Exposure Control Plan for Restoration Companies
One of the most important safety documents a restoration company must develop and maintain is an Exposure Control Plan (ECP). This plan is not only essential for protecting workers from occupational hazards, especially bloodborne pathogens and infectious materials, but it is also required under the U.S. Occupational Safety and Health Administration (OSHA) federal regulations.
What is An Exposure Control Plan?
An ECP is a written document that outlines how a company will eliminate or minimize employee exposure to hazardous biological materials such as blood, bodily fluids, and other potentially infectious materials (OPIM). These risks are especially relevant in trauma scene cleaning, Category 2-3 water damage restoration sites, mold remediation, and any job site where microbial contamination may be present in the form of viruses, bacteria, and fungi.
Does My Company Need to Have an ECP?
YES. In the United States, the primary OSHA standard governing Exposure Control Plans is 29 CFR 1910.1030, commonly referred to as the Bloodborne Pathogens Standard. OSHA requires that any employer with employees who may “reasonably anticipate occupational exposure to blood or OPIM” must have a written ECP in place. This plan must be reviewed and updated at least annually and whenever changes in tasks, procedures, or job classifications occur that affect workplace exposure.
A compliant Exposure Control Plan typically includes several key components:
- Exposure Determination and Risk Assessment
Identifies which job roles and tasks involve potential exposure to bloodborne pathogens such as viruses, bacteria, and fungi, and other potentially infectious materials. - Exposure Prevention Methods
Describes standard precautions, work practice controls, engineering controls, personal protective equipment (PPE), hand hygiene, decontamination, and disposal procedures. - Training and Medical Provisions
Includes employee training, hepatitis B vaccination programs, and procedures for post-exposure evaluation and follow-up. - Documentation and Recordkeeping
Defines responsibilities for maintaining records, updating the plan, and documenting training, incidents, and vaccination status.
Creating an ECP
Developing and creating a company-specific Exposure Control Plan begins with evaluating job duties and identifying all job positions or tasks where exposure to blood, body fluids, OPIM, or other infectious disease could occur. Involve supervisors and technicians in the assessment to ensure all exposure risks are identified. After the potential exposure risks are determined, the plan should document the specific safety controls and procedures your company will use such as the proper use of containment, air filtration, and personal protective equipment (PPE).
ECP Development Resources
To make things easy, there are many resources by supportive government agencies and organizations that can use to develop a company ECP. Below are several resources from OSHA, the US Center for Disease Control and Prevention (CDC) and the National Institute for Occupational Safety and Health (NIOSH) to guide the plan development:
- OSHA https://www.osha.gov/bloodborne-pathogens
- NIOSH https://www.cdc.gov/niosh/topics/bbp/
- OSHA Sample Template https://www.osha.gov/sites/default/files/publications/osha3186.pdf
- Restoration Industry Association (RIA) https://www.restorationindustry.org/
- American Bio Recovery Association (ABRA) https://www.americanbiorecovery.org/
What to do With Your Developed ECP
Once your Exposure Control Plan is developed, ensure that all employees receive training on its contents and implementation. Training should occur at the time of initial assignment and annually thereafter. Supervisors should monitor compliance, conduct routine safety audits, and update the plan as needed.
Your OSHA compliant Exposure Control Plan (ECP) must be easily accessible to all employees at all times during their work shift.
A printed copy must be available at each work location where exposure could occur. For cleaning and restoration companies this might include an employee accessible area, office, warehouse, shop, alternate off-site work locations, and/or in field vehicles (if applicable).
In short: employees must know what the ECP binder looks like, where to find it, and supervisors must ensure it’s available to any employee at any time.
Need More Help?
Developing a thorough and effective Exposure Control Plan is an essential investment in the safety, compliance, and long-term success of your cleaning and restoration business. A well-designed ECP helps protect your employees, ensures regulatory compliance, and reduces potential liability. Click below to download a simple step-by-step PDF checklist for creating your company’s Exposure Control Plan.
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