plan to create your own, or download the Word version to use as your template by clicking the button.
POLICY
The _____(Facility Name)_____ is committed to providing a safe and healthful work environment for our entire staff. In pursuit of this endeavor, the following exposure control plan (ECP) is provided to eliminate or minimize occupational exposure to bloodborne pathogens in accordance with OSHA standard 29 CFR 1910.1030, “Occupational Exposure to Bloodborne Pathogens.”
The ECP is a key document to assist our firm in implementing and ensuring compliance with the standard, thereby protecting our employees. This ECP includes:
- Determination of employee exposure
- Implementation of various methods of exposure control, including: Universal precautions Engineering and work practice controls Personal protective equipment Housekeeping
- Hepatitis B vaccination
- Post-exposure evaluation and follow-up
- Communication of hazards to employees and training
- Recordkeeping
Procedures for evaluating circumstances surrounding an exposure incident.
The methods of implementation of these elements of the standard are discussed in the subsequent pages of this ECP.
PROGRAM ADMINISTRATION
_(Name of responsible person or department)_______________________ is (are) responsible for the implementation of the ECP. _____(Name of responsible person or department)_______________________ will maintain, review, and update the ECP at least annually, and whenever necessary to include new or modified tasks and procedures. Contact location/phone number:____________________________
Those employees who are determined to have occupational exposure to blood or other potentially infectious materials (OPIM) must comply with the procedures and work practices outlined in this ECP.
___(Name of responsible person or department)_____________________ will maintain and provide all necessary personal protective equipment (PPE), engineering controls (e.g., sharps containers), labels, and red bags as required by the standard. _____(Name of responsible person or department)______________________ will ensure that adequate supplies of the aforementioned equipment are available in the appropriate sizes.
Contact location/phone number:_________________________________
_(Name of responsible person or department)_______________________ will be responsible for ensuring that all medical actions required are performed and that appropriate employee health and OSHA records are maintained.
Contact location/phone number:_________________________________
_(Name of responsible person or department)_______________________ will be responsible for training, documentation of training, and making the written ECP available to employees, OSHA, and NIOSH representatives.
Contact location/phone number:_________________________________
EMPLOYEE EXPOSURE DETERMINATION
The following is a list of all job classifications at our establishment in which all employees have occupational exposure:
JOB TITLE | DEPARTMENT/LOCATION |
(Example: Phlebotomists) | (Clinical Lab) |
The following is a list of job classifications in which some employees at our establishment have occupational exposure. Included is a list of tasks and procedures, or groups of closely related tasks and procedures, in which occupational exposure may occur for these individuals:
JOB TITLE | DEPARTMENT/LOCATION | TASK/PROCEDURE |
(Example: Housekeeper | Environmental Services | Handling Regulated Waste) |
Part-time, temporary, contract and per diem employees are covered by the standard. How the provisions of the standard will be met for these employees should be described in the ECP.
METHODS OF IMPLEMENTATION AND CONTROL
Universal Precautions
All employees will utilize universal precautions.
Exposure Control Plan
Employees covered by the bloodborne pathogens standard receive an explanation of this ECP during their initial training session. It will also be reviewed in their annual refresher training. All employees have an opportunity to review this plan at any time during their work shifts by contacting _(Name of responsible person or department)__________. If requested, we will provide an employee with a copy of the ECP free of charge and within 15 days of the request.
___(Name of responsible person or department)_________________ is responsible for reviewing and updating the ECP annually or more frequently if necessary to reflect any new or modified tasks and procedures which affect occupational exposure and to reflect new or revised employee positions with occupational exposure.
Engineering Controls and Work Practices
Engineering controls and work practice controls will be used to prevent or minimize exposure to bloodborne pathogens. The specific engineering controls and work practice controls used are listed below:
- _(For example: non-glass capillary tubes, SESIPs, needleless systems)
- __________________________________________________________
- __________________________________________________________
Sharps disposal containers are inspected and maintained or replaced by ___(Name of responsible person or department)_____________________ every ___(list frequency______________ or whenever necessary to prevent overfilling.
This facility identifies the need for changes in engineering control and work practices through (Examples: Review of OSHA records, employee interviews, committee activities, etc.) _____
We evaluate new procedures or new products regularly by (Describe the process, literature reviewed, supplier info, products considered) ____________________________________
Both front line workers and management officials are involved in this process: (Describe how employees will be involved) ___________________________________________________
(Name of responsible person or department) will ensure effective implementation of these recommendations. ________________________________________________________
Personal Protective Equipment (PPE)
PPE is provided to our employees at no cost to them. Training is provided by __(Name of responsible person or department)______________________ in the use of the appropriate PPE for the tasks or procedures employees will perform.
The types of PPE available to employees are as follows: __(Ex., gloves, eye protection, etc.)___________________________________________________________________
PPE is located ____(List location)_______________________________ and may be obtained through_(Name of responsible person or department)_____ (Specify how employees are to obtain PPE, and who is responsible for ensuring that it is available.)
All employees using PPE must observe the following precautions:
- Wash hands immediately or as soon as feasible after removal of gloves or other PPE.
- Remove PPE after it becomes contaminated, and before leaving the work area.
- Used PPE may be disposed of in _____________(List appropriate containers for storage, laundering, decontamination, or disposal.)
- Wear appropriate gloves when it can be reasonably anticipated that there may be hand contact with blood or OPIM, and when handling or touching contaminated items or surfaces; replace gloves if torn, punctured, contaminated, or if their ability to function as a barrier is compromised.
- Utility gloves may be decontaminated for reuse if their integrity is not compromised; discard utility gloves if they show signs of cracking, peeling, tearing, puncturing, or deterioration.
- Never wash or decontaminate disposable gloves for reuse.
- Wear appropriate face and eye protection when splashes, sprays, spatters, or droplets of blood or OPIM pose a hazard to the eye, nose, or mouth.
- Remove immediately or as soon as feasible any garment contaminated by blood or OPIM, in such a way as to avoid contact with the outer surface.
The procedure for handling used PPE is as follows: (may refer to specific agency procedure by title or number and last date of review) ____________________________________________________________________________________________________________________________________________________________________________________________________________________________________
(For example, how and where to decontaminate face shields, eye protection, resuscitation equipment)
Housekeeping
Regulated waste is placed in containers which are closable, constructed to contain all contents and prevent leakage, appropriately labeled or color-coded (see Labels), and closed prior to removal to prevent spillage or protrusion of contents during handling.
The procedure for handling sharps disposal containers is: (may refer to specific agency procedure by title or number and last date of review)
____________________________________________________________________________________________________________________________________________________________________________________________________________________________________
The procedure for handling other regulated waste is: (may refer to specific agency procedure by title or number and last date of review)
____________________________________________________________________________________________________________________________________________________________________________________________________________________________________
Contaminated sharps
are discarded immediately or as soon as possible in containers that are closable, puncture-resistant, leakproof on sides and bottoms, and labeled or color coded appropriately. Sharps disposal containers are available at __________(must be easily accessible and as close as feasible to the immediate area where sharps are used).
Bins and pails
(e.g. wash or emesis basins) are cleaned and decontaminated as soon as feasible after visible contamination.
Broken glassware
which may be contaminated is picked up using mechanical means, such as a brush and dust pan.
Laundry
The following contaminated articles will be laundered by this company: ____________________________________________________________________________________________________________________________________________________________________________________________________________________________________
Laundering will be performed by _(Name of responsible person or department) _______________________ at (time and/or location) .
The following laundering requirements must be met:
- handle contaminated laundry as little as possible, with minimal agitation
- place wet contaminated laundry in leak-proof, labeled or color-coded containers before transport. Use (red bags or bags marked with biohazard symbol)___________________ for this purpose.
- wear the following PPE when handling and/or sorting contaminated laundry: (List appropriate PPE)______________________
Labels
The following labeling method(s) is used in this facility:
EQUIPMENT TO BE LABELED | LABEL TYPE (Size, Color etc) |
(e.g., specimens, contaminated laundry, etc.) | (_red bag, biohazard label, etc.) |
__(Name of responsible person or department)______________________ will ensure warning labels are affixed or red bags are used as required if regulated waste or contaminated equipment is brought into the facility. Employees are to notify ________________________ if they discover regulated waste containers, refrigerators containing blood or OPIM, contaminated equipment, etc. without proper labels.
HEPATITIS B VACCINATION
(Name of responsible person or department)________________________ will provide training to employees on hepatitis B vaccinations, addressing the safety, benefits, efficacy, methods of administration, and availability.
The hepatitis B vaccination series is available at no cost after training and within 10 days of initial assignment to employees identified in the exposure determination section of this plan. Vaccination is encouraged unless:
- Documentation exists that the employee has previously received the series,
- Antibody testing reveals that the employee is immune, or
- Medical evaluation shows that vaccination is contraindicated.
However, if an employee chooses to decline vaccination, the employee must sign a declination form. Employees who decline may request and obtain the vaccination at a later date at no cost. Documentation of refusal of the vaccination is kept at _______(List location or person responsible for this recordkeeping).
Vaccination will be provided by ____(List Health care Professional who is responsible for this part of the plan)___ at ___(location)____ .
Following the medical evaluation, a copy of the health care professional’s Written Opinion will be obtained and provided to the employee. It will be limited to whether the employee requires the hepatitis vaccine, and whether the vaccine was administered.
POST-EXPOSURE EVALUATION AND FOLLOW-UP
Should an exposure incident occur, contact ____(Name of responsible person) at the following number:_____________________________.
An immediately available confidential medical evaluation and follow-up will be conducted by (Licenced health care professional) . Following the initial first aid (clean the wound, flush eyes or other mucous membrane, etc.), the following activities will be performed:
- Document the routes of exposure and how the exposure occurred.
- Identify and document the source individual (unless the employer can establish that identification is infeasible or prohibited by state or local law).
- Obtain consent and make arrangements to have the source individual tested as soon as possible to determine HIV, HCV, and HBV infectivity; document that the source individual’s test results were conveyed to the employee’s health care provider.
- If the source individual is already known to be HIV, HCV and/or HBV positive, new testing need not be performed.
- Assure that the exposed employee is provided with the source individual’s test results and with information about applicable disclosure laws and regulations concerning the identity and infectious status of the source individual (e.g., laws protecting confidentiality).
- After obtaining consent, collect exposed employee’s blood as soon as feasible after exposure incident, and test blood for HBV and HIV serological status
- If the employee does not give consent for HIV serological testing during collection of blood for baseline testing, preserve the baseline blood sample for at least 90 days; if the exposed employee elects to have the baseline sample tested during this waiting period, perform testing as soon as feasible.
ADMINISTRATION OF POST-EXPOSURE EVALUATION AND FOLLOW-UP
(Name of responsible person or department)________________________ ensures that health care professional(s) responsible for employee’s hepatitis B vaccination and post-exposure evaluation and follow-up are given a copy of OSHA’s bloodborne pathogens standard.
___(Name of responsible person or department)_____________________ ensures that the health care professional evaluating an employee after an exposure incident receives the following:
- A description of the employee’s job duties relevant to the exposure incident
- Route(s) of exposure
- Circumstances of exposure
- If possible, results of the source individual’s blood test
- Relevant employee medical records, including vaccination status
__(Name of responsible person or department)_______________________provides the employee with a copy of the evaluating health care professional’s written opinion within 15 days after completion of the evaluation.
PROCEDURES FOR EVALUATING THE CIRCUMSTANCES SURROUNDING AN EXPOSURE INCIDENT
(Name of responsible person or department)________________________ will review the circumstances of all exposure incidents to determine:
- Engineering controls in use at the time
- Work practices followed
- A description of the device being used (including type and brand)
- Protective equipment or clothing that was used at the time of the exposure incident (gloves, eye shields, etc.)
- Location of the incident (O.R., E.R., patient room, etc.)
- Procedure being performed when the incident occurred
- Employee’s training
(Name of Responsible Person) _____________________ will record all percutaneous injuries from contaminated sharps in the Sharps Injury Log.
If it is determined that revisions need to be made, __(Responsible person or department)___________________ will ensure that appropriate changes are made to this ECP. (Changes may include an evaluation of safer devices, adding employees to the exposure determination list, etc.)
EMPLOYEE TRAINING
All employees who have occupational exposure to bloodborne pathogens receive training conducted by _________ (Name of responsible person or department)________ . (Attach a brief description of their qualifications.)
All employees who have occupational exposure to bloodborne pathogens receive training on the epidemiology, symptoms, and transmission of bloodborne pathogen diseases. In addition, the training program covers, at a minimum, the following elements:
- a copy and explanation of the standard
- an explanation of our ECP and how to obtain a copy
- an explanation of methods to recognize tasks and other activities that may involve exposure to blood and OPIM, including what constitutes an exposure incident
- an explanation of the use and limitations of engineering controls, work practices, and PPE
- an explanation of the types, uses, location, removal, handling, decontamination, and disposal of PPE
- an explanation of the basis for PPE selection
- information on the hepatitis B vaccine, including information on its efficacy, safety, method of administration, the benefits of being vaccinated, and that the vaccine will be offered free of charge
- information on the appropriate actions to take and persons to contact in an emergency involving blood or OPIM
- an explanation of the procedure to follow if an exposure incident occurs, including the method of reporting the incident and the medical follow-up that will be made available
- information on the post-exposure evaluation and follow-up that the employer is required to provide for the employee following an exposure incident
- an explanation of the signs and labels and/or color coding required by the standard and used at this facility
- an opportunity for interactive questions and answers with the person conducting the training session.
Training materials for this facility are available at ___________________________.
RECORDKEEPING
Training Records
Training records are completed for each employee upon completion of training. These documents will be kept for at least three years at __(Name of responsible person or location of records)______________________.
The training records include:
- the dates of the training sessions
- the contents or a summary of the training sessions
- the names and qualifications of persons conducting the training
- the names and job titles of all persons attending the training sessions
Employee training records are provided upon request to the employee or the employee’s authorized representative within 15 working days. Such requests should be addressed to _____(Name of Responsible person or department)_____________________________________.
Medical Records
Medical records are maintained for each employee with occupational exposure in accordance with 29 CFR 1910.1020, “Access to Employee Exposure and Medical Records.”
Medical records are maintained for each employee with occupational exposure in accordance with 29 CFR 1910.1020, “Access to Employee Exposure and Medical Records.” (Name of Responsible person or department) is responsible for maintenance of the required medical records.
These confidential records are kept at ____(List location)________________for at least the duration of employment plus 30 years.
Employee medical records are provided upon request of the employee or to anyone having written consent of the employee within 15 working days. Such requests should be sent to ____(Name of responsible person or department and address)______
OSHA Recordkeeping
An exposure incident is evaluated to determine if the case meets OSHA’s Recordkeeping Requirements (29 CFR 1904). This determination and the recording activities are done by _(Name of responsible person or department)___________.
Sharps Injury Log
In addition to the 1904 Recordkeeping Requirements, all percutaneous injuries from contaminated sharps are also recorded in the Sharps Injury Log. All incidences must include at least:
- The date of the injury
- The type and brand of the device involved
- The department or work area where the incident occurred
- An explanation of how the incident occurred.
This log is reviewed at least annually as part of the annual evaluation of the program and is maintained for at least five years following the end of the calendar year that they cover. If a copy is requested by anyone, it must have any personal identifiers removed from the report.
SAMPLE EMPLOYEE HEPATITIS B VACCINE DECLINATION (MANDATORY)
I understand that due to my occupational exposure to blood or other potentially infectious materials I may be at risk of acquiring hepatitis B virus (HBV) infection. I have been given the opportunity to be vaccinated with hepatitis B vaccine, at no charge to myself. However, I decline hepatitis B vaccination at this time. I understand that by declining this vaccine, I continue to be at risk of acquiring hepatitis B, a serious disease. If in the future I continue to have occupational exposure to blood or other potentially infectious materials and I want to be vaccinated with hepatitis B vaccine, I can receive the vaccination series at no charge to me.
Signed:__(Employee Name)______________________________
Date:________________________
Exposure Plans for Tattoo Studios
Tattoo studios, body art studios, microblading clinics and several other business types are covered by the bloodborne pathogens standard. Fortunately, there are no specific additional requirements for these businesses with regards to the expsoure control plan.
That being said, a part of the ECP is the training element, and tattooists and others do need to undertake special bloodborne pathogens certification for tattoo artists that covers information essential to working in body art environments.
Developing a BBP Exposure Control Plan: Summary
We hope the information in this article helped you in developing your exposure control plan. It is a significant undertaking to develop a compliant ECP but you can rest easy afterward knowing that your business is compliant and your workers are protected.
An important component of the ECP is the documentation of the training approach and training records. If you need to get a bloodborne pathogens certificate for your employees we offer fully compliant training that covers all topics required in the standard.
