Work practice controls are procedures that dictate how employees perform tasks to minimize their exposure to hazards. These controls focus on behavioral and procedural changes, ensuring work is conducted using the safest possible method. They are established to reduce the likelihood of contact with dangerous materials or situations. The goal is to reduce the risk of injury or illness by standardizing how certain activities are executed.
What Defines Work Practice Controls
Work Practice Controls (WPCs) are measures that reduce the chance of exposure by altering how a specific task is performed. They mandate safe behavior during high-risk operations by codifying the safest technique into a mandatory protocol for all employees.
WPCs focus on the human element, requiring employees to change their habits or actions rather than relying solely on equipment. This approach ensures that risk is managed through a consistent, prescribed set of steps, regardless of the individual performing the task. These controls are often applied in environments where handling hazardous materials is unavoidable, such as healthcare or industrial settings.
How Work Practice Controls Differ from Engineering Controls
The distinction between Work Practice Controls and Engineering Controls lies in whether the control isolates the hazard or manages the behavior around the hazard. Engineering Controls are physical modifications to the workplace, equipment, or environment that remove or isolate a hazard from the worker. Examples include self-sheathing needles, sharps disposal containers, and specialized ventilation systems.
Work Practice Controls, by contrast, do not change the equipment but rather change the employee’s interaction with it. For example, an Engineering Control provides a sharps container, while the corresponding WPC dictates the procedure for immediately placing the sharp into that container. Safety regulations prioritize Engineering Controls when feasible, as they are a more reliable method of hazard reduction that does not rely on human behavior. WPCs manage the residual risk that remains after physical barriers have been installed.
Essential Examples of Work Practice Controls in Practice
Hand Hygiene Practices
Proper hand hygiene is a Work Practice Control, especially in environments involving biological hazards. Employees must wash their hands immediately after removing gloves or other personal protective equipment, or after contact with blood or other potentially infectious materials (OPIM).
Washing should be performed with soap and water for a specified duration. Alcohol-based hand sanitizers are used only when a sink is unavailable and hands are not visibly soiled. Hand washing serves as a final decontamination step, preventing the transfer of hazardous materials.
Handling and Disposal of Contaminated Items
WPCs govern the process for handling and disposing of regulated waste to prevent leakage and secondary exposure. Contaminated materials, such as soiled linens or disposable supplies, must be placed in designated, labeled containers that are leak-proof and securely closed before removal. This procedure ensures that hazardous items are contained at the point of use and remain contained during transport and final disposal.
Contaminated equipment must be properly decontaminated before being serviced or shipped, or it must be clearly labeled with a biohazard warning. The standardized practice of containing and labeling items before they leave the work area prevents downstream exposure to cleaning or maintenance personnel.
Prohibitions in Work Areas
WPCs prohibit specific activities in areas where occupational exposure is reasonably anticipated. To prevent the ingestion or absorption of hazardous materials, employees are forbidden from eating, drinking, or smoking in these work zones. Prohibitions also extend to applying cosmetics or lip balm and handling contact lenses.
Furthermore, procedures involving blood or OPIM must be performed in a manner that minimizes splashing, spraying, or the generation of droplets. For instance, mouth pipetting or suctioning of hazardous materials is strictly prohibited, mandating the use of mechanical devices to protect the worker’s mucous membranes.
Safe Handling of Sharps
Controls related to sharps focus on preventing percutaneous injuries from needles, scalpels, and other sharp devices. The primary procedural control is the prohibition against bending, breaking, or manually recapping contaminated needles. Any necessary manipulation of a sharp, such as recapping before disposal, must be accomplished using a mechanical device or a one-handed scoop technique.
Contaminated sharps must be placed immediately after use into designated puncture-resistant, leak-proof disposal containers. This immediate disposal procedure, along with the prohibition of two-handed recapping, is a direct procedural mandate designed to reduce the risk of a needlestick injury.
Regulatory Requirements for Work Practice Controls
The federal mandate for Work Practice Controls is found within the Occupational Safety and Health Administration’s (OSHA) Bloodborne Pathogens Standard (29 CFR 1910.1030). This regulation requires employers to establish a written Exposure Control Plan designed to minimize employee exposure to blood or OPIM.
The standard explicitly requires the use of WPCs alongside Engineering Controls and Personal Protective Equipment. Employers must ensure that all employees adhere to the prescribed procedures, as these controls are enforceable legal requirements, not optional recommendations.
Maintaining and Enforcing Controls in the Workplace
Effective implementation of Work Practice Controls requires a continuous management system focusing on training, monitoring, and corrective action. Employers must ensure that all employees receive comprehensive, documented training that outlines the specific procedures for their tasks. Regular refresher training is necessary to maintain proficiency and communicate any updates to the controls.
Compliance is maintained through routine, documented inspections and supervision to confirm that employees are consistently following the required work practices. A formal, written disciplinary policy is also necessary for enforcement, ensuring employees are held accountable for failing to adhere to the mandated safety procedures.