An employer exposure control plan (ECP) is a requirement of 29 CFR 1910.1030(c) of the Bloodborne Pathogens Standard established by the Occupational Safety and Health Administration (OSHA). The purpose of the ECP is to establish procedures to eliminate or minimize employee exposure to bloodborne pathogens.
A written ECP outlines the strategies necessary to eliminate or minimize employee occupational exposure to bloodborne pathogens. This site-specific plan identifies all employee classifications which have occupational exposure to bloodborne pathogens and other potentially infectious materials.
Additional components of an ECP are:
Another key component of the plan includes listing the site-specific means by which the facility will reduce the employee risk. These methods include appropriate training, the communication of hazards, hepatitis B vaccinations for any employee who has occupational risk of exposure, methods for post-exposure evaluation and follow-up, proper recordkeeping, and a sharps injury log.
The plan should also describe the procedure for investigating and evaluating the circumstances surrounding an exposure incident to quickly provide effective follow-up care to exposed employees. The investigation will also help each site team learn from accidents and establish new measures to prevent them from happening again.
The ECP plan must be accessible to all employees. It must be reviewed and updated annually or when alterations in procedures create the possibility of new occupational exposures. Additionally, non-managerial employees who provide direct patient care must be asked to provide input in the identification, evaluation, and selection of effective controls to isolate or remove bloodborne pathogens from the workplace.
Although an employee's job description may include information regarding potential exposure to bloodborne pathogens, it may not be legally required. The employer's exposure control plan must identify all specific procedures an employee performs which may expose them to bloodborne pathogens.
Steven is a new employee for AAA Manufacturing. He has been hired as a supervisor to oversee line production on the swing-shift. As a supervisor, he is expected to provide emergency medical care if an employee becomes injured or sick.
Although providing emergency medical care is not Steven's primary responsibility, it is part of his job classification. As a result, Steven does have the potential for occupational exposure to bloodborne pathogens. Steven's employer must ensure he has the proper training and equipment to provide medical care safely and with minimal risk of occupational exposure.
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