An Exposure Control Plan (ECP) is required by to be completed by any employer where there may be a risk of bloodborne pathogen or OPIM exposure. The plan should be readily available for the employees’ use.
The ECP should contain information relating to certain job tasks where there may be a risk of exposure. It should also have a requirement with regard to the employee handles the task to avoid/minimize exposure risk.
Additionally, the ECP should contain information regarding workplace and engineering controls utilized as preventative measures to reduce the risk of exposure. The ECP should contain information explaining what to do in the event of an employee’s exposure.
OSHA requires that employers re-evaluate their ECP annually in order to ensure that workplace/engineering controls are taken into consideration to reduce the possibility of exposure.
Please see OSHA’s website for information on developing an ECP.
Work and engineering control practices are necessary in order to reduce the risk of exposure to infected blood or OPIM.
Work Control Practices (WCP) mechanisms include any work practice surrounding the possibility of exposure. This may include policies and procedures to follow when exposure to bloodborne pathogens or OPIM is possible. Examples of WCP include personal protection mechanisms such as using gloves and masks, hand-washing, proper disposal, and clean up of infectious materials. Other examples might include policies to prevent transmission by not allowing food or drinks in areas with blood or OPIM as well as the decontamination of equipment.
Engineering Control Practices (ECP) involves the employer’s evaluation of equipment to ensure they are safe to use and minimize the risk of exposure as much as possible. An example would be the utilization of a needleless system for healthcare professionals in order to minimize their risk to blood or OPIM. Other examples include the utilization of sharps containers and biohazard containers for infectious waste disposal.
Housekeeping Measures are important to minimize exposure to other employees. In the event of blood spillage, follow the procedures outlined below:
Employers whose activities include HIV or HBV research must provide additional training in bloodborne pathogens and the prevention of transmission of infected blood to employees as mandated by OSHA.
When an employee is exposed to bloodborne pathogens or OPIM, it is important for the employer to utilize their ECP to ensure that all the required steps take place during the process of treatment for the employee.
Emergency Situations: During an emergency it is important to act quickly. However, you must be sure to take into consideration your own safety as well as the safety of other individuals. This can be done using the steps outlined earlier in this course.
Once you consider safety, you should also be sure to provide yourself with protection if you are to administer first aid to another employee. This means utilizing the proper PPE. After this occurs and you if are properly trained to do so, you may assist the person exposed.
Bloodborne Pathogen Injury types may include needlesticks, blood to skin contact or mucous membranes or OPIM contact with the person’s skin or mucous membranes.
Needlestick Injuries: In the event of this type of incident you should remove the needle from yourself without causing further injury and in the most safe manner possible. Place the needle in a sharps container and any infected material in the proper container. It should be noted what type of needle the injury came from. Was it a needle that had been used on a person prior or a clean, unused needle? The needle should be secured and the person should wash their hands as soon as possible.
Blood or OPIM to Skin: In the event of exposure to skin, be sure to wash the area as thoroughly as possible. Discard any infectious materials in the proper container.
Blood or OPIM to Eyes: In the event of exposure to the eyes, be sure to wash the area using either an eye wash station or by cupping water in your eyes after washing your hands clean with soap and water. Open and close your eyes repeatedly. Do this for at least 20 minutes. Discard any infectious materials in the proper container.
Gathering Information: Get information regarding how the exposure occurred, what the ECP was and if the proper safety measures were followed. Find out as many details as possible surrounding the incident to use on any reports developed. This information may be useful for healthcare providers and for preventing exposure to the bloodborne pathogen or OPIM in the future. As a special note, any information relating to the exposed employee obtained by the employer should be kept confidential in accordance with the Health Insurance Portability and Accountability Act (HIPAA).
Reporting Requirements: Be sure to document how the exposure occurred and specifically the means of transmission (i.e. needlestick injury). Blood testing may occur at the hospital and treatment may be prescribed by the physician.
After an exposure occurs, the employer should do whatever is possible to avoid the same type of situation from occurring in the future. This may require the institution of additional engineering or workplace controls as well as the re-evaluation of the current ECP, engineering and/or workplace controls. The employer should ensure accurate reporting and determine whether or not safety and personal protective measures were taken during the event. Any injury from needles or sharp objects should be placed on an employer’s sharps injury log.
The employer should note the location and time of the incident, as well as the to schedule and conduct training.
