The Exposure Control Plan (ECP) is a written, site-specific document designed to protect workers from occupational exposure to hazardous materials, primarily bloodborne pathogens. This plan is required for employers whose employees face anticipated contact with infectious agents during their duties. The ECP serves as a blueprint for minimizing or eliminating the transmission of diseases like HIV, HBV, and HCV in the workplace. It outlines the procedures, safety measures, and documentation systems that an organization must implement to comply with occupational safety standards.
Defining the Exposure Control Plan
The ECP safeguards employees from risks associated with bloodborne pathogens and other potentially infectious materials (OPIM). This document guides all infection control protocols, ensuring a standardized approach to employee protection across the organization. The plan must be specific to the workplace, detailing the unique hazards and control measures relevant to its operations. Occupational safety regulations mandate the ECP’s creation, requiring employers to proactively reduce exposure risks. It must be readily accessible to all employees during their work shift.
Who Needs an Exposure Control Plan?
Any employer whose workers have “occupational exposure” must develop and implement an ECP. Occupational exposure is defined as any reasonably anticipated contact with blood or other potentially infectious materials (OPIM) that may result from performing job duties. This determination is based solely on the nature of the tasks, regardless of whether the employee uses personal protective equipment. The requirement extends beyond traditional hospital settings to many industries where contact is foreseeable. This includes healthcare workers, first responders, custodial staff, laundry personnel, and professionals in fields like tattooing and dental hygiene.
Essential Components of the Exposure Control Plan
Exposure Determination
The ECP must begin with a formal exposure determination. This identifies all job classifications and specific tasks where employees have occupational exposure, regardless of frequency. This determination must be made without considering the use of personal protective equipment, ensuring the inherent risk of the job is accurately assessed.
Schedule and Method of Implementation
This section details the timeline and procedures for implementing all control measures. It outlines methods used to ensure compliance, such as applying Universal Precautions—treating all blood and OPIM as infectious. The plan specifies who is responsible for providing, maintaining, and ensuring the correct use of engineering controls and personal protective equipment.
Procedures for Evaluating Incidents
The plan must document the process for reviewing the circumstances surrounding an exposure incident, such as a needlestick or splash. This evaluation identifies the engineering controls used at the time and notes their effectiveness or failure. The goal is to determine how the incident occurred and identify necessary changes to prevent recurrence.
Post-Exposure Evaluation and Follow-up
Protocols must be established for the medical response immediately following an exposure incident. This includes a confidential medical evaluation and follow-up, provided at no cost to the employee. The plan ensures the healthcare professional receives relevant information, including the employee’s job duties and the circumstances of the exposure.
Procedures for Hepatitis B Vaccination
The ECP must document the procedure for offering the Hepatitis B vaccination series to all employees with occupational exposure. The vaccine must be offered free of charge and within 10 working days of initial assignment. Employees who decline the vaccination must sign a standardized declination form, which is kept on file as an administrative record.
Communication of Hazards and Employee Training
The plan details how hazards are communicated, including the use of biohazard warning labels and signs on regulated waste containers and blood storage units. It must outline a training program that includes initial training upon assignment and annual refresher training. Training must cover the epidemiology and symptoms of bloodborne diseases, along with an explanation of the ECP itself.
Recordkeeping Requirements
Specific administrative records must be maintained to demonstrate compliance. Training records, documenting dates, content, and trainer qualifications, must be kept for a minimum of three years from the date the training occurred. Employee medical records, related to exposure incidents or vaccination status, must be maintained for the duration of employment plus 30 years.
Implementing Control Measures
The ECP mandates a hierarchy of controls to minimize employee exposure, prioritizing measures that reduce the hazard at the source. This systematic approach relies first on engineering controls, followed by work practice controls, and finally, personal protective equipment. Employers must use engineering controls to the extent feasible before relying on other methods.
Engineering Controls
Engineering controls are physical changes to the workplace or equipment that isolate or remove the hazard from the employee. Examples include self-sheathing needles, which automatically cover the sharp end after injection, and needleless connection systems. Sharps disposal containers are also controls, designed to be puncture-resistant, closable, and leak-proof for safe storage. Employers must document that safer medical devices have been considered and implemented where possible.
Work Practice Controls
Work practice controls are changes in how a task is performed to reduce the likelihood of exposure. A primary example is prohibiting eating, drinking, smoking, or applying cosmetics in work areas where blood or OPIM are present. Employees must wash hands immediately after removing gloves or other personal protective equipment. Contaminated sharps must never be bent, recapped, or removed from disposable syringes unless the procedure is justified and performed using an approved mechanical device.
Personal Protective Equipment (PPE)
Personal Protective Equipment (PPE) provides a barrier when engineering and work practice controls are insufficient to eliminate exposure. This equipment includes gloves, gowns, face shields, goggles, and resuscitation devices. PPE must be provided by the employer at no cost to the employee. Selection must be based on the anticipated exposure, ensuring that all potentially contaminated body parts and clothing are adequately protected.
Maintaining and Updating the ECP
The ECP is a living document that requires regular review to remain effective and compliant. The plan must be reviewed and updated at least annually to reflect any new or modified tasks, procedures, or employee positions that affect occupational exposure. This ensures the ECP remains current with workplace conditions and technological advancements. The annual review must document the employer’s consideration and implementation of new, commercially available engineering controls designed to reduce exposure incidents. Furthermore, the employer must solicit input from non-managerial employees involved in direct patient care to bring practical experience to the selection and evaluation of safer medical devices.