Exposure Control Plan (ECP)

An Employer's Exposure Control Plan

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.

1. The purpose of the Exposure Control Plan(ECP) is to _____.

a. help employees after they've been exposed to bloodborne pathogens
b. establish procedures to create or increase employee exposure to bloodborne pathogens
c. establish procedures to eliminate or minimize exposure to bloodborne pathogens
d. reduce the employer's legal liability after an employee is exposed to bloodborne pathogens

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Does your employer have an exposure control plan?

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:

  • Engineering and work practice controls
  • Personal protective equipment (PPE)
  • Housekeeping
  • Containment and labeling of potentially infectious materials

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.

2. The ECP is a site-specific plan that identifies all employee classifications which have occupational exposure to bloodborne pathogens and _____.

a. other potentially infectious materials (OPIM)
b. hazardous conditions and activities
c. employees sharing needles in public
d. all other patient bodily fluids

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Your employer's exposure control plan (continued)

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 written ECP 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.

Employees Must Have Access To Their Employer's
Exposure Control Plan (ECP)

3. Where must the employer identify all specific procedures employees perform which may expose them to bloodborne pathogens?

a. Job description
b. Exposure control plan (ECP)
c. Standard operating procedures (SOP)
d. Employee handbook

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Scenario

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.

Should Steven's position be classified as having occupational exposure to bloodborne pathogens?

Yes!

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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