Environmental, Health and Safety Services

BBP Exposure Control Plan Responsibilities


Each department that has employees at risk of occupational exposure to bloodborne pathogens has the following compliance responsibilities and functions.

  • Assigning accountability to implementation coordinators and/or supervisory personnel. Supervisors of employees with occupational exposure to blood and body fluids should have this responsibility listed in their P-112's, the Personnel Performance Plan and Evaluation forms.
  • Circulating Exposure Control Plans after receiving from EHSS.
  • Funding and Providing Personal Protective Equipment, as needed.
  • Notifying EHSS before establishing research endeavors involving human pathogenic agents
  • Notifying EHSS of employee turnover. Contacting EHSS to enroll new hires in the program, within 2 days of the date of hire.
  • Ensuring that new hires do not engage in activities with potential exposure until they have had the introductory training.
  • Encouraging full participation of all "at risk" employees, to include:
    • Allowing attendance at training sessions, during normal work hours
    • Requiring 'at risk' employees to review the Exposure Control Plan
    • Requiring employees to follow safe work practices
  • The following departments have been identified by EHSS as having "at risk" employees:
    • Athletics
    • Biochemistry
    • CEC Housekeeping
    • Chemistry (Peters Center)
    • College of Veterinary Medicine
    • Electrical and Computer Science Engineering
    • Environmental, Health and Safety Services
    • Family & Child Development
    • Human Nutrition, Foods, and Exercise
    • Lab Animal Resources
    • Mechanical Engineering
    • Police
    • Physical Plant Building Services
    • Rescue Squad
    • Residential Programs Housekeeping
    • Student Health Services

      Note, however, that the above list is not exhaustive. If 'at risk' employees are identified in your department that are not already enrolled in the Bloodborne Pathogens Program, please contact EHSS immediately at 231-4034 or sowen@vt.edu.

Implementation Coordinators

Each departments with 'at risk' employees should appoint an "Implementation Coordinator". This individual will be responsible for ensuring that the Exposure Control Plan is complete and accessible. Completion of the ECP involves inserting department-specific policies and procedures where indicated. Accessibility means that all at-risk employees shall be informed of the location of the departmental ECP and shall be encouraged to read its contents.

In the absence on an appointed Implementation Coordinator, these duties will fall to supervisors of "at risk" employees.

Summary of responsibilities:

  • Receiving the university ECP
  • Completing department-specific sections of the ECP
  • Storing the ECP in accessible location
  • Communicating the ECP location to all at-risk employees
  • Reviewing and updating department-specific sections annually, or earlier if work processes change.
  • Conducting annual review sessions with employees


Virginia Tech employees who supervise "at risk" employees have certain responsibilities under this plan. They are to act as implementation coordinators in departments where no one has been assigned to that role. Also, they need to ensure that newly hired employees receive the introductory training and must allow employees to receive the vaccinations during normal work hours. Supervisors also need to secure personal protective equipment, such as gloves, for employees. Also, supervisors need to be familiar with reporting requirements in the event of an exposure incident.

In summary, supervisors:

  • Call EHSS when new employees are hired (within 2 days)
  • Allow employees to receive vaccinations during normal work hours
  • Provide gloves and other protective equipment to employees
  • Report exposure incidents to EHSS and assist with report paperwork

At-risk Employees

Every employee that can reasonably anticipate exposure to blood or other potentially infectious materials during their normal job duties has certain compliance responsibilities.

Responsibilities under this plan:

  • Attending training sessions
  • Complying with procedures outlined in this plan
  • Adhering to Universal Precautions
  • Reporting exposure incidents to supervisors and EHSS


EHSS is responsible for coordinating the following program elements.

  • Identification of "at risk" employees
  • Conducting introductory training classes
  • Conducting annual refresher classes for supervisors
  • Maintaining records of training and vaccination for all program participants.
  • Funding the Hepatitis B vaccinations for at risk employees
  • Providing post-exposure follow-up, to include recordkeeping and infection prophylactic services
  • Creating, distributing, and revising (as regulations/recommendations change) the university-wide Exposure Control Plan
  • Operating a Regulated Medical Waste disposal program, in compliance with state Department of Environmental Quality regulations.
  • Oversight of departmental compliance.


Contractors must follow procedures outlined in Virginia Tech's Contractor Safety Program.