Free printable template · PDF
Bloodborne Pathogens Exposure Control Plan
A fill-in written exposure control plan that follows the sections OSHA's Bloodborne Pathogens Standard requires. Complete it for your clinic, review it with your team, and update it every year.
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Bloodborne Pathogens Exposure Control Plan
MedSpaBinder
Clinic
Plan administrator
Effective date
Template only. Complete it for your clinic, review it at least yearly, and keep it where every employee can read it.
1. Plan administrator and access
Plan administrator (name, title)
Phone / email
Where the plan is kept
Employees can get a copy from
2a. Exposure determination: job titles where ALL employees have occupational exposure
2b. Job titles where SOME employees have exposure, and the tasks that cause it
Exposure is decided as if no protective equipment were worn (OSHA requires this). Common exposures in a med spa: injections, microneedling, PRP, IV therapy, laser and other procedures that can draw blood, handling sharps, and cleaning contaminated equipment.
3. Methods of compliance: how we control exposure here
4. Hepatitis B vaccination
The hepatitis B vaccine is offered at no cost to every employee with occupational exposure, after bloodborne pathogens training and within 10 working days of starting the job. Employees who decline sign the OSHA declination statement (Appendix A). An employee who declines can accept later, still at no cost.
Vaccine provided by (clinic or provider)
Phone
5. Post-exposure evaluation and follow-up
After a needlestick, cut, or splash to the eyes, nose, mouth or broken skin: wash the area right away, report it immediately to the person named below, and go for a confidential medical evaluation, which the employer provides at no cost.
The employer documents the route and circumstances of the exposure, identifies and (with consent, where the law allows) tests the source individual, and gives the evaluating healthcare professional a copy of the standard, the employee's duties, the exposure details, source test results and the employee's vaccination records. The employee gets a copy of the healthcare professional's written opinion within 15 days of the evaluation.
Report exposures to (name, phone)
Post-exposure provider (name, address, phone)
After hours
6. Reviewing each exposure incident: we look at
Engineering controls in use at the time
Work practices followed
Device in use (type and brand)
Protective equipment worn
Location and procedure
Training of the employee
7. Training and communication of hazards
Trainer (name and qualifications)
Training method (in person, video + Q&A)
Initial training: before first exposure
Refresher: at least every 12 months
8. Recordkeeping
Medical records (vaccination status, exposure evaluations, written opinions) are kept confidential and for the length of employment plus 30 years. Training records (dates, content summary, trainer's name and qualifications, attendees' names and job titles) are kept for 3 years. Employers required to keep OSHA injury and illness records also keep a sharps injury log.
9. Annual review, including safer devices and input from front-line staff
Approved by: ______________________ Title: ______________________ Date: ____________
Who needs an exposure control plan?
Every employer with an employee who has occupational exposure to blood or other potentially infectious materials needs a written exposure control plan under OSHA's Bloodborne Pathogens Standard (29 CFR 1910.1030). In a med spa, that covers injectors, nurses and anyone who handles sharps or cleans contaminated equipment.
What OSHA requires the plan to contain
- An exposure determination: the job titles in which all employees have exposure, and those in which some do, with the tasks involved. It's made without regard to protective equipment.
- The schedule and method for putting the standard's requirements in place: controls and work practices, hepatitis B vaccination, post-exposure evaluation and follow-up, communicating hazards to employees, and recordkeeping.
- The procedure for evaluating the circumstances of an exposure incident.
- A review and update at least once a year, which documents the safer medical devices you considered and used, and the input you asked for from front-line staff who use sharps.
How to fill in the template
- Name a plan administrator and say where the plan is kept. Every employee must be able to see it.
- List your job titles honestly under 2a or 2b. If an esthetician never handles sharps or blood, say so; if they do microneedling, they belong in the list.
- Write what you actually do in section 3: which safety needles you use, where the sharps containers are, who empties them.
- Fill in the post-exposure provider before you need one. After a needlestick, time matters.
- Review it every year with the staff who do the work, and record who you asked.
Questions
How often must the exposure control plan be updated?
At least annually, and whenever new or changed tasks, procedures or job positions affect exposure. The annual review must document consideration of safer medical devices.
Is this plan enough for OSHA compliance?
It's the written part. OSHA also expects the plan to be followed: training every year, the vaccine offered, protective equipment provided and records kept. Some states run their own OSHA plans with extra rules, so check yours.
Sources
General guidance, not legal or medical advice. Requirements vary by state; follow your medical director and product labels.