Did you know that the most frequent cause of OSHA violations related to the Bloodborne Pathogens Standard is outdated, or otherwise non-compliant, Exposure Control Plans?
It is generally known in the biotech community that Exposure Control Plans are required to be in place for any facility working with blood or other potentially infectious material (OPIM). What is often overlooked is that there is a specific regulatory requirement to update the Plan.
The Bloodborne Pathogens Standard (in section 1910.1030(c)(1)(iv) ) specifies that the Exposure Control Plan must be reviewed and updated at least annually and whenever necessary to include new or modified tasks and procedures which affect occupational exposure and to address new or revised employee positions with occupational exposure.
The review and update of the Exposure Control Plan must also reflect changes in technology that eliminate or reduce exposure to bloodborne pathogens and document annually consideration and implementation of appropriate commercially available and effective safer medical devices designed to eliminate or minimize occupational exposure.
As we talked about in our November 5th, 2020 blog, meeting this requirement is often fulfilled by having employees complete a safer sharps survey annually.
Another commonly cited violation of the Bloodborne Pathogens Standard is lack of proper training and/or not conducting the required training on an annual basis. The Standard requires that training be given at the time of initial assignment to tasks where occupational exposure may take place. It also requires that annual training be provided within one year (i.e., 12 months) of the previous training.
The annual training must include all of the training topics that are required for the initial training. Employers must also provide additional training when changes occur such as modification of tasks or procedures or institution of new tasks or procedures that affect employees’ occupational exposure.
For additional information on requirements of the OSHA Bloodborne Pathogens Standard, or for help updating your Exposure Control Plan and meeting the Standard’s training requirements please email firstname.lastname@example.org.
This blog was written by Beth Graham, our Associate Director of Quality, Research, and Training who has been with Safety Partners Inc. for the last 11 years.