OSHA Bloodborne Pathogens Exposure Control Plan Annual Review

Use it for any workplace with employees who may have occupational exposure to blood or other potentially infectious materials. It is especially useful for clinics, dental offices, labs, EMS, housekeeping, and maintenance teams that handle contaminated sharps or cleanup tasks. The template is designed for the person responsible for the exposure control plan, safety, or compliance review.

This template is built for the annual review cycle required for bloodborne pathogens programs, and it also works when a plan must be updated sooner because tasks, equipment, or exposure risks change. If a new department, procedure, or control is introduced, the review should capture that change rather than waiting for the next annual date. Many teams use it as both the annual audit and the change-control record.

It checks whether the exposure determination is still accurate, whether current tasks and job classifications are covered, and whether engineering controls, work practices, PPE, housekeeping, and waste procedures are current. It also verifies annual training, employee notification of updates, sharps injury logging where required, and closure of prior corrective actions. In short, it confirms that the written plan matches day-to-day practice.

No. This is an annual review and audit template, not the plan itself. It helps you evaluate the existing plan, document changes, and attach revision notes or follow-up actions. Most organizations keep it with the plan as evidence that the annual review was completed.

Common misses include outdated job classifications, missing new tasks that create exposure, training records without a date or attendee roster, and PPE requirements that no longer match the actual procedure. Teams also overlook sharps injury log review, incomplete post-exposure steps, or corrective actions from the prior year that were never closed. This template is designed to surface those gaps before they become a compliance finding.

Add the specific departments, procedures, and job titles that actually have occupational exposure at your site, rather than using a generic list. You can also tailor the controls section for your sharps containers, disinfectants, laundry handling, waste pickup process, and post-exposure reporting workflow. If your site has multiple locations, duplicate the review by location so each exposure profile is documented separately.

Attach the revised plan summary, training roster, sharps injury log review, incident investigations, and any corrective action tracker. If your organization uses digital records, link the training module completion report, vaccination offer documentation, and post-exposure evaluation forms. The goal is to make the annual review traceable without hunting through separate systems.

An ad-hoc check may catch a visible issue, but it often misses whether the plan itself is current, whether all exposed roles are included, and whether required records are complete. This template forces a structured review of exposure determination, controls, training, incidents, and follow-up actions. That makes it easier to prove the program is being maintained, not just informally monitored.