Smarter HR SolutionsHouston, TX
- What they do
- Compliance consulting
- Who they help
- Its website offers consulting for employee handbooks, HR policies, HR compliance audits and OSHA written programs.
- Standards
- Pricing
- Not published
Bloodborne Pathogens Exposure Control Plan
The Exposure Control Plan is the written program OSHA requires from any employer whose workers can reasonably expect contact with blood or other potentially infectious materials.
It lists the job classifications and tasks with exposure, states how the employer will follow the standard's methods of compliance (universal precautions, engineering and work practice controls, PPE, housekeeping), lays out hepatitis B vaccination and post-exposure follow-up, and describes the sharps injury log and how sharps devices are evaluated.
It is one of the few OSHA written programs with an explicit annual review requirement, and the only one that requires documented input from front-line staff on device selection. Home health, hospice, dental, behavioral health with medical staff, tattoo studios, and any workplace with designated first aid responders are in scope.
Accreditors survey against it and OSHA cites it heavily in health care.
Also called: ECP, BBP plan, Exposure control plan, Bloodborne pathogens program
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Who requires it, and what each one says.
| Source | Applies when | What it requires | Status |
|---|---|---|---|
| OSHA Bloodborne pathogens, exposure control plan 29 CFR 1910.1030(c)(1) | Any employee has occupational exposure | A written plan with the exposure determination, schedule and method of implementing each compliance paragraph, and the procedure for evaluating exposure incidents; accessible to employees. Legally required. | Mandatory |
| OSHA Bloodborne pathogens, annual review and device input 29 CFR 1910.1030(c)(1)(iv) and (v) | Always | Review and update at least annually and whenever tasks or positions change; document annual consideration of safer medical devices; solicit and document input from non-managerial employees who handle sharps. Legally required. | Mandatory |
| OSHA Bloodborne pathogens, training and records 29 CFR 1910.1030(g)(2), (h) | Always | Training at assignment and annually; medical records kept for employment plus 30 years; training records with dates, content summary, trainer and attendees kept three years; sharps injury log for employers who keep an OSHA 300 log. Legally required. | Mandatory |
| Needlestick Safety and Prevention Act Pub. L. 106-430; 66 FR 5318 (Jan 18, 2001) | Always | Added the safer-device review, front-line input, and the sharps injury log to the standard. Legally required (now embedded in 1910.1030). | Mandatory |
| ACHC accreditation standards (home health and home care) ACHC HH7-1A (home health), HC7-1B (home care), HH4-2D.01 | You seek or hold ACHC accreditation for home health or home care | The OSHA Bloodborne Pathogens exposure control plan, with the TB exposure control plan, reviewed annually and available to personnel as part of the infection control program; personnel files show hepatitis B vaccination or a signed declination. This is an ACHC standard; the Medicare infection control conditions (42 CFR 484.70, 418.60) do not name an exposure control plan. CHAP requires policies on work-related exposure and post-exposure follow-up. Accreditation requirement. | Mandatory |
Required sections
- Exposure determination: job classifications with exposure for all employees, and classifications with some exposure plus the tasks involved (1910.1030(c)(2))
- Schedule and method of implementation for: methods of compliance (d), HIV/HBV research labs (e) if applicable, hepatitis B vaccination and post-exposure evaluation (f), communication of hazards and training (g), recordkeeping (h)
- Universal precautions statement and engineering and work practice controls (d)(1) to (d)(2)
- Personal protective equipment provision, use, cleaning and disposal (d)(3)
- Housekeeping, regulated waste, laundry (d)(4)
- Hepatitis B vaccination offered within ten working days of assignment; declination form text from Appendix A (f)(2)
- Post-exposure evaluation and follow-up procedure, including source individual testing and the healthcare professional's written opinion (f)(3) to (f)(5)
- Procedure for evaluating the circumstances of an exposure incident (c)(1)(ii)(C))
- Annual review of safer medical devices and documentation of that review (c)(1)(iv)(B))
- Solicitation of non-managerial employee input on device selection, documented in the plan (c)(1)(v))
- Labels and signs (g)(1)
- Training program content and annual schedule (g)(2)
- Sharps injury log maintenance and privacy (h)(5), for employers required to keep injury records
- Plan review date and revision history (c)(1)(iv))
What the examiner asks for
Written planThe ECP with the current annual review date and the documented device review and employee input. Occupational health consultants, infection control consultants, safety consultants; policy tools hold versions
AttestationAnnual training records per employee (dates, content summary, trainer qualifications); signed hepatitis B declination forms using the Appendix A wording. Policy tools, LMS, occupational health providers
Operational recordsSharps injury log, exposure incident reports, post-exposure follow-up records, vaccination records, regulated waste manifests. The employer; occupational health clinics; medical waste vendors
Technical controlsSafer sharps devices in use; sharps containers; eyewash stations where required by other standards. Medical supply vendors
Change log.
2012-04-03OSHA published a compliance directive update (CPL 02-02-069 remains the enforcement directive).
2001-04-18Revised standard effective, implementing the Needlestick Safety and Prevention Act: safer device evaluation, employee input, sharps injury log.
2001-01-18Final rule revising 1910.1030 published at 66 FR 5318.
1992-03-06Original Bloodborne Pathogens Standard effective.
Where this document is required.
Where this document gets checked.
No one certifies a document like this on its own. It is read during the audits and inspections below, and by the agency behind each rule.
| Where it is looked at | Who looks at it |
|---|---|
| ACHC/CHAP | ACHC and CHAP surveyors employed or contracted by each accreditor, typically clinicians with home care or hospice experience. Surveys for Medicare deemed programs are unannounced |
| OSHA written programs | OSHA compliance safety and health officers, or State Plan inspectors (government inspection). No certification exists; voluntary recognition programs such as VPP and SHARP involve OSHA or consultation program evaluation |
Consultants.
Firms that name these standards in their own material.
Listed in random order, reshuffled each time the page loads. Firms that pay for a listing are shown at the top, labeled Sponsored.
Passio PEO and HR ConsultingEnglewood, CO, USA
- What they do
- Compliance consulting
- Who they help
- Its website offers consulting for OSHA compliance, Employee handbooks and HR policies, Employment law compliance, Harassment prevention training.
- Standards
- Pricing
- Not published
GreenLine HR Consulting LLCMeadville, PA, USA
- What they do
- Compliance consulting
- Who they help
- Its website offers consulting for OSHA compliance, Employee handbooks and HR policies, Employment law compliance, HR compliance audit.
- Standards
- Pricing
- Not published
Upstream Solutions, LLCUSA
- What they do
- Compliance consulting
- Who they help
- Its website offers consulting for OSHA compliance, Employee handbooks and HR policies, Employment law compliance.
- Standards
- Pricing
- Not published
Software.
Tools that hold documents like this one and record who has read them.
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What people ask.
Our staff only give first aid occasionally. Are we in scope?
If you designate employees as first aid responders as part of their job, yes. OSHA's 1993 compliance policy allows some flexibility on when the hepatitis B vaccine is offered for collateral-duty first aiders, but the written plan and training still apply.
What does the annual review have to show?
A dated record that the plan was reviewed, that safer sharps devices available on the market were considered, and that non-managerial employees with sharps exposure were asked for input. Inspectors look for the date and the input record, not just a revised cover page.
Can we use a template?
OSHA publishes a model plan. The exposure determination and the device review must be specific to your workplace, which is where templates fail inspection.
How long do we keep training records?
Three years from the training date. Medical records, including vaccination and post-exposure records, for the duration of employment plus 30 years.