Sample Written Program This sample Bloodborne Pathogens program is provided by the Missouri On-Site Safety and Health Consultation Program. In order to comply with OSHA’s standard for Bloodborne Pathogens, 29 CFR 1910.1030, this written program must be site specific. Modify the template to reflect the policies and procedures at your company. Since OSHA regulations set minimum requirements, you may choose to add additional information to your site specific program. There is no requirement to follow this sample and its use does not guarantee compliance with the OSHA standard. To prepare your plan, please follow these steps: 1. Read the Bloodborne Pathogens Standard 29 CFR 1910.1030 2. The following information may be useful in developing your program: 3. Add information to make it site specific to your company. 4. For clarification or assistance, contact the Missouri On-Site Safety and Health Consultation Program at 573-522-SAFE. Bloodborne Pathogens Exposure Control Plan (To customize, please complete and remove the highlighted areas of the program) Date Created: Date Reviewed: 1. Company Policy (Name of Company) is committed to providing a safe and healthful work environment for our entire staff. In pursuit of this goal, the following exposure control plan (ECP) is provided to eliminate or minimize occupational exposure to bloodborne pathogens in accordance with OSHA standard 29 CFR 1910.1030, “Occupational Exposure to Bloodborne Pathogens.” The ECP is a key document to assist our organization in implementing and ensuring compliance with the standard, thereby protecting our employees. This ECP includes:
Implementation methods for these elements of the standard are discussed in the subsequent pages of this ECP. 2. Program Administration (Name of person or job title) is responsible for the implementation of the ECP. (Name of person or job title) will maintain, review and update the ECP at least annually and whenever necessary to include new or modified tasks and procedures. Employees who are determined to have occupational exposure to blood or other potentially infectious materials (OPIM) must comply with the procedures and work practices outlined in this ECP. (Name of person or job title) will provide and maintain all necessary personal protective equipment (PPE), engineering controls (e.g., sharps containers), labels and red bags as required by the standard. (Name of person or job title) will ensure that adequate supplies of the aforementioned equipment are available in the appropriate sizes. (Name of person or job title) will be responsible for ensuring that all medical actions required by the standard are performed and that appropriate employee health and OSHA records are maintained. (Name of person or job title) will be responsible for training, documentation of training and making the written ECP available to employees, OSHA and NIOSH representatives. 3. Employee Exposure Determination The following is a list of all job classifications at our establishment in which all employees have occupational exposure: (Use as many lines as necessary).
The following is a list of job classifications in which some employees at our establishment have occupational exposure. Included is a list of tasks and procedures, or groups of closely related tasks and procedures, in which occupational exposure may occur for these individuals: (Use as many lines as necessary).
NOTE: Part-time, temporary, contract and per diem employees are covered by the Bloodborne Pathogens standard. The ECP should describe how the standard will be met for these employees. 4. Methods of Implementation and Control Universal Precautions All employees will utilize universal precautions. Exposure Control Plan Employees covered by the Bloodborne Pathogens standard will receive an explanation of this ECP during their initial training session. It will also be reviewed in their annual refresher training. All employees can review this plan at any time during their work shifts by contacting (Name of person or job title). If requested, we will provide an employee with a copy of the ECP free of charge and within 15 days of the request. (Name of person or job title) is responsible for reviewing and updating the ECP annually or more frequently if necessary to reflect any new or modified tasks and procedures that affect occupational exposure and to reflect new or revised employee positions with occupational exposure. 5. Engineering Controls and Work Practices Engineering controls and work practice controls will be used to prevent or minimize exposure to bloodborne pathogens. The specific engineering controls and work practice controls used are listed below: (For example: non-glass capillary tubes, SESIPs, needleless systems) Sharps disposal containers are inspected and maintained or replaced by (Name of person or job title) whenever necessary to prevent overfilling. This facility identifies the need for changes in engineering controls and work practices through (Examples: Review of OSHA records, employee interviews, committee activities, etc.) We evaluate new procedures and new products regularly by (Describe the process, literature reviewed, supplier info, products considered) Both front-line workers and management officials are involved in this process in the following manner: (Describe employees' involvement) (Name of person or job title) is responsible for ensuring that these recommendations are implemented. 6. Personal Protective Equipment (PPE) PPE is provided to our employees at no cost to them. Training in the use of the appropriate PPE for specific tasks or procedures is provided by (Name of person or job title). The types of PPE available to employees are as follows: (gloves, gowns, eye protection, etc.) PPE is located (Location) and may be obtained through contacting (Name of person or job title). (Specify how employees will obtain PPE and who is responsible for ensuring that PPE is available.) All employees using PPE must observe the following precautions:
The procedure for handling used PPE is as follows: (May refer to specific procedure by title or number and last date of review; include how and where to find decontaminate face shields, eye protection, resuscitation equipment) 7. Housekeeping Regulated waste is placed in containers which are closable, constructed to contain all contents and prevent leakage, appropriately labeled or color-coded (see the following section “Labels”), and closed prior to removal to prevent spillage or protrusion of contents during handling. The procedure for handling sharps disposal containers is: (May refer to specific procedure by title or number and last date of review) The procedure for handling other regulated waste is: (May refer to specific procedure by title or number and last date of review) Contaminated sharps are discarded immediately or as soon as possible in containers that are closable, puncture-resistant, leak proof on sides and bottoms, and appropriately labeled or color coded. Sharps disposal containers are available at (Locations) They will be placed in locations that are easily accessible and as close as feasible to the immediate area where sharps are used. Bins and pails (e.g., wash or emesis basins) are cleaned and decontaminated as soon as feasible after visible contamination. Broken glassware that may be contaminated is only picked up using mechanical means, such as a brush and dustpan. 8. Laundry The following contaminated articles will be laundered by this company: Laundering will be performed by (Name of person or job title or department). The following laundering requirements must be met:
9. Labels The following labeling methods are used in this facility:
(Name of person or job title) is responsible for ensuring that warning labels are affixed, or red bags are used as required if regulated waste or contaminated equipment is brought into the facility. Employees are to notify (Name of person or job title) if they discover regulated waste containers, refrigerators containing blood or OPIM, contaminated equipment, etc., without proper labels. 10. Hepatitis B Vaccination (Name of person or job title) will provide training to employees on hepatitis B vaccinations, addressing safety, benefits, efficacy, methods of administration, and availability. The hepatitis B vaccination series is available at no cost after initial employee training and within 10 days of initial assignment to all employees identified in the exposure determination section of this plan. Vaccination is encouraged unless: 1) documentation exists that the employee has previously received the series; 2) antibody testing reveals that the employee is immune; or 3) medical evaluation shows that vaccination is contraindicated. However, if an employee declines the vaccination, the employee must sign a declination form. Employees who decline may request and obtain the vaccination at a later date at no cost. Documentation of refusal of the vaccination is kept at (Location). Vaccination will be provided by (List health care professional responsible for this part of the plan). Following the medical evaluation, a copy of the health care professional’s written opinion will be obtained and provided to the employee within 15 days of the completion of the evaluation. It will be limited to whether the employee requires the hepatitis vaccination and whether the vaccine was administered. 11. Post-Exposure Evaluation and Follow-Up Should an exposure incident occur, contact (Name of person or job title). An immediately available confidential medical evaluation and follow-up will be conducted by (Name of licensed health care professional). Following initial first aid (clean the wound, flush eyes or other mucous membrane, etc.), the following activities will be performed:
12. Administration of Post-Exposure Evaluation and Follow-Up (Name of person or job title) ensures that the health care professional(s) responsible for employee’s hepatitis B vaccination and post-exposure evaluation and follow-up are given a copy of OSHA’s Bloodborne Pathogens standard. (Name of person or job title) ensures that the health care professional evaluating an employee after an exposure incident receives the following:
(Name of person or job title) will provide the employee with a copy of the evaluating health care professional’s written opinion within 15 days after completion of the evaluation. 13. Procedures for Evaluating the Circumstances Surrounding an Exposure Incident (Name of person or job title) will review the circumstances of all exposure incidents to determine:
(Name of person or job title) will record all percutaneous injuries from contaminated sharps in a Sharps Injury Log. If revisions to this ECP are necessary (Name of person or job title) will ensure that appropriate changes are made. (Changes may include an evaluation of safer devices, adding employees to the exposure determination list, etc.) 14. Employee Training All employees who have occupational exposure to bloodborne pathogens receive initial and annual training conducted by (Name of person or job title). (Attached is a brief description of their qualifications.) All employees who have occupational exposure to bloodborne pathogens receive training on the epidemiology, symptoms and transmission of bloodborne pathogen diseases. In addition, the training program covers, at a minimum, the following elements:
Training materials for this facility are available at (Location). 15. Recordkeeping Training records are completed for each employee upon completion of training. These documents will be kept for at least three years. The training records include:
Employee training records are provided upon request to the employee or the employee’s authorized representative within 15 working days. Such requests should be addressed to (Name of person or job title). 16. Medical Records Medical records are maintained for each employee with occupational exposure in accordance with 29 CFR 1910.1020, “Access to Employee Exposure and Medical Records.” (Name of person or job title) is responsible for maintenance of the required medical records. These confidential records are kept in (Location) for at least the duration of employment plus 30 years. Employee medical records are provided upon request of the employee or to anyone having written consent of the employee within 15 working days. Such requests should be sent to (Name of person or job title). 17. OSHA Recordkeeping Exposure incidents will be evaluated to determine if the case meets OSHA’s Recordkeeping Requirements (29 CFR 1904). This determination and the recording activities are done by (Name of person or job title). 18. Sharps Injury Log In addition to the 1904 Recordkeeping Requirements, all percutaneous injuries from contaminated sharps are also recorded in a Sharps Injury Log. All incidences must include at least:
This log is reviewed as part of the annual program evaluation and maintained for at least five years following the end of the calendar year covered. If a copy is requested by anyone, it must have any personal identifiers removed from the report.
*Optional Entry HEPATITIS B VACCINE DECLINATION (MANDATORY) I understand that due to my occupational exposure to blood or other potentially infectious materials I may be at risk of acquiring hepatitis B virus (HBV) infection. I have been given the opportunity to be vaccinated with hepatitis B vaccine, at no charge to myself. However, I decline hepatitis B vaccination at this time. I understand that by declining this vaccine, I continue to be at risk of acquiring hepatitis B, a serious disease. If in the future I continue to have occupational exposure to blood or other potentially infectious materials and I want to be vaccinated with the hepatitis B vaccine, I can receive the vaccination series at no charge to me. Signed: ______________________________ Date: __________________________________ Bloodborne Pathogens/Exposure Control Plan Training Roster Training Performed By:
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One new element added to the employers annual review of the exposure control plan requirements
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