Why a Thorough Exposure Control Plan Is Vital (And How to Create One)

Why a Thorough Exposure Control Plan Is Vital (And How to Create One)

You likely were taught the phrase “Stop, drop, and roll” as a child. From a young age, teachers and firefighters educated us on the importance of taking care of ourselves if our bodies’ caught on fire. Just like there is an established plan of action for fires, we need to have plans for other potentially harmful scenarios. 

Whether you work in a healthcare setting, at a summer camp, or in any other capacity where you could reasonably come in contact with blood or body fluids, it is essential to be aware of the risks of bloodborne pathogen exposures. Bloodborne pathogens can cause serious infections, so your workplace should be adequately prepared with a detailed exposure control plan based on recommended infection control guidelines. Let’s explore the ins and outs of exposure control plans and how you can create one.


What Is an Exposure Control Plan?

The Bloodborne Pathogen Standard outlines the required contents of an exposure control plan as well as employee training requirements. There are 28 state Occupational and Health Plans which could adopt the federal standard or may have a more stringent plan. 

If you or other employees in your workplace are reasonably anticipated to have exposures to blood or other bodily fluids, you are required by the Occupational Safety and Health Administration’s (OSHA) Bloodborne Pathogens Standard to create and implement an exposure control plan. Tasks and procedures in which bloodborne pathogen exposure can occur include, but are not limited to:

  • Handling of blood, blood products, bodily fluids, or contaminated objects
  • Wound care
  • Invasive procedures
  • Phlebotomy or vascular access procedures and care
  • Contact with laboratory or pathological specimens
  • Handling medical waste
  • Contact with mucous membranes or non-intact skin
  • CPR and intubation
  • Cleaning or processing contaminated equipment
  • Decontaminating environmental surfaces
  • Sputum induction

In addition to blood, “other bodily fluids” includes other potentially infectious substances, including:

  • Semen
  • Vaginal secretions
  • Cerebrospinal fluids
  • Synovial fluids
  • Pleural fluids
  • Peritoneal fluids
  • Pericardial fluids
  • Amniotic fluids
  • Any other bodily fluid containing visible blood

According to OSHA, an exposure control plan must be written specifically for each facility, meaning you can’t copy a plan from another workplace. It must be reviewed and updated at least once a year to reflect changes like new technology used to reduce exposures or new employee positions. All employees must have easy access to the exposure control plan, and they need to be thoroughly educated on its contents and where it is kept.

Since employee education is such a vital part of exposure control plans, many workplaces find it valuable to hire an infection control consultant. A certified consultant will thoroughly educate your entire staff about current guidelines, federal regulations, and proven prevention practices. 


Why Are Exposure Control Plans Important?

You may be wondering why it’s so essential to have an exposure control plan at your facility. Simply put, an exposure control plan is important because it helps protect employees from harmful exposures to blood and other fluids. 

Chances are you weren’t taught about bloodborne pathogens the same week you learned “Stop, drop, and roll” in school. So what makes exposure to bloodborne pathogens so dangerous? Bloodborne pathogens include serious diseases, with the most common ones in the United States being:

  • Hepatitis B
  • Hepatitis C
  • HIV (Human Immunodeficiency Virus)

Chronic Hepatitis B and C cause considerable liver infections. In fact, almost all cases of liver cancer are caused by chronic Hepatitis B and C. People with Hepatitis B are more likely to die from liver-related complications, while those with Hepatitis C often develop cirrhosis— scarring of the liver. Hepatitis B can survive on surfaces outside the body for up to ten days if not properly disinfected. 

If you are infected with HIV, the virus will immediately attack and weaken your body’s immune system. If not detected and treated early on, HIV will progress to AIDS (acquired immunodeficiency syndrome) in roughly eight to ten years. AIDS is a potentially life-threatening disease that makes the body susceptible to developing issues like:

  • Cancers like lymphoma and sarcoma
  • Pneumonia
  • Candidiasis
  • Tuberculosis
  • Meningitis
  • Kidney disease
  • Neurological complications
  • And more

As you can see, the effects of bloodborne pathogen exposures aren’t only inconvenient, but they’re severe and potentially life-threatening. Keeping employees safe from these harmful exposures is why exposure control plans are so important. 


What Should Be Included in an Exposure Control Plan?

Even though OSHA requires each facility to craft a specific exposure control plan, there are basic categories that should be included in all plans. As you create your own exposure control plan, you can reference the outline provided here:



In this introductory section, detail the name of your facility and why it is committed to forming an exposure control plan. From there, outline the remaining sections included in your plan.


Program Administration

Use this portion to list the names and contact information of the person or department responsible for implementing the exposure control plan. Also include names and contact information of the person who will review the plan each year, employees at risk of occupational exposure, the person who will provide all personal protective equipment (PPE), and the person responsible for training. 


Employee Exposure Determination

You can provide more details about your at-risk employees in this section. List the job classifications of employees who handle occupational exposure. Include their job title, location, and all procedures and tasks in which occupational exposure may occur. Note that all full-time, part-time, temporary, contract, and per diem employees are covered by OSHA’s Bloodborne Pathogens Standard.  Don’t be overwhelmed by the thought of listing procedures and tasks since these can be grouped into general categories.  


Methods of Implementation and Control

This is the portion of your exposure control plan that will detail preventative measures. Be sure to include:

  • Engineering controls and work practice controls
  • Provided PPE and PPE protocols
  • Housekeeping and waste removal procedures
  • Laundry requirements
  • Labeling methods for specimens, biohazards, etc.
  • Encourage free Hepatitis B vaccinations

All employees should also be trained on preventative hand hygiene as well as your facility’s stance on respiratory hygiene and cough etiquette.


Post-Exposure Evaluation and Follow-Up

Should an exposure occur, use this section to detail post-exposure steps. Provide specific action steps, such as:

  • Completing immediate first aid (clean the wound, flush eyes, etc.)
  • How to report an exposure and who should be notified
  • Where to go to obtain a prompt, confidential medical evaluation and follow-up
  • Documenting how the exposure occurred
  • Identifying and documenting the source individual
  • Arranging for the source individual to be tested for HIV, Hepatitis B, and Hepatitis C as soon as possible
  • Providing the source individual’s test results to the exposed employee
  • Testing the exposed employee’s blood for infection

Keep in mind that testing and documenting both the source individual and exposed employee requires you to obtain consent before proceeding. 


Exposure Control Plans Keep Employees Safe

Considering how dangerous exposure to bloodborne pathogens can be, it’s no surprise why OSHA requires facilities with exposure to blood or other bodily fluids to have a detailed exposure control plan. Remember to keep your document “living” and review and update it at least once a year.

Exposure control education is valuable for healthcare facilities of all kinds. An infection control specialist can lead your education program each year to ensure your employees are thoroughly aware of all exposure control protocols. Contact Infection Control Results to learn more.