Do You Have an Exposure Control Plan?

     No one knows better than EMS personnel the inherent risks of being exposed to a contagious disease or infectious substance while on the job. Unfortunately, knowing and doing something about it don't always go together.

     In theory, every EMS agency should have an exposure control plan, says Jeff Lindsey, PhD, CFO, EMT-P, chief of Estero (FL) Fire Rescue. "Some states require it and others don't, but everyone uses OSHA's Bloodborne Pathogens Standard as a guideline, and an exposure control plan is part of that standard," says Lindsey, medical writer for the American Academy of Orthopaedic Surgeons' Bloodborne Pathogens, Fifth Edition. "Unless things have changed, one of the items most agencies get hit on during an OSHA review is their failure to have an exposure control plan. Although I don't have any statistical evidence to prove it, I think that many agencies are not actually following their plan if they do have one, and there are still agencies looking to implement a plan for the first time."

     The biggest consequence for not having a plan is jeopardizing personnel, says Lindsey. "Hopefully nothing will ever occur, but we can't depend on that, so we need to make sure we're prepared by having a plan in place and training employees so they're familiar with it and know what to do if there's an exposure," he says. "These exposures typically don't occur during the day when the chief or EMS director is around. It's more likely to happen at 3 a.m. when you're on your own and wondering what to do next. That's not the time to try to figure things out."

     For those who are new to the concept, what is an exposure control plan? According to the above-mentioned publication, "an exposure control plan exists as a guideline for employees to know what to do when an exposure occurs." To put it simply, says Lindsey, it means that even before an exposure occurs, there is a plan in place to say what you will do to keep your crews safe, as well as what to do if there is an exposure and the test comes back positive. In most cases, he says, it's up to the infection control officer, or other designated officer, to identify employees who should receive training, protective equipment, vaccination and other protections of the OSHA standard. The plan should be reviewed annually and updated to reflect changes in procedures that could lead to occupational exposure to blood or other potentially infectious materials. According to OSHA, every employer needs to review job descriptions to determine which employees could be exposed to blood or other materials on the job without regard to the use of personal protective equipment. A copy of the plan must be made available to an employee within 15 working days of his/her request.

     If you are an agency that hasn't gotten around to developing a plan, there are templates available, says Lindsey. "There's no boilerplate plan that you can use as your own, but you can use the templates as a guideline for how to put your plan together. If you look up the OSHA standard, it will tell you what should be included. Don't wait any longer. If you don't have a plan, start making one today. Once you put the plan in place, don't let it gather dust. Train on it and keep it updated."

     For more on exposure control, refer to Bloodborne Pathogens, Fifth Edition, compiled by AAOS and the Emergency Care and Safety Institute (www.ECSInstitute.org) and published by Jones and Bartlett (info@jbpub.com).