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Exposure Control Plan: What is it and Why Does Your Office Need One?

Kevin Webber - Mar 30, 2018 7:45:00 AM

OSHA-Exposure-Control-Plan-StandardsThe Occupational Safety and Health Administration (OSHA) was created with the Occupational Safety and Health Act of 1970 to ensure worker and workplace safety. In addition to setting and enforcing standards, the agency provides training, outreach, education, and assistance. There are many risks associated with OSHA violations, such as potential chemical and drug exposures, fire and electrical hazards, respiratory hazards, and others. OSHA standards require that you train your employees in the safety and health aspects of their jobs to ensure that they do not get hurt.

The Bloodborne Pathogens (BBP) Standard applies specifically to all of your employees who are exposed to blood or any other potentially infectious materials. This safeguards against health hazards caused by bloodborne pathogens. One of the requirements of the standard is the development of an Exposure Control Plan. Let’s look at why this plan is so important and how to develop one for your practice.

Why is an Exposure Control Plan Important?

A central requirement of the BBP standard is the development of an exposure control plan if exposure to blood or other body fluids is reasonably anticipated. The plan will help you protect your employees from potential exposure to potentially infectious materials. Also, by protecting staff, you will also control exposure incident costs. The health of your patients will be protected, because an employee who has been exposed to a bloodborne disease could potentially pose a threat to anyone in your medical facility. Finally, the plan will also help protect the health of your employees’ family members.

If one of your employees is exposed to a patient’s blood, he or she may need to be examined or tested and possibly undergo treatment or counseling. An employee who has been exposed to a bloodborne disease may have to take time off from work to cope with the illness. Their absence could negatively impact family members as well as your medical practice.

What is an Exposure Control Plan?

Your Exposure Control Plan will be used for answering any questions that your employees might have about bloodborne pathogens. It should be a “living document” that is updated on a regular basis and will help ensure that exposure control activities are in place at your medical facility. You must regularly educate your employees on the uses of the plan and where it is located, so that it is available when needed.

What Criteria Must an Exposure Control Plan Meet?

According to OSHA’s BBP Standard, your Exposure Control Plan must meet the following criteria:

  • Be written specifically for each facility
  • Be reviewed and updated on an annual basis (to reflect changes such as new employees)
  • Include engineering and work practice controls used to reduce exposures to blood or body fluids
  • Be readily available to all employees

The plan begins with an exposure determination, listing all job classifications in which all employees may be expected to to incur occupational exposure. A listing of job classifications and tasks is also required for those employees who may have some exposure.

Compliance methods for both should be outlined, including all precautions that are observed to limit exposure. These methods would include steps such as work area restrictions, procedures for handling Sharps containers, use of Personal Protective Equipment (PPE), regulated medical waste disposal practices, employee training, etc. OSHA has a guide for developing an Exposure Control Plan that meets their standards and a template, the Model Plans and Programs for the OSHA Bloodborne Pathogens and Hazard Communications Standard, that can help you put together your plan.

Your facility’s Exposure Control Plan is a key document to assist you in implementing and maintaining OSHA compliance to protect your employees. Annual OSHA training is mandatory and the BBP course should be taken by all employees with a reasonable anticipated risk of exposure. Need help with compliance training for your medical office? We offer compliance solutions for all our waste service customers, including convenient online training.

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Topics: Compliance

Kevin Webber

Kevin Webber

Kevin Webber is a partner at TriHaz Solutions and actively involved in the day-to-day business from a strategic and operational standpoint. He has a successful background in business/investment management and entrepreneurship, including recognition by Inc. Magazine’s 5000 list of fastest-growing private companies.

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