Easy Exposure Control Plan (ECP)

Annual Updating is Mandatory

OSHA mandates a written ECP must be constructed by the institution detailing the strategy
and processes involved in reducing exposure to blood and Other Potentially
Infectious Materials (OPIM).

The major changes for 2003 include:

• ECP must be updated annually, even if no change has occurred.
• Employers must implement devices "appropriate, commercially available and effective"
• ECP must include input from non-managerial employees train employees on Hepas C and maintain a sharps injury log.

OSHA inspectors will seek out your ECP before proceeding with any other aspect of a routine inspection. A well prepared ECP will do much to put the inspectors in the right mood to approve your safety procedures. We at Feta Med, Inc. want you to pass every time!

These guidelines will assist you in the preparation of an effective ECP:

Steps:

1. Secure a large binder with several chapter dividers
2. Prepare an “Exposure Determination” of your facility
3. Include: Doctor, Nurse, Patient, Housekeeping, Laundry, and Medical Waste exposure analysis
4. Establish protocols for Communication of Hazards (such as labeling & training)
5. Establish protocols for reporting and evaluating an Exposure Incident
6. Establish post exposure procedures such as HBV, HIV vaccinations, etc.
7. List all safety devices used and considered for use
8. Document Safety, Suitability and Appropriateness for each item (Evaluation forms appended)
9. Describe methodology for determination of safety item preference: price, reliability, etc.
10. Solicit and document all employees’ opinions in setting the ECP
11. Document the Schedule of your ECP Implementation Plan throughout the facility
12. Make final ECP accessible to every employee, post multiple copies if necessary
13. Revise every year, even if there are no changes
14. Never have “no changes”, technology changes all the time and OSHA expects vigilance
15. The OSHA Model ECP is available at: osha.gov/OshDoc/Directive_pdf/CPL_2-2_69_APPD.pdf (Address is case sensitive)

Document your facility’s efforts to improve safety throughout the year. Include commercial material, Sampled items, relevant journal articles, etc. OSHA will know you are a vigilant partner in reducing blood born infectious opportunities.

Remember, price is a factor but not an excuse. You must adopt safety products to fully comply with OSHA standards.

Feta Med will help you find the lowest cost/best designed products to satisfy your pocketbook and OSHA.