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If you’ve got a first aid team then your employees need to be covered by a bloodborne pathogens (BBP) exposure control plan. Keep in mind the BBP standard isn’t limited to the healthcare industry. Preliminary enforcement data from fiscal year 2022 shows that nearly 40 percent of BBP violations went to industries other than healthcare, including manufacturing, warehousing and storage, and retail. You’ll need to consider the jobs and tasks in your workplace to make an exposure determination.

What’s considered “occupational exposure”?

The standard defines occupational exposure as “reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials (OPIM) that may result from the performance of an employee’s duties.” In simpler terms, occupational exposure means that your employees could be exposed to blood or OPIM in the course of their work.

What must be included in the exposure control plan?

Essentially, the exposure control plan identifies workers with occupational exposure and explains how you’ll protect and train them. It must contain:

  • An explanation of how the exposure determination was made.
  • A schedule of how other provisions of 1910.1030 are implemented, including:
    • Methods of compliance, such as:
      • Universal Precautions;
      • Engineering and work practice controls, such as safer medical devices, sharps disposal containers, and hand hygiene;
      • Personal protective equipment; and
      • Housekeeping, including decontamination procedures and removal of regulated waste.
    • HIV and HBV research laboratories and production facilities requirements,
    • Hepatitis B vaccination and post-exposure evaluation and follow-up,
    • Communication of hazards to employees, and
    • Recordkeeping;
  • The procedure for evaluating the circumstances surrounding exposure incidents.
  • Documentation of:
    • The annual consideration and implementation of appropriate commercially available and effective safer medical devices designed to eliminate or minimize occupational exposure, and
    • The solicitation of non-managerial employees who are responsible for direct patient care and are potentially exposed to injuries from contaminated sharps in the identification, evaluation, and selection of effective engineering and work practice controls.
    If, after employee input, an employer determines that an engineering control is effective, the employer must simply keep abreast of new and emerging technologies and document this in the plan. It’s not necessary to evaluate all newly emerging engineering controls each year, but employers must make a concerted effort to evaluate new technologies in order to determine which device is effective in reducing injuries.

OSHA notes that the exposure control plan may be part of another document, such as the facility’s health and safety manual, as long as all components are included. For the plan to be accessible to employees, however, it either must be a cohesive entity by itself or there must be a guiding document that states the overall policy and goals and references the elements of existing separate policies that make up the plan.

For small facilities, the plan’s schedule and method of implementation of the standard may be an annotated copy of 1910.1030 that states on the document how its provisions are implemented. Larger facilities could develop a broad facility program, incorporating provisions from the standard that apply to their establishments.

Reviewing and updating your plan

The exposure control plan must be reviewed and updated at least annually - and whenever changes that could impact the program are made - to reflect:

  • New or modified tasks and procedures which affect occupational exposure.
  • New or revised employee positions with occupational exposure.

The review and update must also:

  • Reflect changes in technology that eliminate or reduce exposure to bloodborne pathogens, and
  • Document consideration and implementation of appropriate commercially available and effective safer medical devices designed to eliminate or minimize occupational exposure.

Key to remember

If you have employees with occupational exposure to BBP, you must develop a written exposure control plan.