• Employers with an exposure control plan must solicit input on engineering and work practice controls from their non-managerial employees who are responsible for direct patient care.

Any employer who’s required to have an exposure control plan must solicit input from non-managerial employees who are responsible for direct patient care and who are potentially exposed to injuries from contaminated sharps. These employees must have input into the identification, selection, and evaluation of effective engineering and work practice controls. The employer then must document the solicitation in the written exposure control plan.

The employer must solicit employee input in ways that are appropriate to the circumstances in the workplace. These may include:

• Joint labor-management safety committees;
• Informal problem-solving groups;
• Participation in safety meetings and audits, employee surveys, worksite inspections, or exposure incident investigations;
• A suggestion box or other effective method for collecting written comments;
• Participation in pilot testing to evaluate devices; and
• Requests through the bargaining agent of employees covered by a collective bargaining agreement.

Employers must clearly and effectively communicate these opportunities to employees. Employers don’t need to receive input from every employee who provides direct patient care and who is potentially exposed to contaminated sharps. However, the employees selected to provide input must represent the range of exposure situations encountered in the workplace (e.g., emergency department, pediatrics, nuclear medicine). The employer also must document the process by which the input was requested and identify the employees or the positions of those employees who were involved.

If employees with occupational exposure are not responsible for patient care, this solicitation isn’t necessary. Laboratory workers, for example, who do not have patient contact, would not be included in this provision. However, where this solicitation provision is not required, the written plan needs to document that this element does not apply because the employees don’t perform direct patient care or are not potentially exposed to contaminated sharps.