Top 8 Exposure Control Requirements That OSHA Expects

Posted by Selin Hoboy on Wed, Apr 09, 2014 @ 06:37 AM

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For many, the first image that comes to mind when the words "EXPOSURE CONTROL" are brought up in healthcare is a needlestick injury. Healthcare safety experts report that annually hundreds of thousands of needlestick injuries take place.


OSHA’s Bloodborne Pathogens Standard (1910.1030) aims to reduce needlestick injuries among other exposures to blood and other potentially infectious materials (OPIM). Here are the top 8 Exposure Control requirements if you have employees who are exposed or have the potential to be exposed to blood or other potentially infectious materials:

  1.  Written Bloodborne Pathogens Exposure Control Plan (ECP)

    • Steri•Safe OSHA Compliance Solutions customers can use the Steri•Safe Safety Plan Builder at to create the written Exposure Control Plan.
  2. Documented review and update of the ECP 

    Be sure to not only review and update your ECP annually, but also to document the fact that you have done so in writing. Include updates as you make changes to your operation (eg, staff changes or other changes that affect the Plan’s contents).
    • Steri•Safe OSHA Compliance Solutions customers can use the Steri•Safe Safety Plan Builder at to create the written Exposure Control Plan.
  3. Documented  consideration and implementation of safer medical devices at the site level

    • Steri•Safe OSHA Compliance Solutions customers can use the evaluation forms from Steri-Safe’s Safety Plan Builder at to document the fact that you have considered and implemented safer medical devices annually
  4. Documented solicitation of non-managerial input. 

    Typically done in conjunction with #3 above, OSHA requires the annual documentation in writing to support that you have solicited input from your facility’s non-managerial staff members concerning such things as safer medical devices and other engineering controls that would contribute to a safer, more healthful workplace. 

    • Steri•Safe OSHA Compliance Solutions customers can use Steri•Safe’s Safety Plan Builder at to document the solicitation of non-managerial input. 
  5. Hepatitis B Immunization 

    OSHA requires that the employer offer all employees with the possibility of exposure to blood/OPIM the hepatitis B virus (HBV) immunization.  All costs associated with the HBV immunization must be paid by the employer and may not be passed along to an employee’s own medical insurance provider for payment unless that insurance is 100% paid by the employer with no deductibles, copayments, payroll withholding, or other costs to the employee. Any employee is permitted to decline the immunization, but such employees must sign a declination form.

    Steri•Safe OSHA Compliance Solutions customers may access the declination form through the Safety Plan Builder on The hepatitis B immunization must be offered within 10 days of hire and before placement into an area or activities where the potential for exposure exists.

  6. Hepatitis B Antibody Testing

    As required by OSHA 1 to 2 months after completion of the HBV immunization series, OSHA requires antibody testing in accordance with USPHS guidelines.  However, routine, periodic antibody testing beyond that done upon completion of the initial immunization series is neither required nor currently recommended by the guidelines. 
  7. Signs and Labels 

    OSHA requires that the biohazard symbol and color coding be evident where biohazardous materials are present. 

    • Call Stericycle’s product support team for assistance in purchasing signs and labels: 800-355-8773. 
    • Stericycle customers may purchase these signs and labels upon registering and logging into
  8. Bloodborne Pathogens  (BBP) Training

    OSHA requires BBP Training initially before placement into potential exposure situations and annually thereafter for any and all employees with potential for exposure to blood or OPIM.  The training must be specific to the particular workplace. 

    • Steri•Safe OSHA Compliance customers can take advantage of the Steri•Safe award-winning online Bloodborne Pathogens Training or the personalized on-site Bloodborne Pathogens Training conducted by a Stericycle Certified Occupational Safety Specialist with more than 30 hours of OSHA Training as part of the Preferred Steri-Safe OSHA Compliance Solutions suite of services.   

Tackling and achieving these 8 requirements provides your facility with a stable foundation to prevent exposure control situations. Use this list to make your facility safe and healthful today.

If you have questions about these exposure control requirements, direct them to our regulatory experts at 1.866.783.9816 or contact us online:

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Current customers: contact us by phone 1.866.783.7422 or email at

Coming Soon!  The new will make it even easier for Stericycle customers to manage Regulated Medical Waste and Compliance Services. 

Topics: OSHA Compliance, Bloodborne Pathogens, Bloodborne Pathogens Exposure Control, Exposure Control Requirements, Exposure Control Plans

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