Does my clinic need to have an Exposure Control Plan in place?  If so, why?  

• Submitter: Research Manager, Oncology Clinic

Answer:

The Occupational Safety and Health Administration published the Occupational Exposure to Bloodborne Pathogens (BBP) Standard in 1991 to help protect workers from the risk of exposure to bloodborne pathogens, such as HIV, hepatitis B virus, and hepatitis C virus. 

One of the key requirements of the BBP Standard is that employers must establish a written Exposure Control Plan (ECP) if they have employees who, because of their job duties, may be exposed to human blood or other potentially infectious materials.  Nurses, doctors, other healthcare personnel, and housekeeping personnel in clinical settings can all be expected to have occupational exposure bloodborne pathogens. 

Key requirements of an ECP include:

• Determination of employee exposure to include job classifications with occupational exposure and tasks/procedures in which occupational exposure may occur
• Implementation of exposure control methods (universal precautions, engineering and work practice controls, personal protective equipment, and housekeeping)
• Documentation that safer medical devices, such as sharps with engineered sharps injury protections or needle-less systems, have been considered and implemented where possible
• Occupational medicine considerations such as hepatitis B vaccination and post-exposure evaluation and follow-up
• Hazard communication and training
• Recordkeeping
• Procedures for evaluating, responding to, and reporting potential exposures

Exposure Control Plans must be reviewed at least annually. They must also be updated whenever there are changes to job classifications, tasks, or procedures that may impact the risk of exposure. In addition to being a requirement of the BBP Standard, establishing an ECP is also a best practice, as it can help to prevent employee injuries and illnesses and maintain a safe and productive work environment. 

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