Last Revised: July 01, 2022

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.

Please email a PDF of your completed ECP to Make sure that the signature page (page 2) and Appendix C (pages 20-22) have been completed. For resubmissions, if there are no changes, submit last year's plan with a current date and an updated signature page. For research labs, a copy of your ECP will be attached to the lab's BioRAFT profile to ensure that it is available to all lab members.

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