An exposure control plan is the written plan OSHA requires from every dental office with employees exposed to blood or saliva. It must list which jobs and tasks involve exposure, how the office prevents it, and what happens after an exposure incident. Review and update it at least once a year.
Download the free exposure control plan template below. It has every element of 29 CFR 1910.1030(c) as fill-in sections, with dental examples.
What's in the free template
The PDF prints on 4 letter pages:
- Plan details and exposure determination. Office, plan owner, review date, where the plan is kept, and the jobs and tasks with exposure.
- Methods of compliance. Engineering and work practice controls, the yearly safer device review, the record of staff input, and PPE by task.
- Housekeeping, waste and vaccination. Cleaning schedule, regulated waste and sharps, hepatitis B vaccination, and the post-exposure steps with phone numbers.
- Labels, training, records and review. Biohazard labels, training, record retention, incident reviews and a yearly sign-off table.
Open the printable version or use the download button.
Who needs an exposure control plan
Under 29 CFR 1910.1030(c)(1), every employer with an employee who has occupational exposure must have a written exposure control plan "designed to eliminate or minimize employee exposure." In a dental office, saliva in dental procedures counts as potentially infectious material, so any office with a hygienist or assistant needs one.
What an exposure control plan must include
The standard sets the minimum content.
The exposure determination (paragraph (c)(2)), made without regard to the PPE people wear:
- job classifications in which all employees have occupational exposure,
- job classifications in which some employees have occupational exposure, and
- the tasks and procedures in which exposure occurs.
The schedule and method of implementation for the rest of the standard:
- methods of compliance: universal precautions, engineering and work practice controls, PPE, housekeeping and regulated waste,
- hepatitis B vaccination and post-exposure evaluation and follow-up,
- communication of hazards: labels and training, and
- recordkeeping.
The procedure for evaluating the circumstances of exposure incidents, so you can see what failed and fix it.
The plan also has to meet four more rules:
| Rule | What it means for your office |
|---|---|
| Accessible to employees, (c)(1)(iii) | Keep it where every employee can read it, and give a copy on request |
| Reviewed at least annually, (c)(1)(iv) | Update it yearly and whenever tasks, procedures or positions change, and reflect new technology that reduces exposure |
| Safer devices documented, (c)(1)(iv)(B) | Record each year which commercially available safer medical devices you considered and used |
| Staff input, (c)(1)(v) | Ask non-managerial staff who do direct patient care for input on choosing controls, and record it in the plan |
OSHA can also ask to examine and copy the plan, (c)(1)(vi).
How to fill in the template
- Write the office name, the person responsible for the plan and today's date. Note where the plan will be kept.
- List every job title. Put each in "all employees exposed" or "some employees exposed". Dentists, hygienists, assistants and sterilization staff usually go in the first list. Front desk staff who also clean operatories go in the second.
- List the tasks with exposure: for example injections, scaling, extractions, handling and cleaning instruments, turning over operatories, and handling sharps and waste.
- For each task, write the controls you use and who checks them.
- Review safer devices on the market, such as safety syringes or scalpels. Write what you considered and what you chose, or why not.
- Ask the hygienists and assistants for their input on those devices and controls. Record who you asked, how, and what came of it.
- Fill in PPE by task and where it's stored, your cleaning schedule, your waste hauler, and when sharps containers are replaced.
- Add the clinic for hepatitis B vaccines and the clinic for post-exposure evaluations, with phone numbers and after-hours options.
- Sign the yearly review table. Then train staff on the plan and show them where it is.
Dental examples of controls
These are common examples, not a required list. Your plan should name what your office actually uses.
- Engineering controls: sharps containers in each operatory, needle recapping devices, safety syringes and scalpels, instrument cassettes that limit hand contact during cleaning, ultrasonic cleaners or instrument washers.
- Work practice controls: no bending, recapping or removing contaminated needles except with a mechanical device or a one-handed technique, as 1910.1030(d)(2)(vii) requires; hand washing after removing gloves; no eating or drinking in treatment and sterilization areas.
- PPE: gloves, masks, eye protection with side shields or face shields, and gowns or clinic jackets, provided at no cost. Disposable gloves are never washed for reuse. Heavy utility gloves for instrument cleaning can be decontaminated and reused while they're intact.
What to do after an exposure incident
An exposure incident is a needlestick or cut, or blood or saliva in the eyes, mouth, other mucous membranes or broken skin. Under 1910.1030(f)(3), after an employee reports one, the office must make a confidential medical evaluation and follow-up available immediately, at no cost to the employee. It includes at least:
- documentation of the route of exposure and how it happened,
- identification and documentation of the source individual, unless that is infeasible or prohibited by state or local law,
- collection and testing of the employee's blood for HBV and HIV status, with their consent,
- post-exposure prophylaxis when medically indicated, as the U.S. Public Health Service recommends,
- counseling, and
- evaluation of reported illnesses.
The office gives the evaluating healthcare professional a copy of the standard, a description of the employee's duties, the exposure details, the source individual's test results if available, and relevant medical records. The employee gets a copy of the professional's written opinion within 15 days of the completed evaluation. The template has a section for the names and phone numbers so nobody has to look them up after an injury.
Records the plan should cover
- Training records: 3 years from the date of training. See OSHA training for dental offices.
- Employee medical records, including hepatitis B vaccination status and any hepatitis B declination form: duration of employment plus 30 years, kept confidential.
- Sharps injury log: federal OSHA only requires one from employers who must keep the OSHA 300 injury log. Offices of dentists are on OSHA's list of partially exempt industries, so most don't. California is different (below).
California and other state plans
States with their own OSHA-approved plans can add rules. California's bloodborne pathogens standard, 8 CCR 5193, requires the plan to include more than the federal one, for example:
- a procedure for gathering the information for a Sharps Injury Log, which every covered employer must keep, record each incident in within 14 working days, and keep for 5 years,
- a procedure for identifying and selecting engineering controls, and
- the active involvement of employees in reviewing and updating the plan.
If your office is in a state plan state, check its rule before you finalize the plan.
Keep it current with the rest of your yearly work
The plan review is due every year, along with staff training and your sterilizer records. The dental OSHA compliance checklist lists everything due, and the autoclave log sheet covers sterilization monitoring. ComplyDay handles OSHA and HIPAA training for dental offices and writes this plan for you.