Q. What is an exposure control plan?
A. The exposure control plan is the employers written program that outlines the protective measures an employer will take to eliminate or minimize employee exposure to blood and OPIM.
The exposure control plan must contain at a minimum: (1) the exposure determination which identifies job classifications and, in some cases, tasks and procedures where there is occupational exposure to blood and OPIM; (2) the procedures for evaluating the circumstances surrounding an exposure incident; and (3) a schedule of how and when other provisions of the standard will be implemented, including methods of compliance, HIV and HBV research laboratories and production facilities requirements, hepatitis B vaccination and post-exposure follow-up, communication of hazards to employees, and recordkeeping.
Q. In the exposure control plan, are employers required to list specific tasks that place the employee at risk for all job classifications?
A. No. If all the employees within a specific job classification perform duties where occupational exposure occurs, then a list of specific tasks and procedures is not required for that job classification. However, the job classification (e.g., “nurse”) must be listed in the plans exposure determination and all employees within the job classification must be included under the requirements of the standard.
Q. Can tasks and procedures be grouped for certain job classifications?
A. Yes. Tasks and procedures that are closely related may be grouped. However, they must share a common activity, such as “vascular access procedure,” or “handling of contaminated sharps.”
Q. Does the exposure control plan need to be a separate document?
A. No. The exposure control plan may be part of another document, such as the facility’s health and safety manual, as long as all components are included. However, in order for the plan to be accessible to employees, it must be a cohesive entity by itself or there must be a guiding document which states the overall policy and goals and references the elements of existing separate policies that comprise the plan. For small facilities, the plans schedule and method of implementation of the standard may be an annotated copy of the final standard that states on the document when and how the provisions of the standard will be implemented. Larger facilities could develop a broad facility program, incorporating provisions from the standard that apply to their establishments.
Q. How often must the exposure control plan be reviewed?
A. The standard requires an annual review of the exposure control plan. In addition, whenever changes in tasks, procedures, or employee positions affect or create new occupational exposure, the existing plan must be reviewed and updated accordingly.
Q. Must the exposure control plan be accessible to employees?
A. Yes, the exposure control plan must be accessible to employees, as well as to OSHA and NIOSH representatives. The location of the plan may be adapted to the circumstances of a particular workplace, provided that employees can access a copy at the workplace during the workshift. If the plan is maintained solely on computer, employees must be trained to operate the computer.
A hard copy of the exposure control plan must be provided within 15 working days of the employees request in accordance with 29 CFR 1910.1020.
Q. What should be included in the procedure for evaluating an exposure incident?
A. The procedure for evaluating an exposure incident shall include:
the engineering controls and work practices in place,
the protective equipment or clothing used at the time of the exposure incident,
an evaluation of the policies and “failures of control” at the time of the exposure incident.