I have had the opportunity to work with several housekeeping and cleaning contractor operations and from my observations discovered that a major part of the Bloodborne Pathogen (BBP) Standard is often ignored or is referenced generically. The key part being left out is the Exposure Control Plan (ECP). Usually defined in the program as the BBP are: The Methods of Compliance, Hepatitis B Explanations, and Personal Protective Equipment. However, the ECP is incomplete.
I would like to emphasize the BBP is not complete unless a thorough examination of exposures and job classifications are listed and classified according to job assignment.
It is important to review and classify employees according to their jobs. Recognize that the exposure determination will be based on the occupational exposure without personal protective equipment. Next review the job classifications of the personnel at the job site. Remembering exposures are site specific.
Divide the job classifications of the Site into job groups. As an example:
- Group A: group as all employees that have occupational exposure.
- Group B: group those employees that may have some exposure.
It is the employer’s responsibility to communicate to each group of employees their respective occupational Exposure to Blood or Other Potentially Infectious Material (OPIM). Gather information from your staff as well as from site audits in recognizing exposures. Understand the respective job function, processes and area assignments of each employee.
Most important is after determining the class of employees who has exposure to Blood or OPIM, Group A, you need to list all the task and procedures which an employee performs in the course of his job. From the task list recognize the exposures/hazards that are or may be present. Thoroughly determine if any exposure to a hazard can be eliminated. Could work practices mitigate the hazard? Finally, what is the correct Personal Protective Equipment (PPE) needed to protect the employee. Your selection of PPE should be outlined based on the results from your assessment knowledge gained from developing the ECP.
The Listing of Job Classifications, Exposures and Processes are mostly overlooked or given as a generic reference within the organization. As before stated the Exposure Control Plan is Site Specific and Performance Based. Recognize this fact is critical in completing the Bloodborne Pathogen Plan. I want to say if you have 10 different sites the Exposure Control Plan may be generic looking but the Exposure Control Plan must be developed relevant to the specific site. Not just a companywide statement relating to generic exposures, processes and area assignments. This has been my findings from my audits and inspections.
Referring to Group B, analyze their List of Tasks and Exposures as outlined above in Group One.
Train everyone in BBP. Also acknowledge that the job site is fluid and what was not an exposure or hazard today could become one tomorrow.
Create a simple form(matrix)to use that would outline the Job Classification; Area assignment; Task/Processes; Exposure; Personal Protective Equipment required, if needed.
Remember the Exposure Control Plan (ECP) must be updated and Job Listings re-analyzed on an annual basis. I suggest that all organizations develop a formal process of review and update of the Exposure Control Plan. Designate a supervisor or staff member that has qualifications to maintain audits and inspections of each job site. Continue to engage the site staff and have a communication channel for reporting changes or developments that may affect the Exposure Plan.
Finally, tell all staff members where this Plan is located and allow easy access to the ECP. That is a requirement in the BBP Standard. Keep everyone engaged in safe work practices and continually strive to improve you plan.