Guidelines and Instructions for Developing a Bloodborne Pathogen Exposure Control Plan - Introduction - Maryland Occupational Safety and Health (MOSH)

MOSH is providing this publication to assist you in complying with the requirements of the bloodborne pathogen standard. While we have attempted to make these materials as Auser friendly@ as possible, it is essential that you read the full text of the standard (29 CFR 1910.1030) before beginning to develop your exposure control plan.

Since our aim is to provide practical guidance to small establishments such as dentists' and physicians' offices, we have not included information on paragraph (e) which relates to HIV and HBV research labs and production facilities.

It is important that you understand that the bloodborne pathogen standard is a performance standard, not a specification standard. That means that the regulation identifies the goals you must achieve, and then gives you the freedom to choose the compliance strategy that best suits your needs. This approach differs from specification standards that tell you what you have to do and give you only one way to do it.

The advantage of performance standards is that they allow you more flexibility in deciding how you will comply. There may be many ways of achieving compliance with a particular aspect of the regulation, and the performance-oriented approach gives you the freedom to choose the methods that work best for you, provided that they meet the requirements of the standard.

The regulation requires that you develop a written plan which describes how you will manage exposure to bloodborne pathogens in your facility and these guidelines can help you do just that. While we have done a lot of the organizational legwork for you, you will still have to supply the details concerning the specific procedures you have decided to follow at your facility.

After you have read over the standard, you can use our compliance worksheet to identify deficiencies or weaknesses in your existing program. If you do not have a program, you can use the worksheet to help develop one, but you should be aware that not everything on the worksheet may be relevant to your facility. For example, if you do not handle specimens, then the requirements for specimen handling would not apply to you.

To make things easy for you, we have provided a sample exposure control plan that can be filled out once you have completed the compliance worksheet. Both the sample plan and the compliance worksheet include references to relevant sections of 29 CFR 1910.1030 so you can check the exact wording of the standard if you need clarification on some points.

We have allowed space in the sample program for you to fill in appropriate information. If necessary, you may wish to add additional pages.

Updated March 19, 2010