Exposure control plan for NEMT crews: fill-in sections for blood and body fluid cleanup

This is a written exposure control plan sized for a NEMT company, where the people at risk are drivers and attendants who give first aid, clean blood out of a van, or find a rider’s used needle on the floor. The bloodborne pathogens standard (29 CFR 1910.1030) calls for the plan as soon as any employee has that kind of exposure. Who the standard covers, the first aid exception for the vaccine, and the injury log rules are explained in OSHA for NEMT companies. This page is the document itself, ready to fill in.

How to use this template

OSHA publishes its own model plan (OSHA 3186), with examples drawn from health care settings such as phlebotomists in a clinical lab. It says the model contains every element the standard requires and that employers should tailor it without dropping any of them. The version below keeps every element and swaps the clinic details for vans, spill kits, and drivers working away from running water.

1. Fill in every bracket with a real name. “Management” is not a person a driver can call at 9 p.m.
2. Ignore gloves when you decide who is exposed. The standard says the exposure determination is made without regard to protective equipment. A driver who always gloves up still counts.
3. Point to your checklists instead of copying them. The vehicle cleaning checklist already holds the cleaning steps and products, and the kit contents are in the safety equipment checklist. Name them in sections 3 and 5 so the plan and the checklists never disagree.
4. Make it reachable on every shift. OSHA’s directive accepts a computer-only plan when staff know how to pull it up, and a paper copy is due within 15 working days of an employee’s request. A copy in the glovebox binder and one at dispatch covers both.
5. Look it over yearly, plus any time jobs or tasks change. Record each review in section 10. If any staff give hands-on patient care and could be stuck by a contaminated sharp, the standard also requires asking those frontline employees for input on controls and writing down that you asked.
6. Check whether your state runs its own program. This plan follows the federal text. Where a state plan covers private employers, the state’s rule governs. California’s section 5193, for one, adds a required procedure for involving employees in reviewing and updating the plan. The OSHA guide lists which states have their own plan.

The template

[Company name] exposure control plan

Effective date: [date] | Last reviewed: [date] | Plan administrator: [name, phone]

1. Purpose and responsibilities

[Company name] uses this plan to eliminate or minimize employee contact with blood and other potentially infectious materials, as required by 29 CFR 1910.1030.

• Plan administrator: [name] keeps this plan, reviews it at least yearly, and updates it when tasks or jobs change.
• Supplies: [name] stocks gloves, masks, sharps containers, and red bags in every vehicle and at the office, in the sizes staff need.
• Medical follow-up: [name] arranges hepatitis B vaccinations and post-exposure visits and keeps the confidential medical records.
• Training: [name] runs bloodborne pathogens training and keeps the training records.

2. Who is exposed and when

Every employee in these jobs has occupational exposure:

Some employees in these jobs have exposure, only during the tasks listed:

3. Controls in every vehicle

• Hand cleaning without a sink. Vans have no running water, so each one carries [antiseptic hand cleanser and paper towels / antiseptic towelettes]. At the next stop with a sink, staff wash properly with soap, and they wash every time gloves come off.
• Needles riders leave behind. Never recap, bend, or break a used needle. It goes straight into the closable, puncture-resistant, leakproof, labeled sharps container kept [location in the vehicle], which stays upright and is swapped before it gets full.
• Broken glass. Sweep it into a dustpan with the kit’s brush, or lift it with tongs. Hands never touch it.
• Kit checks. The spill kit and protective equipment are checked [at each pre-shift inspection] against the [safety equipment checklist].

4. Protective equipment

• [Company name] provides, at no cost: [nitrile gloves in sizes S to XL, CPR pocket masks with one-way valves, face shields or goggles, disposable gowns or coveralls, (other)].
• Staff allergic to the usual gloves get [non-latex or powderless gloves] on request.
• Gloves are changed as soon as they are torn, punctured, or contaminated.
• Clothing that blood soaks through comes off as soon as feasible. Each vehicle carries [a spare coverall / a change of clothes kept by each driver]. OSHA’s directive gives, as an example of a violation, paramedics who cannot change out of blood-soaked clothing because the spare set sits at the ambulance’s home base and the ambulance stays out for long stretches.
• [Company name] cleans, launders, repairs, and replaces protective equipment at no cost. Staff do not take it home to wash.

5. Cleaning the van after blood or body fluids

• When: right after any spill, or at the first safe place to pull over. At the end of the shift, any surface that may have picked up blood since its last cleaning gets done again. The van takes no riders until it is cleaned.
• How: follow the [vehicle cleaning checklist], using [disinfectant product], left wet as long as its label says.
• Waste: bag anything soaked or caked with blood in a red or biohazard-labeled bag that closes and will not leak. Full bags go to [where, under your state’s medical waste rules].
• Laundry: blankets and seat covers are bagged at the van in [red or labeled] bags, never sorted or rinsed there, and wet loads go in leakproof bags. [Vendor or location] washes them.

6. Hepatitis B vaccine

• Every employee in section 2 is offered the vaccine series free. The offer comes once they finish training, and no later than the tenth working day after they start exposed work, unless they already completed the series, an antibody test shows immunity, or it is medically ruled out.
• No one has to take a screening test first to get the vaccine.
• Anyone who turns it down signs OSHA’s mandatory declination wording (Appendix A to 1910.1030), and the series stays available free if they change their mind.
• Vaccinations are given by [clinic name, address, phone].

7. After an exposure incident

An exposure incident is blood or other infectious material reaching the eyes, mouth, other mucous membranes, or broken skin, or entering through a needlestick, cut, or bite.

1. First aid right away. Soap and water on a stick or cut. Plain water on a splash to the skin, nose, or mouth. A full eye rinse with clean water, saline, or sterile eyewash.
2. Call [name] at [phone], any hour. Dispatch moves the remaining trips to another vehicle.
3. Go to [clinic or emergency room] the same shift. The visit, tests, and any preventive treatment are free to the employee.
4. [Name] sends the clinician a copy of the standard, a description of the employee’s duties, how and where the exposure happened, the source rider’s test results if available, and the employee’s vaccination records.
5. The source rider is named in the record when that is possible and state or local law allows it. [Name] asks for the rider’s consent to a blood test where the law requires consent, and writes down why when it cannot be obtained. Test results go to the employee and the clinician.
6. The employee receives the clinician’s written opinion within 15 days of the completed evaluation.
7. [Name] reviews the incident within [5] working days: the task, the protective equipment used, what failed, and the fix. The review and an incident report are filed together.
8. Sharps injury log. If [Company name] keeps an OSHA 300 log, each needlestick also goes on the sharps injury log, which records the device’s type and brand, the work area, and how the injury happened.

8. Training

• When: before an employee’s first task with exposure, a refresher no more than 12 months after the previous one, and whenever tasks change.
• Terms: free, during paid hours, in language and vocabulary the employee understands, with a trainer who can answer questions during the session. A video alone is not enough.
• Content: the 14 topics listed in paragraph (g)(2)(vii) of the standard, including where to find this plan, the kit in each vehicle, the spill steps in section 5, the vaccine, and the steps in section 7.
• Records: for each session, the date, the topics, who taught it and their qualifications, and who attended with their job titles. Keep them 3 years.

9. Records

• Medical record for each employee in section 2: name, hepatitis B vaccination dates or declination, results of any post-exposure evaluation, the clinician’s written opinion, and the information sent to the clinician. Kept confidential while the person works here and for 30 years after.
• Training records: 3 years from each session.
• Who may see them: employees may examine and copy their own training records. Medical records go only to the employee, or to a person the employee names in writing, unless the law requires otherwise.

10. Yearly review

Approval

Approved by [owner name, title] | Signature: __________ | Date: __________

Keeping the plan’s dates and supplies current

HealthRide can hold any credential that has an expiration date, so the yearly training in section 8 can sit on each driver’s record next to the license. Reminders arrive ahead of the expiration, and dispatch is warned before a driver with an expired credential is put on a trip. Keep vaccination records and exposure paperwork in the separate confidential medical file from section 9, not in dispatch software. Setup is on the fleet and credentials page.