Exposure Control Plan: 7 Required Elements (OSHA Bloodborne Pathogens)

OSHA’s Bloodborne Pathogens Standard (29 CFR 1910.1030) mandates a written Exposure Control Plan with these seven elements:

1. Exposure Determination: List all jobs/tasks with occupational exposure to blood/OPIM.
2. Exposed Employee Roster: Identify covered employees by role and department.
3. Control Methods: Engineering (sharps containers, safer devices), work practice (hand hygiene, no recapping), administrative (policies, training), PPE.
4. Post-Exposure Protocol: Immediate first aid, confidential medical evaluation, source testing, counseling, follow-up per CDC guidelines.
5. Training Program: Initial + annual; covers risks, controls, PPE, Hep B vaccine, exposure response.
6. Recordkeeping: Sharps injury log (5 years), training records (3 years), medical records (duration + 30 years).
7. Annual Review & Update: Evaluate effectiveness; incorporate new technology, regulatory changes, incident lessons.

The plan must be accessible to all employees and updated at least annually.