BBP Exposure Control Plan (ECP)

OSHA requires that each employer "establish a written Exposure Control Plan designed to eliminate or minimize employee exposure" to BBP.  

Responsibilities

CAHP parties and associated duties are as follow:

  • Students & faculty/staff - familiarize themselves & comply with all ECP procedures and work practices.
  • Department Chairpersons - ensure departmental compliance with all ECP components. 
  • Biosafety Committee - assist department chairs, identifies changes in occupational exposure risk.
  • Biosafety Officer - assist Dean in all biosafety matters, maintains, reviews, and updates the ECP annually.
  • Dean - overall program administration.


ECP Elements

The OSHA  Model Exposure Control Plan* has been used as a guide to develop a college-wide ECP, which elements are as follows:

  • Employee exposure determination 
  • Exposure control methods
    - universal precautions
    - engineering and work practice controls
    - personal protective equipment
    - housekeeping
  • Hepatitis B vaccination
  • Post-exposure evaluation/ follow-up
  • Communication of hazards to employees and training
  • Recordkeeping
  • Procedures for evaluating circumstances surrounding exposure incidents

* Model Plans and Programs for the OSHA Bloodborne Pathogens and Hazard Communications Standards available @ https://www.osha.gov/Publications/osha3186.pdf


Exposure Control Methods

  1. Universal Precautions - see Bloodborne pathogens page
  2. Engineering/Work Practice Controls - includes methods to eliminate or minimize potential workplace exposure.
    • Hand washing (or washing of other affected skin area) with lots of soap and water, or flushing mucous membranes with water, immediately following an exposure incident (e.g., blood splash to the eyes or an accidental puncture injury).  
    • Sharps devices are disposed of in labeled sharps containers provided at each location where sharps generation is anticipated. Needles should never be recapped, broken or sheared.
    • No eating, drinking, smoking, applying cosmetics/ lip products (e.g. Chapstick lip balm, etc.), or contact lenses handling is permitted in a work area        
    • No food or drinks are kept in refrigerators, freezers, cabinets where blood or other potentially infectious materials are present.  
    • Barrier devices (e.g. goggles with side shields, acrylic counter top barriers, etc.) are used when performing procedures involving blood or other potentially infectious materials.

    You must wash your hands immediately (or as soon as feasible) after removal of gloves. A foam-alcohol substitute can only be used in areas where sinks are not readily available.
  3. Personal Protective Equipment - appropriate PPE use provides an adequate barrier to infectious agent transmission from the patient to you and vice versa.  
     

    It's selection is based upon the "anticipated exposure" to blood or OPIMs*. PPE is used in a task-specific manner.  In other words, the task that you're going to perform dictates what PPE you're to use.  
    * Other potentially infectious materials.

    Directly below is a task-specific PPE example taken from Table 1 of the ECP. 

    Activity

    Hand washing

    Gloves

    Lab coat/apron

    Eyewear/face shield

    Venipuncture

    X

    X

    X

     X*

    * Use protective eyewear or face shield, if splattering of blood or OPIM is reasonably anticipated.


    Protection afforded by PPE lasts only as long as the barrier remains intact.  For example, water resistant gowns/lab coats should be removed and replaced with a clean one soon after soiling. Punctured gloves should be immediately replaced after washing your hands.

    Each department will determine task-specific risk exposure to determine appropriate PPE. Departments shall furnish size, allergen, and task appropriate PPE to all students, faculty & staff. 

  4. Housekeeping - measures used to ensure that (1) contaminated materials are properly disposed of, (2) work surfaces are routinely disinfected, (3)  blood or OPIM spills are properly decontaminated.

    Only ECP-approved disinfectants will be used to perform these procedures. 
  5. Training - Both initial and annual refresher training is required for all personnel determined to be at risk of BBP exposure.  The training requirement is the same for individuals in either academic or clinical settings. Additional site-specific training may be required by the clinical affiliate site.  Training records will be kept in the employee or student's permanent folder.

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