US · Expiry & renewal tracking
Review your Exposure Control Plan at least once a year
An employer whose employees have occupational exposure to blood must keep a written Exposure Control Plan and review and update it at least annually, and whenever tasks, procedures or exposed positions change (29 CFR 1910.1030(c)(1)(iv)). Each review must document the consideration of safer medical devices.
OSHA's Bloodborne Pathogens standard, 29 CFR 1910.1030, applies to all occupational exposure to blood or other potentially infectious materials (1910.1030(a)). Each employer with one or more employees with occupational exposure must establish a written Exposure Control Plan designed to eliminate or minimize employee exposure (1910.1030(c)(1)(i)).
The plan must contain at least the exposure determination, the schedule and method of implementation for the standard's methods of compliance, hepatitis B vaccination and post-exposure follow-up, communication of hazards, and recordkeeping, and the procedure for evaluating the circumstances around exposure incidents (1910.1030(c)(1)(ii)). A copy must be accessible to employees (1910.1030(c)(1)(iii)).
The plan must be reviewed and updated at least annually, and whenever necessary to reflect new or modified tasks and procedures that affect occupational exposure, or new or revised employee positions with occupational exposure. Each review must also reflect changes in technology that eliminate or reduce exposure, and document annually the consideration and implementation of appropriate commercially available and effective safer medical devices (1910.1030(c)(1)(iv)).
At a glance
| Rule | 29 CFR 1910.1030(c)(1), OSHA |
|---|---|
| Who needs a plan | Employers with employees who have occupational exposure |
| Review and update | At least annually, and whenever tasks, procedures or exposed positions change |
| Each review covers | New technology and safer medical devices, documented annually |
| Employee input | From non-managerial direct patient care staff, documented in the plan |
| Access | Accessible to employees; available on request to the Assistant Secretary and the Director |
Occupational exposure means reasonably anticipated skin, eye, mucous membrane or parenteral contact with blood or other potentially infectious materials that may result from an employee's duties (1910.1030(b)).
Who is responsible?
The employer. It must also ask non-managerial employees responsible for direct patient care, who are potentially exposed to sharps injuries, for input on engineering and work practice controls, and document this in the plan (1910.1030(c)(1)(v)).
Training and the sharps injury log run alongside the plan
Employees with occupational exposure need annual training within one year of their previous training (1910.1030(g)(2)(iv)); track it as a separate document. Employers that must keep an injury and illness log under 29 CFR part 1904 must also keep a sharps injury log, recording at least the type and brand of device, the department or work area, and how the incident happened (1910.1030(h)(5)).
Tracking it with ExpirySuite
- Add the Exposure Control Plan for each site and record the date of its next review: one year after the last review.
- Reminders arrive 60, 30, 14, 7 and 1 day before the due date and on the due date itself.
- Assign a responsible person (for example your safety or infection control lead) so the right person gets the reminder.
- When tasks, procedures or exposed positions change, review the plan then and set the next date one year later.
- If a date passes, managers get overdue reminders 3, 7 and 14 days later.
- Upload the reviewed plan, or ask a colleague to send it through a secure upload link, valid for 14 days; no account is needed.
Frequently asked questions
- How often must the Exposure Control Plan be reviewed?
- At least annually, and whenever necessary to reflect new or modified tasks and procedures or new or revised positions with occupational exposure (29 CFR 1910.1030(c)(1)(iv)).
- What must the annual review document?
- Changes in technology that eliminate or reduce exposure, and the consideration and implementation of appropriate commercially available and effective safer medical devices (1910.1030(c)(1)(iv)(A) and (B)).
- Who must be asked for input?
- Non-managerial employees responsible for direct patient care who are potentially exposed to injuries from contaminated sharps. The request must be documented in the plan (1910.1030(c)(1)(v)).
- Is the annual training the same deadline?
- No. Training is due within one year of each employee's previous training (1910.1030(g)(2)(iv)), so it is tracked per employee.
Sources
Last checked: Oct 1, 2026 · This page summarises official sources for general information and is not legal advice. Check the linked sources for current rules and fees.
Made for exposure control plan annual review (OSHA) (US)
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Reminders on time
Email alerts at 60, 30, 14, 7 and 1 day before each exposure control plan annual review (OSHA) (US) expires, plus overdue escalation to managers.
Assign an owner
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