Continuing on with our series on the most frequently asked questions regarding OSHA's Bloodborne Pathogens Standard this post covers everything under the "exposure control" section.
If you would like to read our previous post on scope, please click here.
This blog post is not intended to be used as a substitute for the standard's requirements. Please refer to the standard for the complete text.
Q1. What is an exposure control plan?
A1. The exposure control plan is the employer's written program that outlines the protective measures an employer will take to eliminate or minimize employee exposure to blood and OPIM.
The exposure control plan must contain, at a minimum:
- The exposure determination which identifies job classifications with occupational exposure and tasks and procedures where there is occupational exposure and that are performed by employees in job classifications in which some employees have occupational exposure.
- The procedures for evaluating the circumstances surrounding exposure incidents;
- A schedule of how other provisions of the standard are implemented, including methods of compliance, 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; Methods of compliance include:
- Universal Precautions;
- Engineering and work practice controls, e.g., safer medical devices, sharps disposal containers, hand hygiene;
- Personal protective equipment;
- Housekeeping, including decontamination procedures and removal of regulated waste.
- 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 healthcare workers (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.
Q2. In the exposure control plan, are employers required to list specific tasks that place the employee at risk for all job classifications?
A2. No. If all the employees within a specific job classification perform duties where occupational exposure occurs, then a list of specific tasks and procedures is not required for that job classification. However, the job classification (e.g., "nurse") must be listed in the plan's exposure determination, and all employees within the job classification must be included under the requirements of the standard.
Q3. Can tasks and procedures be grouped for certain job classifications?
A3. Yes. Tasks and procedures that are closely related may be grouped. In other words, they must share a common activity, such as "vascular access procedure" or "handling of contaminated sharps."
Q4. Does the exposure control plan need to be a separate document?
A4. No. 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. However, in order for the plan to be accessible to employees, it must be a cohesive entity by itself or there must be a guiding document which states the overall policy and goals and references the elements of existing separate policies that comprise the plan. For small facilities, the plan's schedule and method of implementation of the standard may be an annotated copy of the final standard that states on the document how the provisions of the standard are implemented. Larger facilities could develop a broad facility program, incorporating provisions from the standard that apply to their establishments.
Q5. How often must the exposure control plan be reviewed?
A5. The standard requires an annual review of the exposure control plan. In addition, whenever changes in tasks, procedures, or employee positions affect, or create new occupational exposure, the existing plan must be reviewed and updated accordingly.
Q6. Must the exposure control plan be accessible to employees?
A6. Yes, the exposure control plan must be accessible to employees, as well as to OSHA and NIOSH representatives. The location of the plan may be adapted to the circumstances of a particular workplace, provided that employees can access a copy at the workplace during the workshift. If the plan is maintained solely on computer, employees must be trained to operate the computer.
A hard copy of the exposure control plan must be provided within 15 working days of the employee's request in accord with 29 CFR 1910.1020.
Q7. What should be included in the evaluation of an exposure incident?
A7. Following an exposure incident, employers are required to document, at a minimum, the route(s) of exposure, and the circumstances under which the exposure incident occurred. To be useful, the documentation must contain sufficient detail about the incident. There should be information about the following:
- The engineering controls in use at the time and work practices followed;
- Description of the device in use;
- The protective equipment or clothing used at the time of the exposure incident;
- Location of the incident and procedures being performed when the incident occurred; and
- Employee’s training.
- The source individual, unless the employer can establish that identification is infeasible or prohibited by state or local law.
The employer should then evaluate the policies and "failures of controls" at the time of the exposure incident to determine actions that could prevent future incidents.
Are you concerned that your facility does not have a kit designed for OSHA's Bloodborne Pathogens Standard? This kit is designed to help in OSHA Standard Compliance (1910.1030) and combines personal protection and clean-up items mandated by OSHA, CDC, and State Health Departments to aid in the clean-up, transportation, and disposal of potentially infectious blood or body fluid spills.
The information contained is this document is not considered a substitute for any provisions of the Occupational Safety and Health Act of 1970 (OSH Act) or the requirements of 29 CFR 1910.1030, Occupational Exposure to Bloodborne Pathogens.