SECTION 5: Exposure control plan

Learning objectives: The learner will be able to

Identify job classifications, tasks, and procedures that put employees at risk of exposure. Establish a written exposure control plan, and make it available to all employees with potential risk. The plan must be reviewed and updated annually. There are specific items that must be addressed by the plan. These items include:

We will provide an example of a generic exposure control plan containing each of the above sections at the end of this section.

Safety devices

Evaluate medical devices with engineered sharps injury protection, such as commercially available sharps containers.

Involve front line employees in the evaluation and selection process for safety equipment.

Document the evaluation and selection of the equipment.

Hepatitis B vaccination

Offer free hepatitis B vaccinations to all employees with occupational exposure to blood or other potentially infectious materials.


Ensure that employees comply with universal precautions.

Have a program in place for those that are exposed.

Information and training

Train all occupationally exposed employees at the initial assignment and at least annually. Training must include:

Every company will have a unique exposure control plan that follows the same general outline to meet the requirements of the BBP standard. This model exposure control plan, written and implemented by an Emergency Medical Services Agency, is intended to serve employers as an example exposure control plan which is required by the Bloodborne Pathogens Standard.

Each employer will need to adjust or adapt the model for their specific use. The information contained in this model is not considered a substitute for any provisions of OSHA standards. It provides guidance but should not be considered a definitive interpretation for compliance with OSHA requirements.

Bloodborne pathogen standard

Model exposure control plan

Component Responsibility
Exposure control officer  
Education and training coordinator  
Exposure Determination  
Exposure control plan  
Engineering controls  
Work control practices  
Personal protective equipment  
Contaminated waste housekeeping  
Exposure investigation  
Hepatitis B program  
Post exposure evaluation and follow up  
Recordkeeping (training)  
Labeling and signs  

Although each of the above positions needs a person to be assigned, they can overlap. For example, the training coordinator may be in charge of training recordkeeping as well.


General management

Responsible persons:

The following sections define the roles played by each of these groups in carrying out our plan. Throughout this written plan, employees with specific responsibilities are identified. If because of promotion or other reasons, a new employee is assigned any of these responsibilities, ______________ is to be notified of the change so that the plan can be updated.

Exposure control officer

The exposure control officer will be responsible for the overall management and support of our facility’s Bloodborne Pathogens Compliance Program. Activities that are delegated to the exposure control officer typically include, but are not limited to:

______________ has been appointed as the facility’s exposure control officer. We have determined that the exposure control officer will require assistance in fulfilling his responsibilities. To assist him/her in carrying out his duties, we have created an exposure control committee composed of the following people.

Exposure control committee

Education and training coordinator

The Education and Training Coordinator will be responsible for providing information and training to all employees who have the potential for exposure to bloodborne pathogens. Activities falling under the direction of the coordinator include:

________________has been selected as the facility’s Education and Training Coordinator.


As with all our facility’s activities, our employees have the most important role in our Bloodborne Pathogens Compliance Program. The ultimate execution of the plan rests in their hands. In this role, they must do things such as:

Availability of the exposure control plan to employees

To help them with their efforts, our facility’s exposure control plan is available to our employees at any time. They are advised of this availability during their education and training sessions. Copies of the exposure control plan are kept in the following locations.

Review and update of the plan

We recognize that it is important to keep our exposure control plan up to date. To ensure this, the plan will be reviewed and updated under the following circumstances:

Exposure determination

One of the keys to implementing a successful exposure control plan is to identify exposure situations employees may encounter. To facilitate this in our facility, we have prepared the following lists:

The initial lists were compiled on or before _____________ and updated on an annual basis. The exposure control committee will work with managers to revise and update these lists as our tasks, procedures, and classifications change.

Job classifications in which all employees have exposure to bloodborne pathogens

This list would change depending upon the type of facility the plan is being written for. For example, if a tattoo parlor, it would be a list of different people than for an ambulance service. All people and their positions that may be exposed must be listed here.

Job classifications in which some employees have exposure to bloodborne pathogens

As above, this list would change depending upon the type of facility. This list would contain people who may on occasion be exposed. For example, in a tattoo parlor, this may be the receptionist or at an ambulance service, this may be the mechanic.

Tasks and procedures that may result in exposure

Every task that may result in exposure is listed in detail here. For example:

Everything that pertains to exposure must be listed here.

Methods of compliance

Universal precautions – explanation

Universal precautions is an approach to infection control. According to the concept of universal precautions, all human blood and certain human body fluids are treated as if known to be infectious.

To prevent the transmission of bloodborne infectious diseases, proper precautions are set forth by this policy. Universal blood and body fluid precautions will be used by all healthcare providers when delivering direct patient care or in situations where tasks may expose the employee or volunteer to bloodborne infectious material.

Universal precautions are regarded as a supplement not a replacement for routine infection control procedures and/or enteric precautions applicable to certain clinical situations presented by each patient.

Please note that although there have not been any recorded cases of HIV being transmitted by sweat and saliva, it is highly recommended that precautions are used when there is any risk of exposure.

A basic aseptic technique in addition to universal precautions practiced by employees can prevent the transmission of bloodborne pathogens in all settings.

The purpose of universal precautions is to prevent the transmission of all infectious diseases that are spread by blood or other potentially infectious material (OPIM).

Since medical history and examination cannot reliably identify all people who are infected with bloodborne pathogens, blood and OPIM must be used in all situations where exposure is possible.


Engineering controls

One of the key aspects of our exposure control plan is the use of engineering controls to eliminate or minimize employee exposure to bloodborne pathogens. As a result, our facility employs equipment such as sharps disposal containers and biohazard bags.

______________ periodically works with managers and supervisors to review tasks and procedures performed where engineering controls can be implemented or updated. The following engineering controls are used throughout the facility.

Work practice controls

In addition to engineering controls, our facility uses a number of work practice controls to help eliminate or minimize employee exposure to bloodborne pathogens. Many of these work practices are outlined in the company policy and must be strictly followed. The person in our facility who is responsible for overseeing the implementation of these work practice controls is ______________. As the designee, they will work in conjunction with managers and supervisors to affect this implementation. Our facility has adopted the following work practice controls as part of our Bloodborne Pathogens Compliance Program.

Personal protective equipment

Personal protective equipment is the last line of defense against bloodborne pathogens. Because of this, our facility provides (at no cost to our employees) PPE that they need to protect themselves against such exposure. The equipment includes, but is not limited to:

______________ is working with managers and supervisors to ensure that all personal protective equipment is available to all personnel and in all appropriate work areas.

Our employees are trained in the use of the appropriate personal protective equipment for their job classification and tasks/procedures. Initial training for personal protective equipment was completed in our facility prior to ______________. Additional training is provided as needed if an employee takes a new position or new job functions are added to their current position. Infection control practices are reviewed at an annual infection control educational update.

To ensure that personal protective equipment is not contaminated and is in the appropriate condition to protect employees from potential exposure, our facility adheres to the following practices:

To make sure that this equipment is used as effectively as possible, our employees adhere to the following practices when using their equipment.

Maintaining our facility in a clean and sanitary condition is an important part of our bloodborne pathogens compliance program. To facilitate this, we have set up a written schedule for cleaning and decontamination of the various areas of the facility that have potential exposure.

All equipment and surfaces are cleaned and decontaminated after contact with blood or OPIM. Protective coverings are removed and replaced. All pails, bins, cans, and other receptacles intended for use are routinely inspected, cleaned and decontaminated as soon as possible if visibly contaminated. Potentially contaminated broken glassware is picked up by mechanical means.

All receptacles will be emptied and cleaned of gross contamination, placed in biohazard bags, labeled, and decontaminated. All disposable items will be discarded in an approved biohazard bag. All equipment that cannot be placed in biohazard bags will be cleaned with water and the designated detergent disinfectant.

Hepatitis B vaccination plan

All employees who have been identified as having a risk of exposure to blood or OPIM will be offered the hepatitis B vaccination at no cost to the employee. The vaccine will be offered to all employees within ten days of their initial assignment to work that involves the potential for occupational exposure. If the employee has been vaccinated before or wishes to submit to antibody testing which shows the employee to have sufficient immunity, this will be acceptable.

To ensure all employees are aware of the vaccination program, it is thoroughly discussed in the bloodborne pathogens training and also posted in prominent places throughout the facility. This program is made available to all occupationally exposed employees. The employee is to report any exposure and receive medical evaluation and treatment as soon as possible after the incident.

When an employee incurs an exposure incident, they shall report it to their immediate supervisor who will:

The incident will be investigated by the supervisor within the next working day after the incident occurs and is reported.

It involves gathering the following information:

The information regarding the exposure is evaluated thoroughly by a written summary that identifies its causes and further recommendations for avoiding similar incidents. To make sure that our employees receive the best and most timely treatment if an exposure occurs, our facility has set up a comprehensive post-exposure evaluation and follow-up process. We utilize the investigation form to ensure that all steps in the process are followed correctly.

We recognize that much of the information involved in this process must remain confidential and we will do everything possible to protect the privacy of the people involved. As the first step in this process, we provide the exposed employee with the following confidential information.

Once these procedures have been completed, an appointment will be arranged for the exposed employee with a qualified healthcare professional to discuss the employee’s medical status. This will include an evaluation of any reported illness, as well as the recommended treatment.

Labels and signs

For our employees, the most obvious warnings of possible exposure to bloodborne pathogens are biohazard signs. Because of this, we have implemented a comprehensive biohazard warning labeling program in our facility using labels of standard type or when appropriate using red, color-coded containers. The following items will be labeled:

Information and training

Having well-informed employees is extremely important when attempting to eliminate or minimize our exposure to bloodborne pathogens. Because of this, all employees and volunteers who have the potential for exposure to bloodborne pathogens are put through a comprehensive training program and furnished with as much information as possible on this issue.

Employees are updated on an annual basis or more often if needed. Additionally, all new employees, as well as employees changing jobs or job functions, will be given any additional training that their new position requires at the time of their job reassignment

Training topics

The topics in our training program include, but are not limited to:

Appropriate methods for recognizing tasks and other activities that may involve exposure to blood and other potentially infectious materials will be reviewed. A review of the use and limitations of methods that will prevent or reduce exposure including:

Selection and use of personal protective equipment will be reviewed including:

Actions to take and persons to contact in an emergency involving blood or OPIM. The procedures to follow if exposure occurs, including the incident report.

Training methods

Our facility’s training presentations make use of several training techniques including, but not limited to, the following:

Because we feel that employees need an opportunity to ask questions and to interact with their instructions, time is allotted for these activities in each training session.


To facilitate the training of our employees, as well as to document the training process, we maintain training records containing the following information:

The training records are available for examination and copying to our employees as well as OSHA and its representatives.

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