Unless your facility is brand new, you should already have a bloodborne pathogen exposure control plan in place. But a good exposure control plan is never really "final," and should be considered a work in progress.

When you update your plan, it needs to reflect what is actually going on at your facility throughout the year. If, for example, a staff member is injured while disposing of a device, you shouldn't treat it as an isolated incident-you may need to revise your plan to include standards for emptying disposal units more frequently to ensure that the incident does not reoccur.

Similarly, evaluating safety devices must be an ongoing process. OSHA requires your facility to have safety devices in place in all situations where a staff person might become infected by a contaminated sharp. Your exposure control plan should include a summary of these devices and a mechanism for evaluating exposure incidents (such as needlestick injuries) to determine if changes need to be made in your procedures or types of devices being used.

This article will provide step-by-step plan of how to bring your exposure control plan up-to-date. The information was adapted from the compliance checklists and FAQ that the Premier Safety Institute provides on its public access website www.premierinc.com/safety.

1. Form a team.
Everyone in your facility should be involved in noting trends and evaluating safety devices. To make the changes "official," however, it's best to have the team of people that developed the original plan-a mixture of administrators and frontline personnel-coordinate the updates to the plan. Depending upon your device evaluation methods, you may want to add additional personnel, such as those staff who have most extensively worked with new equipment, to the process.