What Your Work Exposure Control Plan Is, and How to Review It As a Team Annually

by Gracie Hogue, BM

Your Work Exposure Control Plan is essentially one of the most important parts of your OSHA Manual, and it needs to be reviewed by everyone at the practice annually. Consider taking time to review the Work Exposure Control Plan as a team when you have your annual training. 

Here are a few frequently asked questions about the Work Exposure Control Plan:

What is our Work Exposure Control Plan?

This policy basically encompasses the standard operating procedures of how your practice functions in such a way as to minimize or even eliminate exposure to bloodborne pathogens and other potentially infectious materials.

What do we do with the WECP?

Any time there is a change or modification in how the practice runs, or if a new procedure is introduced or a procedure changed, the WECP needs to be reviewed as a team. Whenever the practice hires a new employee, the new hire needs to review the WECP along with having OSHA training before they hit the floor.

How do we review the WECP effectively as a team?

The practice’s Safety Coordinator can head up a staff meeting and highlight the areas in the WECP that are part of the everyday lives of the team, such as:

• Engineering Controls and Work Practice Controls – It’s important to explore the differences between correctly using a device that is used to prevent injury or exposure (engineering controls), and the correct way to execute a task that reduces the likelihood of exposure (work practice controls). There are helpful bullet points and tips in your OSHA Manual’s WECP that you can review together on this topic.
• How to handle sharps to meet OSHA’s safety standards – Review together OSHA’s standards of how sharps are handled, where sharps containers are supposed to be mounted on walls, and what the standard procedure would be if there were a sharps exposure incident. This would also be a great time to talk about the instruments you’re using in the practice, and whether or not you may need certain devices to be replaced with another brand or model. You are required by OSHA to evaluate a safer device once a year, so maybe see if there are any devices that may be easier, more comfortable, and safer to use the ones that you’re currently using. 
• Needle Recapping – Is everyone using the one-handed scoop technique or using a safer medical device to recap needles?
• Instrument Transport – Is everyone using utility gloves and a leak-proof container with solid sides and bottom with a biohazard label on it when transporting contaminated instruments?

This list could go on with all the different facets of compliance that the WECP covers: Reusable contaminated sharps, sterilization, hand hygiene guidelines, housekeeping and cleaning schedules, surface cleaning, waste management, and more. 

In all, having a solid foundation of understanding of the WECP gives the team a unified perspective and helps the practice run as an effective unit against infection.