Exposure Control Plan

Penn's Bloodborne Pathogens Exposure Control Plan (ECP)

All Penn faculty, staff and students in clinical, research, and non-research areas who may reasonably anticipate occupational exposure to human bloodborne pathogens (BBP) or other potentially infectious materials (OPIM) must comply with the OSHA Bloodborne Pathogen Standard.

All research personnel who have the potential to be exposed to BBP or human source material, including primary and established cell lines, blood products, body fluids, and tissue must have a lab-specific ECP on file with EHRS.

Non-research personnel may include, but are not limited to individuals working within: Department of Recreation, Facilities & Real Estate Services, Housekeeping staff, Intercollegiate Athletics, Penn Children’s Center, and University of Pennsylvania Police Department, Clinical Research, and Dental Clinics.

In addition to annual training, each group must have on file a site-specific, BBP, Exposure Control Plan (ECP) that is available on demand.  The University of Pennsylvania Bloodborne Pathogen Exposure Control Plan is provided as a customizable template to assist you in creating this site-specific compliance document. Your ECP must be updated annually, reviewed and signed by all who are listed in the ECP.

Make sure that the signature page (page 2) and Appendix C (pages 20-22) have been completed. The signature page must contain the Penn ID numbers, signatures, AND the review date for each individual listed on the page. For resubmissions, if there are no changes, submit last year's plan with a current date and an updated signature page. Follow these instructions for submission:

• Non-research personnel: Please email a PDF of your completed ECP to ehrs@ehrs.upenn.edu.
• Research labs: PIs and LSCs can upload ECPs directly to the lab's "Documents" section in BioRAFT. Upload the document as a "general" file type using the suggested naming convention "Lab Name_ECP_Date of Signatures." The document will be available to all personnel listed in the "Lab Members" section of the lab's profile.

For guidance filling out Appendix C of the Exposure Control Plan, please refer to Penn's Biosafety Manual or contact a biosafety officer: BIOSAFETY@LISTS.UPENN.EDU