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Written Programs & Records
- ✓ Exposure Control Plan (ECP): Each employer having an employee(s) with occupational exposure to blood or OPIM shall establish an ECP; review and update at least annually. 29 CFR 1910.1030(c)(1)
- ✓ Training Records: Keep records of initial and annual BBP training. 1910.1030(g)
- ✓ Medical Records: Maintain confidential hepatitis B vaccination status and exposure incident records for employment duration + 30 years. 1910.1020(d)
Protection Against Occupational Exposure
- ✓ Hepatitis B Vaccination: Offer the series at no cost to at-risk employees; document vaccination or declination. 1910.1030(f)
- ✓ PPE: Provide appropriate personal protective equipment at no cost; ensure correct use. 1910.1030(d)(3)
- ✓ Engineering & Work Practice Controls: Use these to eliminate or minimize employee exposure to blood and OPIM; when occupational exposure remains, use PPE.
1910.1030(d)(2)
Training & Communication
- ✓ Training Program: Provide bloodborne pathogens training at the time of initial assignment to tasks involving occupational exposure, when changes affect exposure, and at least 12 months after initial training; BBP training must be interactive and studio-specific. 1910.1030(g)(2)
- ✓ Accessible Resources: Ensure employees can access your Exposure Control Plan and OSHA's Bloodborne Pathogens Standard. 1910.1030(c)(1)(iii)
Communication of Hazards
- ✓ Labels and signs: Label sharps containers, contaminated equipment, and regulated waste; post work area signs.1910.1030(g)(1)
- ✓ Safety Data Sheets: Maintain copies of the required Safety Data Sheets for each hazardous chemical.
1901.1200 (g)
- ✓ Regulated Waste Disposal: Use containers that are closable, labeled, puncture-resistant, and leak-proof; arrange for compliant disposal. 1910.1030(d)(4)(iii)
Pro tip: Keep all documents (ECP, training logs, vaccination records, exposure incident reports, etc.) in one binder or digital folder for quick access during unannounced inspections.
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