An Exposure Control Plan, often referred to as an “ECP,” is a requirement for all businesses who have workers with occupational exposure. OSHA’s Bloodborne Pathogens Standard (29 CFR 1910.1030) defines occupational exposure as “reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee’s duties.” This standard also requires an ECP to be reviewed and updated, at a minimum, annually.
“1910.1030(c)(1)(iv)
The Exposure Control Plan shall be reviewed and updated at least annually…”
Like annual Bloodborne Pathogens Standard training, Exposure Control Plans are not only a requirement for body art facilities like body piercing studios and tattoo shops, they’re a very important element to a facility’s communications program. Universal Precautions is vital to both worker and public safety and the ECP contains a facility’s policies and protocols that all affected workers may need to review so they may work “universally” with their colleagues. Not doing so creates unnecessary risk.
Paragraph C of OSHA’s Bloodborne Pathogens Standard outlines the requirements for a piercing studio’s (and tattoo shop’s) ECP. Any business owner or manager can easily access the standard and review (or create) their facility’s plan. Now that it’s the beginning of the year, we’ve introduced our updated Exposure Control Plans to our body piercing staff at New Flower Studio in Long Beach and our colleagues at Black Raven Tattoo in Torrance. We encourage other body art facilities to do the same. The Association of Professional Piercers (APP) offers an online presentation designed specifically for this purpose. We wish each of you a Happy New Year and we hope you keep safety a priority in body art.
