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NIOSH Publication No. 2008-115:First Responders: Protect Your Employees with an Exposure Control Plan |
July 2008 |
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What is an Exposure Control Plan?An Exposure Control Plan is the focal point of any bloodborne pathogens exposure prevention program. It details in writing your plan for reducing exposures to bloodborne pathogens and explains what steps to take when an exposure occurs. The Plan specifies all steps taken by your department to protect your workers. Why is an Exposure Control Plan Important?First — and most important — your Exposure Control Plan helps you protect your frontline workers from exposure to bloodborne pathogens. Second, if your workers are at risk for a bloodborne pathogens exposure, you may be required by the law to have a written Exposure Control Plan. Third, the costs of an exposure incident can be significant, including post-exposure treatment and counseling, as well as loss of employee work time. If an employee does contract an illness, costs can dramatically escalate from increased worker’s compensation, lost work time, training of a replacement, etc. The Plan helps you control these costs by reducing exposures to bloodborne pathogens.
Your first line of defense
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Your Exposure Control Plan must be:
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The National Institute for Occupational Safety and Health (NIOSH) identified a number of problems with the Exposure Control Plans at fire, emergency medical services, and police departments.
Here are some tips on how to avoid these problems. Review your Plan to see if it has any of these defects. If it does, revise the Plan to fix the problems.
A written Exposure Control Plan is the basis for an effective bloodborne pathogens program. Update it annually.
During initial and annual bloodborne pathogens training, tell workers about the Exposure Control Plan and where they can find it.
Your Exposure Control Plan should identify a designated individual responsible for implementing the Plan.
Make one list of job titles where all employees have reasonably anticipated contact with blood or other potentially infectious materials and another list of job titles where specified tasks or procedures put some employees at risk of exposure.
Provide safety devices engineered to prevent needlesticks and other sharps injuries to employees who use these devices. The use of these devices will help prevent exposures to blood.
Involve frontline employees in the evaluation and selection of safety devices. Document the selection process in your Exposure Control Plan.
Your Exposure Control Plan should specify work practices to control exposures to bloodborne pathogens. For example, the Plan should cover decontamination of work surfaces and equipment and inspection and replacement of sharps disposal containers, including who is responsible for doing these tasks.
The Exposure Control Plan should provide guidelines on when and how to use different types of PPE. PPE includes disposable gloves, other protective clothing, face and eye protection, and ventilation devices. Under normal conditions, PPE should not permit blood or body fluids to reach the workers’ skin, eyes, mouth, outer clothing, or undergarments.
Offer the vaccination series at no cost to employees after required training, which includes information on the vaccine. Vaccination is encouraged unless the employee has been previously vaccinated, is immune, or vaccination is not medically indicated. The Plan must also designate someone responsible for the vaccination program and include a vaccination declination form.
Let employees know the procedure for reporting exposures, and have a plan for immediate medical evaluation and follow-up.
REMEMBER: Update your Exposure Control Plan every year, and get the updates into every copy!
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