SECTION 5 - Exposure control plan

Written by Judy Haluka

Identify job classifications, tasks, and procedures that put employees at risk of exposure. Establish a written exposure control plan, and make it available to all employees with potential risk. The plan must be reviewed and updated annually. There are specific items that must be addressed by the plan. These items include:

• Appointing an exposure control officer and education and training coordinator.
• Exposure determination.
• Exposure control plan.
• Engineering controls.
• Work control practices.
• Personal protective equipment.
• Contaminated waste housekeeping.
• Exposure investigation.
• Hepatitis B program.
• Post-exposure evaluation and follow-up.
• Record keeping (training).
• Labeling and signs.

We will provide an example of a generic exposure control plan containing each of the above sections at the end of this section.

Safety devices

Evaluate medical devices with engineered sharps injury protection, such as commercially available sharps containers.

Involve front line employees in the evaluation and selection process for safety equipment.

Document the evaluation and selection of the equipment.

Hepatitis B vaccination

Offer free hepatitis B vaccinations to all employees with occupational exposure to blood or other potentially infectious materials.

Other

Ensure that employees comply with universal precautions.

Have a program in place for those that are exposed.

Access to the California bloodborne pathogens standard

In compliance with California Health and Safety Code Section 119307(c)(3)(A), the full text of the California Division of Occupational Safety and Health (Cal/OSHA) Bloodborne Pathogens Standard (Title 8, Section 5193) is available at the following link: https://www.dir.ca.gov/title8/5193.html

This document outlines the complete legal requirements for protecting employees from bloodborne pathogen exposure in California workplaces. It includes definitions, employer responsibilities, engineering and work practice controls, personal protective equipment (PPE), training, medical evaluations, recordkeeping, and labeling requirements.

Train all occupationally exposed employees at the initial assignment and at least annually. Training must include:

• An accessible copy of the BBP standard (29 CFR 1910.1030)
• Information on the epidemiology and symptoms of bloodborne diseases
• Information on modes of transmission of BBPs
• Description of the employer’s exposure control plan and how to get a copy
• How to recognize tasks that may involve exposure to blood
• Use and limitations of methods to reduce exposure, including engineering controls, work practices and personal protective equipment
• Information on the hepatitis B vaccine
• What to do and whom to contact after an exposure
• Information on post-exposure evaluation and follow-up
• An opportunity for interactive questions and answers

Every company will have a unique exposure control plan that follows the same general outline to meet the requirements of the BBP standard. This model exposure control plan, written and implemented by an Emergency Medical Services Agency, is intended to serve employers as an example exposure control plan which is required by the Bloodborne Pathogens Standard.

Each employer will need to adjust or adapt the model for their specific use. The information contained in this model is not considered a substitute for any provisions of OSHA standards. It provides guidance but should not be considered a definitive interpretation for compliance with OSHA requirements.

Bloodborne pathogen standard

Model exposure control plan

Although each of the above positions needs a person to be assigned, they can overlap. For example, the training coordinator may be in charge of training recordkeeping as well.

Purpose

• To reduce exposure of employees to the hepatitis B virus, HIV, and other bloodborne pathogens
• To provide appropriate education regarding minimizing exposure
• To ensure that the risks of exposure to bloodborne pathogens are not underestimated
• To provide appropriate treatment and counseling should an employee be exposed to a Bloodborne Pathogen
• To meet OSHA Bloodborne pathogen standards

General management

Responsible persons

• Exposure control officer
• Managers and supervisors
• Education and training coordinator
• Employees

The following sections define the roles played by each of these groups in carrying out our plan. Throughout this written plan, employees with specific responsibilities are identified. If because of promotion or other reasons, a new employee is assigned any of these responsibilities, ________________________________________ is to be notified of the change so that the plan can be updated.

Exposure control officer

The exposure control officer will be responsible for the overall management and support of our facility’s Bloodborne Pathogens Compliance Program. Activities that are delegated to the exposure control officer typically include, but are not limited to:

• Overall responsibility for implementing the exposure control plan for the entire facility
• Working with the administration and other employees to develop and administer any additional bloodborne pathogens related policies and practices needed to support the effective implementation of this plan
• Investigating ways to improve the exposure control plan, as well as to revise and update the plan when necessary
• Collecting and maintaining a suitable reference library on the Bloodborne Pathogens Standards and bloodborne pathogens safety and health information
• Knowing current legal requirements concerning bloodborne pathogens
• Acting as a facility liaison during OSHA inspections
• Conducting periodic facility audit to maintain an up-to-date exposure control plan

________________________________________ has been appointed as the facility’s exposure control officer. We have determined that the exposure control officer will require assistance in fulfilling his responsibilities. To assist him/her in carrying out his duties, we have created an exposure control committee composed of the following people.

Exposure control committee

Education and training coordinator

The Education and Training Coordinator will be responsible for providing information and training to all employees who have the potential for exposure to bloodborne pathogens. Activities falling under the direction of the coordinator include:

• Maintaining an up-to-date list of facility personnel requiring training in conjunction with facility management
• Developing suitable education and training programs
• Schedule periodic training seminars for employees
• Maintaining appropriate training documentation, such as sign in sheets for seminars
• Periodically reviewing the training program with the exposure control officer, managers, and supervisors

________________________________________has been selected as the facility’s Education and Training Coordinator.

Employees

As with all our facility’s activities, our employees have the most important role in our Bloodborne Pathogens Compliance Program. The ultimate execution of the plan rests in their hands. In this role, they must do things such as:

• Know what tasks they perform that have the potential for occupational exposure.
• Attend the Bloodborne Pathogens training sessions.
• Plan and conduct all operations in accordance with work practice controls.
• Develop good personal hygiene habits.

Availability of the exposure control plan to employees

To help them with their efforts, our facility’s exposure control plan is available to our employees at any time. They are advised of this availability during their education and training sessions. Copies of the exposure control plan are kept in the following locations.

• Office of the assistant director of operations
• Supervisor’s office

Review and update of the plan

We recognize that it is important to keep our exposure control plan up-to-date. To ensure this, the plan will be reviewed and updated under the following circumstances:

• Annually on or before ______________________
• Whenever new or modified tasks and procedures are implemented which affect occupational exposure to our employees
• Whenever our employees’ jobs are revised such that new instances of occupational exposure may occur
• Whenever we establish new functioning positions within our facility that may involve exposure to bloodborne pathogens

Exposure determination

One of the keys to implementing a successful exposure control plan is to identify exposure situations employees may encounter. To facilitate this in our facility, we have prepared the following lists:

• Job classifications in which all employees have occupational exposure to bloodborne pathogens
• Job classifications in which some employees have occupational exposure to bloodborne pathogens
• Tasks and procedures in which occupational exposure to bloodborne pathogens occur. (These tasks and procedures are performed by employees in the job classifications shown on the previous lists)

The initial lists were compiled on or before _____________________________ and updated on an annual basis. The exposure control committee will work with managers to revise and update these lists as our tasks, procedures, and classifications change.

Job classifications in which all employees have exposure to bloodborne pathogens

This list would change depending upon the type of facility the plan is being written for. For example, if a tattoo parlor, it would be a list of different people than for an ambulance service. All people and their positions that may be exposed must be listed here.

Job classifications in which some employees have exposure to bloodborne pathogens

As above, this list would change depending upon the type of facility. This list would contain people who may on occasion be exposed. For example, in a tattoo parlor, this may be the receptionist or at an ambulance service, this may be the mechanic.

Tasks and procedures that may result in exposure

Every task that may result in exposure is listed in detail here. For example:

• Changing needles for tattoos.
• Cleaning the table following service.

Everything that pertains to exposure must be listed here.

Methods of compliance

Universal precautions – explanation

Universal precautions is an approach to infection control. According to the concept of universal precautions, all human blood and certain human body fluids are treated as if known to be infectious.

To prevent the transmission of bloodborne infectious diseases, proper precautions are set forth by this policy. Universal blood and body fluid precautions will be used by all healthcare providers when delivering direct patient care or in situations where tasks may expose the employee or volunteer to bloodborne infectious material.

Universal precautions are regarded as a supplement not a replacement for routine infection control procedures and/or enteric precautions applicable to certain clinical situations presented by each patient.

Please note that although there have not been any recorded cases of HIV being transmitted by sweat and saliva, it is highly recommended that precautions are used when there is any risk of exposure.

A basic aseptic technique in addition to universal precautions practiced by employees can prevent the transmission of bloodborne pathogens in all settings.

The purpose of universal precautions is to prevent the transmission of all infectious diseases that are spread by blood or other potentially infectious material (OPIM).

Since medical history and examination cannot reliably identify all people who are infected with bloodborne pathogens, blood and OPIM must be used in all situations where exposure is possible.

Procedures

• Nonsterile gloves will be worn if contact with blood or OPIM may occur.
• Gowns will be worn if soiling of clothing with blood or OPIM may occur. The protections shall be impervious to blood or body fluids particularly in the chest and arm areas.
• Masks shall be worn if aerosolization of blood or body fluids may occur.
• Protective eyewear will be worn when splattering of blood or OPIM may occur.
• Hand washing will be done before and after contact with any client regardless of whether gloves were used. Hands contaminated with blood or body fluids will be washed as soon as possible.
• Contaminated articles – bag all non-disposable articles soiled with blood or body fluids and handle according to company policy. Bloody or soiled non-disposable articles shall be rendered safe for handling before being placed back in service.
• Bloody or soiled disposable equipment shall be carefully bagged and discarded in appropriately labeled Biohazard bags.
• Needles and syringes shall be disposed of in a rigid puncture-resistant container and labeled as contaminated sharps. Any employee will never attempt to clean, rearrange, or for any other purpose, insert his/her hand or fingers into a sharps container.
• Blood spills should be cleaned up promptly with a solution of 5.35% sodium hypochlorite (household bleach), diluted 1:10 with water or other approved cleaning solution.

Engineering controls

One of the key aspects of our exposure control plan is the use of engineering controls to eliminate or minimize employee exposure to bloodborne pathogens. As a result, our facility employs equipment such as sharps disposal containers and biohazard bags.

________________________________________ periodically works with managers and supervisors to review tasks and procedures performed where engineering controls can be implemented or updated. The following engineering controls are used throughout the facility.

• Sharps containers for all areas that utilize needs, blades or other sharps
• List all safety equipment used at your facility.

Work practice controls

In addition to engineering controls, our facility uses a number of work practice controls to help eliminate or minimize employee exposure to bloodborne pathogens. Many of these work practices are outlined in the company policy and must be strictly followed. The person in our facility who is responsible for overseeing the implementation of these work practice controls is ________________________________________. As the designee, they will work in conjunction with managers and supervisors to affect this implementation. Our facility has adopted the following work practice controls as part of our Bloodborne Pathogens Compliance Program.

• Employees wash their hands immediately or as soon as possible after the removal of gloves or other PPE.
• Following any contact of body areas with blood or OPIM, all employees will wash their hands and any other exposed skin with soap and water as soon as possible. They will also flush any exposed mucous membranes (eyes, nose) with water.
• Contaminated needles and other contaminated sharps are not bent, recapped, or removed unless:
  • It can be demonstrated that there is no feasible alternative.
  • The action is required by a specific procedure.
  • In the two situations above, the recapping or needle removal is accomplished using a device or a one-handed technique.
• Eating, drinking, smoking, applying cosmetics or lip balm, and handling contact lenses is prohibited in work areas where there are potentially infectious materials. Food and drink are not kept in refrigerators, freezers, or on countertops or in other storage areas where blood or OPIM are present.
• Equipment that becomes contaminated is examined prior to servicing or shipping and decontaminated as necessary unless it can be demonstrated that decontamination is not feasible.
• When a new employee comes to our facility, or an employee changes jobs within the facility, the following process takes place to ensure that they are familiar with the proper work practice controls.

Personal protective equipment

Personal protective equipment is the last line of defense against bloodborne pathogens. Because of this, our facility provides (at no cost to our employees) PPE that they need to protect themselves against such exposure. The equipment includes, but is not limited to:

• Gloves
• Gowns
• Face shields
• Goggles

________________________________________ is working with managers and supervisors to ensure that all personal protective equipment is available to all personnel and in all appropriate work areas.

Our employees are trained in the use of the appropriate personal protective equipment for their job classification and tasks/procedures. Initial training for personal protective equipment was completed in our facility prior to ________________________________________. Additional training is provided as needed if an employee takes a new position or new job functions are added to their current position. Infection control practices are reviewed at an annual infection control educational update.

To ensure that personal protective equipment is not contaminated and is in the appropriate condition to protect employees from potential exposure, our facility adheres to the following practices:

• All personal protective equipment is inspected periodically and repaired or replaced as needed to maintain its effectiveness.
• Reusable personal protective equipment is cleaned, laundered, and decontaminated as needed.

To make sure that this equipment is used as effectively as possible, our employees adhere to the following practices when using their equipment.

• Any garments penetrated by blood or other infectious materials are removed immediately or as soon as practically possible.
• All personal protective equipment is removed prior to leaving the work area.
• Disposable gloves are replaced as soon as possible after contamination or if they are torn, punctured, or otherwise lose their ability to function as an exposure barrier.

Maintaining our facility in a clean and sanitary condition is an important part of our bloodborne pathogens compliance program. To facilitate this, we have set up a written schedule for cleaning and decontamination of the various areas of the facility that have potential exposure.

• The area to be cleaned/decontaminated
• Day and time of scheduled work to be completed
• Cleansers and disinfectants to be used
• Any special instructions that are appropriate to the area

All equipment and surfaces are cleaned and decontaminated after contact with blood or OPIM. Protective coverings are removed and replaced. All pails, bins, cans, and other receptacles intended for use are routinely inspected, cleaned and decontaminated as soon as possible if visibly contaminated. Potentially contaminated broken glassware is picked up by mechanical means.

All receptacles will be emptied and cleaned of gross contamination, placed in biohazard bags, labeled, and decontaminated. All disposable items will be discarded in an approved biohazard bag. All equipment that cannot be placed in biohazard bags will be cleaned with water and the designated detergent disinfectant.

Hepatitis B vaccination plan

All employees who have been identified as having a risk of exposure to blood or OPIM will be offered the hepatitis B vaccination at no cost to the employee. The vaccine will be offered to all employees within ten days of their initial assignment to work that involves the potential for occupational exposure. If the employee has been vaccinated before or wishes to submit to antibody testing which shows the employee to have sufficient immunity, this will be acceptable.

To ensure all employees are aware of the vaccination program, it is thoroughly discussed in the bloodborne pathogens training and also posted in prominent places throughout the facility. This program is made available to all occupationally exposed employees. The employee is to report any exposure and receive medical evaluation and treatment as soon as possible after the incident.

When an employee incurs an exposure incident, they shall report it to their immediate supervisor who will:

• Investigate the circumstances surrounding the exposure.
• Advise the employee to present to the emergency department for a medical consultation.

The incident will be investigated by the supervisor within the next working day after the incident occurs and is reported.

It involves gathering the following information:

• Day and time of the incident
• Location of incident
• What potentially infectious materials were involved
• Source of material
• Route of exposure
• Under what circumstances the incident occurred
• How the incident happened:
  • Accident
  • Unusual circumstances, such as equipment failure
• Personal protective equipment being used at the time of the incident; and if personal protective equipment should have been used and was not
• Actions are taken because of the incident:
  • Employee decontamination
  • Clean up
  • Notifications made
  • Counseling
  • Disciplinary action if warranted
  • Department in service, if appropriate

The information regarding the exposure is evaluated thoroughly by a written summary that identifies its causes and further recommendations for avoiding similar incidents. To make sure that our employees receive the best and most timely treatment if an exposure occurs, our facility has set up a comprehensive post-exposure evaluation and follow-up process. We utilize the investigation form to ensure that all steps in the process are followed correctly.

We recognize that much of the information involved in this process must remain confidential and we will do everything possible to protect the privacy of the people involved. As the first step in this process, we provide the exposed employee with the following confidential information.

• How the exposure occurred
• Identification of the source individual

Once these procedures have been completed, an appointment will be arranged for the exposed employee with a qualified healthcare professional to discuss the employee’s medical status. This will include an evaluation of any reported illness, as well as the recommended treatment.

Labels and signs

For our employees, the most obvious warnings of possible exposure to bloodborne pathogens are biohazard signs. Because of this, we have implemented a comprehensive biohazard warning labeling program in our facility using labels of standard type or when appropriate using red, color-coded containers. The following items will be labeled:

• Containers of regulated waste
• Refrigerators/freezers containing blood or other potentially infectious materials.
• Sharps disposal containers
• Laundry bags and containers
• Contaminated equipment
• On labels affixed to contaminated equipment, we have also indicated which portions of the equipment is contaminated

Information and training for employees

Having well-informed employees is extremely important when attempting to eliminate or minimize our exposure to bloodborne pathogens. Because of this, all employees and volunteers who have the potential for exposure to bloodborne pathogens are put through a comprehensive training program and furnished with as much information as possible on this issue.

Employees are updated on an annual basis or more often if needed. Additionally, all new employees, as well as employees changing jobs or job functions, will be given any additional training that their new position requires at the time of their job reassignment

Training topics

The topics in our training program include, but are not limited to:

• Bloodborne Pathogens Standard
• Epidemiology and symptoms of bloodborne diseases
• Modes of transmission of bloodborne pathogens
• Exposure control plan

Appropriate methods for recognizing tasks and other activities that may involve exposure to blood and other potentially infectious materials will be reviewed. A review of the use and limitations of methods that will prevent or reduce exposure including:

• Engineering controls
• Work practice controls
• Personal protective equipment

Selection and use of personal protective equipment will be reviewed including:

• Type available
• Proper use
• Location within the facility
• Removal
• Handling
• Decontamination
• Disposal

Actions to take and persons to contact in an emergency involving blood or OPIM. The procedures to follow if exposure occurs, including the incident report.

Training methods

Our facility’s training presentations make use of several training techniques including, but not limited to, the following:

• Classroom type atmosphere with personal instruction
• Digital programs
• Training manuals and employee and volunteer handouts

Because we feel that employees need an opportunity to ask questions and to interact with their instructions, time is allotted for these activities in each training session.

Recordkeeping

To facilitate the training of our employees, as well as to document the training process, we maintain training records containing the following information:

• Dates and sessions
• Contents and summary
• Names of instructors
• Names of attendees

The training records are available for examination and copying to our employees as well as OSHA and its representatives.

Works cited

1. American Red Cross. First Aid/CPR/AED Participant’s Manual. StayWell, 2016.
2. Centers for Disease Control and Prevention. “Heat Stress.” National Institute for Occupational Safety and Health (NIOSH), 31 May 2024. https://www.cdc.gov/niosh/topics/heatstress/.
3. Centers for Disease Control and Prevention. “Heat Related Illness.” Heat Stress, 7 Aug 2024. https://www.cdc.gov/niosh/heat-stress/about/illnesses.html.
4. Centers for Disease Control and Prevention. “Outdoor Workers.” Extreme Heat, 9 July 2024. https://www.cdc.gov/heat-health/risk-factors/heat-and-outdoor-workers.html.
5. Mayo Clinic Staff. “First Aid for Burns.” Mayo Clinic, 28 Aug 2024. https://www.mayoclinic.org/first-aid/first-aid-burns/basics/art-20056649.
6. Occupational Safety and Health Administration. “Protecting Workers from the Effects of Heat.” OSHA. https://www.osha.gov/heat-exposure.