Developing a Bloodborne Pathogen Exposure Control Plan: What Businesses Need to Know

As an employer or member of management, you have a responsibility to ensure the health and safety of your employees. For certain industries, this includes protecting them from exposure to bloodborne pathogens, which are infectious microorganisms (such as HIV, hepatitis B, and hepatitis C) in human blood that can cause disease.

To meet this obligation, it’s important to have a comprehensive Bloodborne Pathogen Exposure Control Plan (sometimes called a needlestick plan). This plan outlines the measures you will take to prevent exposure to bloodborne pathogens, and the steps you will take in the event of exposure.

What Businesses Need an Exposure Control Plan?

Any employer whose employees are regularly exposed to blood or other potentially infectious materials (OPIM) must develop an exposure control plan. Examples include employers in the following industries:

• Healthcare
• tattooing
• body piercing
• Funeral services
• Correctional facilities

Why is an Exposure Control Plan Important?

1. It helps you protect your workers.
2. The cost of an exposure incident can be significant–including post-exposure treatment, counseling, and loss of employee work time. If an employee contracts a disease, those costs can dramatically increase. The plan helps avoid or reduce these costs by reducing the risk of exposure.
3. If your workers are at risk for bloodborne pathogens exposure, you are required by law to have a written Exposure Control Plan. You will become intimately familiar with OSHA’s Bloodborne Pathogens Standard 29 CFR 1910.1030.

How Do You Develop an Exposure Control Plan?

An Exposure Control Plan is tailored to the specific workplace includes an evaluation of tasks and procedures, identification of employee exposure risks, methods for reducing risk, and training requirements. It must identify the types of personal protective equipment (PPE) to be used and procedures for cleaning and disposing of contaminated materials. It must include information on post-exposure care and procedures for reporting incidents of exposure.

It’s important to note that the Exposure Control Plan must be reviewed and updated at least once a year in order to remain effective. They should also be evaluated whenever there is a change in the workplace environment or processes that may increase the risk of exposure or require additional safety measures.

What Are the Basic Elements of the Plan?

The Occupational Safety and Health Administration (OSHA) sets standards for the control of bloodborne pathogens in the workplace. The basic elements of a Bloodborne Pathogen Exposure Control Plan according to OSHA include:

• Written policy: A written policy statement that outlines the employer’s commitment to protecting employees from exposure to bloodborne pathogens.
• Identification of job classifications and tasks that may result in exposure: A list of job classifications and tasks that may result in exposure to bloodborne pathogens, and the specific hazards associated with each task.
• Engineering and work practice controls: The use of engineering and work practice controls to eliminate or minimize exposure to bloodborne pathogens.
• Use of personal protective equipment: The use of personal protective equipment, such as gloves, gowns, and eye protection, to prevent exposure to bloodborne pathogens.
• Hepatitis B vaccine and post-exposure evaluation and follow-up: The provision of the hepatitis B vaccine to employees who are at risk of exposure, and post-exposure evaluation and follow-up, including medical evaluation and testing, as needed.
• Training: Information and training provided to employees on the dangers of bloodborne pathogens, how to prevent exposure, and what to do in the event of an exposure.
• Recordkeeping: Documentation of exposure incidents, training records, and other relevant information related to the Bloodborne Pathogen Exposure Control Plan.
• Program evaluation: A process for regularly evaluating the effectiveness of the Bloodborne Pathogen Exposure Control Plan, and making any necessary revisions.

By taking steps such as establishing and implementing an appropriate exposure control plan, employers can help protect their workers from the dangers posed by bloodborne pathogens. Doing so is essential for ensuring a safe and healthy working environment for all–and remaining in compliance with OSHA, of course.

For more information and model plans, the following resources are a great place to begin your research:

• CDC BBP: www.cdc.gov/niosh/topics/bbp/default.html
• NIOSH: www.cdc.gov/niosh/
• OSHA BBP: www.osha.gov/SLTC/bloodbornepathogens/index.html
• OSHA: Model Plans and Programs for the Bloodborne Pathogens and Hazard Communications Standards, www.osha.gov/ Publications/osha3186.html