OSHA Requires Annual Updates
OSHA has determined that each employer having an employee(s) with occupational exposure to blood or other potentially infectious body fluids including semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid, peritoneal fluid, amniotic fluid, saliva in dental procedures, and any body fluid visibly contaminated with blood MUST establish a written Exposure Control Plan designed to eliminate or minimize employee exposure. OSHA further stipulates that the Exposure Control Plan shall be reviewed and updated at least annually and whenever necessary to reflect new or modified tasks and procedures which affect occupational exposure and to reflect new or revised employee positions with occupational exposure.
Many citations have been issued to facilities that have NOT updated their Exposure Control Plan to reflect changes in technology that eliminate or reduce exposure to bloodborne pathogens. Other citations have been issued for those that fail to document annually consideration and implementation of appropriate commercially available and effective safer medical devices designed to eliminate or minimize occupational exposure.