Exposure control plan: Meeting the standard
With the revised bloodborne pathogens standard, the Occupational Safety and Health Administration (OSHA) requires that exposure control plans "account for innovations in procedure and technological developments that reduce the risk of exposure incidents." What exactly does that mean? Here is some of the explanation OSHA offers:
• Employers must implement the safer medical devices that are appropriate, commercially available, and effective. No one medical device is appropriate in all circumstances of use.
• For purposes of this standard, an "appropriate" safer medical device includes only devices whose use, based on reasonable judgment in individual cases, will not jeopardize patient or employee safety or be medically contraindicated.
• Although new devices are being continually introduced, OSHA recognizes that a safer device may not be available for every situation. If a safer device is not available in the marketplace, the employer is not required to develop any such device.
• Furthermore, the revised requirements are limited to the safer medical devices that are considered to be "effective." For purposes of this standard, an "effective" safer medical device is a device that, based on reasonable judgment, will make an exposure incident involving a contaminated sharp less likely to occur in the application in which it is used.
The exposure control plan also should document the solicitation of input from "nonmanagerial employees responsible for direct patient care who are potentially exposed to injuries from contaminated sharps," OSHA notes. "No specific procedures for obtaining employee input are prescribed. This provides the employer with flexibility to solicit employee input in any manner appropriate to the circumstances of the workplace."
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