Writing an Exposure Control Plan: Meeting OSHA’s Bloodborne Pathogen Standard

by | Mar 27, 2019 | Blog, Regulatory Compliance | 0 comments

Healthcare facilities, and other qualifying facilities in other industries, must abide by OSHA’s Bloodborne Pathogen Standard. This Standard seeks to protect workers from occupational hazards that result from being exposed to potentially infectious pathogens. The Standard was set forth in 1991 andincludes 7 key components, one of which specifically outlines the requirement to create and maintain an Exposure Control Plan (ECP).

The Standard’s requirements do not have clear specifications or directions. The plan is known as a “performance standard”, meaning there is a goal set forth but there is flexibility in how individual facilities achieve that goal.

The Standard applies to more than just the hospital, dental, or medical fields. OSHA says “Workers in many occupations, including first responders, housekeeping personnel in some industries, nurses and other healthcare personnel, all may be at risk for exposure to bloodborne pathogens.”

Those liable under the Standard can even include employees of tattoo parlors and sports coaches. “The Standard places requirements on employers whose workers can be reasonably anticipated to contact blood or other potentially infectious materials (OPIM), such as unfixed human tissues and certain body fluids.”

The consequences for violating OSHA’s Bloodborne Standard can be severe depending on the situation. For example, in 2016 OSHA fined USPS $342,000 for willfully violating the Exposure Control Plan requirements, as well as many other violations.

According to OSHA’s Field Operations Manual, violating any part(s) of the Bloodborne Pathogen Standard results in Gravity-Based Penalties (GBP). GBPs are determined by the severity of the violation, with high gravity violations resulting in fines up to $12,471, moderate gravity violations up to $10,689, and low gravity violations up to $5,345.

When determining the amount of the fine, OSHA also considers the size of the employer’s business, the good faith of the employer, and the employer’s history of violations. OSHA fines heavily for willful violations and repeat offenders.

What should my Exposure Control Plan include?

To avoid these fines, you should have a robust Exposure Control Plan. There are four basic rules your Exposure Control Plan needs to include.

They are:

  • The plan must be specific to your facility
  • The plan must be updated yearly – or when things change
  • Updates in technology must be considered
  • The plan must be accessible to your workers

The plan must be specific to your facility

The plan needs to specifically outline the details of your facility, workers, as well as the technology and equipment used in it. You must also delineate any potential threats, plans to address those threats, and what to do when things go wrong. You will want to be detailed when explaining specific job roles, the risks inherent in those roles, and how you are minimizing those risks.

Remember, the Standard is a Performance Standard. Your focus should be to show that you are acting in good faith by doing all you can to reduce any and all risks to your staff. The more thought-out and detailed your outline is, coupled with how you intend to reduce all identified threats, the closer you are to meeting the objectives of the Standard.

The plan must be updated yearly – or when things change

The plan must be updated yearly, with those updates communicated to staff. If anything in the plan changes, such as new staff, job roles, procedures or technology used, the plan needs to be updated to reflect those changes, even if a full year has not passed.

Updates in technology must be considered

As a part of your annual updates, OSHA requires that you review any technology that has come out since your last annual update. That way, you can assess if a new device or procedure can further limit any risks posed to staff. You need to document what you have reviewed and why you made the decision to either adopt or not adopt new equipment on the market.

OSHA will levy a fine against a facility that ignores new commercially-available devices that are designed to provide extra safety to workers, so do not miss this step or miss documenting it.

Additionally, OSHA requires that feedback from your workers is solicited on any new technology considered, so you will want to ensure you document that as well.

The plan must be accessible to your workers

Regular staff education on the plan’s contents and where the plan is kept is a requirement. The plan is meant to be fully accessible to workers at all times. This helps ensure it is readily available when an accident or incident has occurred.
It pays to be diligent in writing and maintaining your Exposure Control Plan. OSHA’s mission to protect workers may be a costly and time-consuming endeavor for your business, but in the end it will help you avoid fines, unnecessary workplace compensation issues, loss of staff due to temporary injury, and even staff turnover. It truly benefits everyone to be OSHA compliant.

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