What’s required in a bloodborne pathogens exposure control plan?

Employers covered by the bloodborne pathogens standard at 29 CFR 1910.1030 must have a written exposure control plan that identifies employees with occupational exposure, lays out a timetable for compliance with the standard, and addresses other elements of the standard as applicable to the workplace.

Occupational exposure is defined 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.”

What must be included in the exposure control plan?

The exposure control plan identifies employees who have occupational exposure and commits the employer to a timetable for implementing the standard’s requirements. The plan must also address paragraphs (d)-(h) of 1910.1030 in a way that’s appropriate to the circumstances of the particular workplace.

Broadly, these paragraphs cover:

• Methods of compliance for employers with employees with occupational exposure,
• Regulations applying to certain facilities producing or performing laboratory study of human immunodeficiency virus (HIV) or hepatitis B virus (HBV),
• Hepatitis B vaccination and post-exposure evaluation and follow-up,
• Employee training and communication, and
• Recordkeeping.

At a minimum, the plan must include:

• The exposure determination required by 1910.1030(c)(2).
• The schedule and method of implementation for 1910.1030(d)-(h). This can be as simple as an annotated copy of the regulation that states when and how the provisions of the regulation will be complied with.
• The procedure for evaluating the circumstances surrounding exposure incidents.
• Documentation of the employer’s solicitation of input from non-managerial employees who are responsible for direct patient care and who are potentially exposed to injuries from contaminated sharps. The employer must ask these employees for input in identifying, evaluating, and selecting effective engineering and work practice controls.

Employers may wish to also include the required documentation that they annually considered and implemented appropriate commercially available and effective safer medical devices designed to eliminate or minimize occupational exposure.

If a plan element isn’t applicable to the specific workplace, the plan should include it but state directly that the element does not apply and explain why.

Reviewing and updating the plan

The plan must be reviewed and updated at least annually and whenever necessary to reflect changes in tasks, procedures, and positions that affect occupational exposure. These plan reviews and updates include:

• Technological changes that eliminate or reduce occupational exposure, such as effective engineering controls;
• Consideration and implementation of appropriate commercially available and effective safer medical devices designed to eliminate or minimize occupational exposure.

The exposure control plan must include the procedure for evaluating the circumstances surrounding exposure incidents, which might also lead to changes during reviews of the plan.

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