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RISK MANAGEMENT

Model Policy: OSHA bloodborne pathogens exposure control

Why you need this policy:

All medical practices need infection control policies and procedures. And with regard to one particular form of infection—bloodborne pathogens that get into the bloodstream via puncture or piercing by contaminated needles or other medical sharps—QA measures must include a specific exposure control policy that meets the requirements of the federal workplace safety law called OSHA (the Occupational Safety and Health Act)—specifically, the regulation or “standard” dealing with bloodborne pathogens.

How this policy helps you:

The Model Policy below comes right from OSHA itself, i.e., the agency that enforces the bloodborne pathogens standard. We’ve altered it only slightly and in a nonsubstantive way to make it work for medical practices.

How to use this policy:

Because it comes from the government agency, you don’t want to make massive revisions to this Model Policy. However, you will have to fill in the blanks by listing information that applies to your practice, e.g., who at the practice is in charge of the exposure control policy, selecting needleless systems, etc. Just look for the italicized language in the Model Policy to identify the blanks that need filling.

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