Exposure control plan

The revision included new requirements regarding the employer s exposure control plan, including an annual review and update to reflect changes in technology that eliminate or reduce exposures to bloodborne pathogens. The anployer must 

Consider new innovations in medical procedures and technology that rednce the risk of exposnre to needle sticks 

Consider and document use of appropriate, commercially available, and effective safer 

Realize that no single medical device can prove effective for all circnmstances Identify devices used, the method in place to evaluate those devices, and justification for the eventual selection 

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The needle stick log will help both employees and employers track all needle sticks to help identify problem areas. The log must be maintained to protect the confidentiality of the injured employee. In addition, employers must have a written Exposure Control Plan that is updated annually. During the annual review, inquiries must be made about new or prospective safer options. If new safer devices are available, they should be adopted for use in the agency. The new guidelines will help reduce needle stick injuries among health care workers and others who handle medical sharps. Safety engineered devices such as self-sheathing needles and needleless systems can be used. 

Health Act (OSHA), which regulates workplace safety. In particular, pharmacists who perform laboratory tests that require finger sticks are at risk from exposure to blood-borne pathogens. Pharmacies who perform these tests should have a blood-borne pathogen exposure control plan (BPEPC) that describes who should be trained about the hazards of blood-borne exposure, precautions that need to be taken to prevent exposure, and what to do when an exposure incident occurs (Rosenthal, 2000). More information regarding OSHA and an example BPEPC can be found at the OSHA Web site (www.osha.gov). 

As discussed earlier in this section, OSHA has mandated that all U.S. laboratories have an exposure control plan. In addition, the National Institute for Occupational Safety and Health (NIOSH), a functional unit of the GDC, has prepared and widely distributed a document entitled Universal Pre-cautions that specifies how U.S. clinical laboratories handle infectious agents. In general it mandates that clinical laboratories treat aU human blood and other potentially infectious materials as if they were known to contain infectious agents, such as HBV, HIV, and other blood-borne pathogens. These requirements apply to all specimens of blood, serum, plasma, blood products, vaginal secretions, semen, cerebrospinal fluid, synovial fluid, and concentrated HBV or HIV viruses. In addition, any specimen of any type that contains visible traces of blood should be bandied using tliese Universal Precautions. 

The NCCLS has also published a similar set of recom-mendations, several of which are specified as requirements in the OSHA exposure control plan. They include ... 

This book wfil help you comply with the OSHA bloodbome pathogens standard, ft includes guidance in setting up a bloodborne pathogens program, writing an exposure control plan, and training employees. 

Potentially hazardous work practices safe procedures and equipment- common routes of exposure epidemiology, symptoms, and heaitn risks hepatitis B vaccine personal protective equipment OSHA Exposure Control Plan and cleanup, waste handling and labeling. 

Techniques for first-aid responders and employees. Universal precautions, exposure control plans, exposure incidents, personal protection, and decontamination. 

The OSHA Blood-Borne Pathogen Standard mandates that each facility must establish its own blood-borne exposure control plan to avoid placing employees in contact with blood, body fluids, or other potentially infectious materials. Each facility develops its own program and trains employees to the requirements of that program. 

Safety professionals should also be aware that OSHA has announced an airborne infectious disease rule that may impact a substantial number of workplaces. This proposed rule is modeled after the Cal-OSHA aerosol transmissible disease rule, which required respiratory protection, fit testing, disease exposure control plans, medical surveillance, and communication procedures, among other requirements. 

OSHA published 29 CER 1910.1030, relating exposures to bloodbome pathogens on December 6, 1991. The rule took effect on March 6, 1992. Under the standard, employers affected by the standard were to be in fttU compliance by July 6, 1992. An exposure control plan was to be in effect by May 5, 1992, and employee training made available by June 5, 1992. OSHA has taken a firm posture on implementation of the mle. OSHA can impose a fine of up to 70,000 per willful violation. 

An explanation of the exposure control plan and how a written copy can be obtained. 

An accessible copy of the regulatory text of this standard and an explanation of its contents A general explanation of the epidemiology and symptoms of bloodborne diseases An explanation of the modes of transmission of bloodborne pathogens An explanation of the employer s exposure control plan and the means by which the employee can obtain a copy of the written plan... 

A written exposure control plan is necessary for the safety and health of workers. 

Explain the employer s written exposure control plan. 

Practice Name) maintains, reviews, and updates the exposure control plan... 

This Tuberculosis Exposure Control Plan applies to aU areas of this practice where exposure to pulmonary or laryngeal TB may occur. It is intended to prevent transmission of pulmonary Mycobacterium tuberculosis (TB) from infected individuals to susceptible hosts. All employees must comply with this plan. TB precautions are not necessary if the patient is on anti-TB medications (and compliant) and has no symptoms such as coughing, night sweats, weight loss, and fever. Person(s) responsible for this plan are listed as follows ... 

Simply put, you must provide some protection for construction employees with occupational exposure, such as those designated as responsible for providing first aid or medical assistance. OSHA enforcement officers have indicated that what is expected for those employees includes basic instruction in bloodborne pathogen hazards, as well as vaccination and follow-up for first-aid providers in the event of an exposure incident. Appropriate personal protective equipment (PPE) and sharps containers must be provided. However, a written exposure control plan is not required. 

An annual review of the exposure control plan by employers must ensure that their plans reflect consideration and use of commercially available safer medical devices. An emphasis should be placed on the use of effective engineering controls, to include safer medical devices, work practices, administrative controls, and personal protective equipment. Employers should rely on relevant evidence, in addition to Food and Drug Administration (FDA) approval, to ensure the effectiveness of devices designed to prevent exposure to bloodbome pathogens. 

Sample Exposure Control Plan. Part of OSHA s eTools for hospitals and nursing homes. This sample plan was included in OSHA s proposed tuberculosis standard (Appendix F to proposed 29 CFR 1910.1035, 62 Fed. Reg. 54,160, October 17, 1997), but OSH A withdrew the proposed rule in May 2003. 

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