Wednesday, June 4, 2014

Exposure Control FAQs

Q8. What is an exposure control plan?

A8. The exposure control plan is the employer's written program that outlines the protective measures an employer will take to eliminate or minimize employee exposure to blood and OPIM.
The exposure control plan must contain, at a minimum:
  • The exposure determination which identifies job classifications with occupational exposure and tasks and procedures where there is occupational exposure and that are performed by employees in job classifications in which some employees have occupational exposure.
  • The procedures for evaluating the circumstances surrounding exposure incidents;
  • A schedule of how other provisions of the standard are implemented, including methods of compliance, HIV and HBV research laboratories and production facilities requirements, hepatitis B vaccination and post-exposure evaluation and follow-up, communication of hazards to employees, and recordkeeping; Methods of compliance include:
    • Universal Precautions;
    • Engineering and work practice controls, e.g., safer medical devices, sharps disposal containers, hand hygiene;
    • Personal protective equipment;
    • Housekeeping, including decontamination procedures and removal of regulated waste.
  • Documentation of:
    • the annual consideration and implementation of appropriate commercially available and effective safer medical devices designed to eliminate or minimize occupational exposure, and
    • the solicitation of non-managerial healthcare workers (who are responsible for direct patient care and are potentially exposed to injuries from contaminated sharps) in the identification, evaluation, and selection of effective engineering and work practice controls.

Q9. In the exposure control plan, are employers required to list specific tasks that place the employee at risk for all job classifications?

A9. No. If all the employees within a specific job classification perform duties where occupational exposure occurs, then a list of specific tasks and procedures is not required for that job classification. However, the job classification (e.g., "nurse") must be listed in the plan's exposure determination, and all employees within the job classification must be included under the requirements of the standard.

Q10. Can tasks and procedures be grouped for certain job classifications?

A10. Yes. Tasks and procedures that are closely related may be grouped. In other words, they must share a common activity, such as "vascular access procedure" or "handling of contaminated sharps."

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