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Does Your Exposure Control Plan Cover All the Bases?

Clendenning Donna Posted by Donna Clendenning


OSHA estimates that 5.6 million workers in the healthcare industry and related occupations are at risk of occupational exposure to Bloodborne Pathogens.  Check out their health care hazards page for more information. 

Recently, I have been reviewing written Exposure Control Plans (ECP) for employers that have occupational exposure risks to blood borne pathogens and/or other potentially infectious disease.  General Industry Standard 1910.1030 covers the details of Bloodborne Pathogens and the requirement to have a written ECP 1910.1030(c).

A common thread found among employers is that their written Exposure Control Plans are not updated (annually and whenever necessary) to reflect new or modified tasks and procedures which affect occupational exposure risks.  Refer to 1910.1030(c)(1)(iv).

The annual review requires employers who have occupational exposure risks to “document annually consideration and implementation of appropriate commercially available and effective safer medical devices designed to eliminate or minimize occupational exposure.”  1910.1030(c)(1)(iv)(B).

Further, the standard requires solicitation and input in the identification, evaluation, and selection of effective engineering and work practice controls from non-managerial employees who are responsible for direct patient care and are at risk from contaminated sharps.  The evaluation and selection process must be documented annually in the Exposure Control Plan. 1910.1030(c)(1)(v).

For further information on the requirements of your written Exposure Control Plan, go to OSHA’s Bloodborne Pathogens and Needle Stick prevention page.  

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