# Exposure Control Plan Template for NEMT Companies: Bloodborne Pathogens, Van Spills, and Hepatitis B

Canonical URL: https://nemtguide.com/templates/exposure-control-plan/ · Updated 2026-10-02

An exposure control plan template is a fill-in version of the written plan OSHA's bloodborne pathogens standard requires once any employee can reasonably be expected to contact blood at work. In a NEMT company that usually means drivers who give first aid and anyone who cleans blood out of a van. The plan names those jobs, your spill rules, the free hepatitis B vaccine, and the steps after an exposure.

- You need a written plan once any employee can be expected to contact blood at work, such as a driver who gives first aid or cleans up a spill.
- Decide which jobs have exposure as if nobody wore gloves. OSHA makes the call without counting protective equipment.
- Offer the hepatitis B vaccine free, after training and within 10 working days of first assignment, and have anyone who declines sign the Appendix A statement.
- After a needlestick, bite, or splash, the employee gets a free, confidential medical evaluation right away, and you give the clinic the facts in Part 7.
- Review the plan at least once a year with your drivers. Keep training records 3 years and medical records for the length of employment plus 30 years.

A rider cuts a hand on the lift, a dialysis access site starts to bleed, or a driver finds a used insulin needle under a seat. Once you expect your staff to deal with blood like this, OSHA's bloodborne pathogens standard asks for a written exposure control plan. This template is that plan, filled in for vans, drivers, and van cleanup, with the hepatitis B declination statement attached.

## How to use this template

1. **Check that the standard applies.** It covers your employees once any of them can reasonably be expected to contact blood on the job, such as a driver trained and expected to give first aid. The [OSHA guide for NEMT companies](https://nemtguide.com/guides/osha-for-nemt/) explains who is covered and the narrow first aid exception.
2. **Fill in Part 1** with the plan owner and the clinic that gives the vaccine and sees employees after an exposure. Call the clinic first to confirm it handles workplace blood exposures, and ask about after-hours care.
3. **Fill in Part 2 by job title, not by name.** Keep or cross out the sample rows and add your own.
4. **Set each rule in Part 3** and write the date it started. Use the [vehicle cleaning checklist](https://nemtguide.com/templates/nemt-vehicle-cleaning-checklist/) as your written cleaning schedule, and stock each van to the [first aid kit checklist](https://nemtguide.com/templates/nemt-first-aid-kit-checklist/).
5. **Train every covered employee before their first shift with exposure,** using Part 8, then offer the vaccine and record it in Part 4. Anyone who declines signs Part 5.
6. **Print Part 6 for every van** and the dispatch desk, so a driver knows what to do in the first ten minutes.
7. **Review the plan once a year** in Part 9, with drivers in the room, and any time you add a service, a job, or a new cleaning product.

Keep Parts 4, 5, and 7 confidential. They hold medical information, so store them apart from personnel files and show them only to the people the standard allows.

## The template

### Part 1: Plan details

| Field | Entry |
|---|---|
| Company name | |
| Effective date | |
| Last reviewed | |
| Plan owner, name and phone | |
| Backup when the plan owner is away | |
| Where staff can read the plan during a shift | |
| Clinic for hepatitis B vaccines and exposure evaluations: name, address, phone, hours | |
| Where to go after hours | |
| Number a driver calls right after an exposure | |
| Where confidential medical records are kept | |

### Part 2: Jobs with exposure

Decide each job as if nobody wore gloves or other protective equipment. Part-time, temporary, and per diem staff in these jobs are covered the same way.

| Job title | All or some in this job have exposure | Tasks with exposure |
|---|---|---|
| Driver trained and expected to give first aid | All | First aid to riders, cleaning blood or body fluid from the van, handling soiled straps, belts, or seat covers |
| Stretcher van assistant or attendant | All | Moving and positioning riders, first aid, changing soiled linens |
| Van cleaner or detailer | All | Spill cleanup, bagging and removing contaminated waste |
| Mechanic or lift technician | Some | Servicing seats, lifts, or securement straps that may be contaminated |
| Dispatcher or office staff who also drive | Some | The driving shifts above |
| | | |
| | | |

### Part 3: How we prevent exposure

Write the start date for each rule. Together these columns are the schedule and method the standard asks for.

| Control | How we do it | Start date |
|---|---|---|
| Universal precautions | Treat all blood, and any body fluid you cannot identify, as infectious | |
| Gloves | Disposable gloves in every van in each size staff need, plus non-latex gloves for anyone allergic. Never wash or reuse them. | |
| CPR barrier | A pocket mask with a one-way valve in every van | |
| Eye and face protection | Mask and goggles or a face shield for any task that could splash | |
| Hand cleaning | Antiseptic towelettes, or antiseptic hand cleaner with paper towels, in every van. Wash with soap and running water as soon as you can. | |
| Hands after gloves | Wash or clean hands right after taking gloves off | |
| No eating during cleanup | No eating, drinking, or lip balm during first aid or cleanup, or with soiled hands | |
| Spill cleanup | The van leaves service until the spill is cleaned and disinfected, by the steps in our cleaning checklist | |
| Disinfectant | An EPA List S product or an EPA-registered tuberculocidal disinfectant, used as the label directs, or household bleach diluted 1 part to 10 to 100 parts water | |
| End of shift | Disinfect any surface that may have been touched by blood since the last cleaning | |
| Broken glass | Never by hand. Use a brush and dustpan or tongs. | |
| Found needles | Never by hand. Use tongs and drop it in a closable, puncture-resistant, leakproof, labeled or red sharps container kept upright. | |
| Contaminated waste | Absorbent, towels, or gloves soaked or caked with blood go in a closable, leakproof red or labeled bag, closed before it leaves the van and disposed of under our state's medical waste rules | |
| Soiled linens and seat covers | Bagged in the van in a red or labeled bag and never rinsed there | |
| Protective gear | We supply, clean, repair, and dispose of it at no cost. No one takes soiled gear home to wash. | |
| Soaked clothing | Clothing soaked through with blood comes off as soon as possible and goes in a bag | |

### Part 4: Hepatitis B vaccine record (confidential)

Offer the vaccine after training and within 10 working days of first assignment to a job in Part 2.

| Employee and job title | First assigned | Trained on | Vaccine offered on | Accepted, declined, already vaccinated, immune, or medical reason | Dose dates |
|---|---|---|---|---|---|
| | | | | | |
| | | | | | |
| | | | | | |
| | | | | | |

### Part 5: Hepatitis B vaccine declination (confidential)

An employee who declines signs this statement, word for word, from Appendix A of 29 CFR 1910.1030:

> I understand that due to my occupational exposure to blood or other potentially infectious materials I may be at risk of acquiring hepatitis B virus (HBV) infection. I have been given the opportunity to be vaccinated with hepatitis B vaccine, at no charge to myself. However, I decline hepatitis B vaccination at this time. I understand that by declining this vaccine, I continue to be at risk of acquiring hepatitis B, a serious disease. If in the future I continue to have occupational exposure to blood or other potentially infectious materials and I want to be vaccinated with hepatitis B vaccine, I can receive the vaccination series at no charge to me.

| Employee name | Job title | Signature | Date |
|---|---|---|---|
| | | | |

### Part 6: After a needlestick, bite, cut, or splash

**What the driver does, in this order**

1. Wash a needlestick, cut, or bite with soap and water. Flush a splash to the nose, mouth, or skin with water. Rinse eyes with clean water or saline.
2. Pull over or stay parked, and call the number in Part 1 right away. Dispatch sends another driver for the rest of the route if needed.
3. Go to the clinic in Part 1 the same shift. The visit costs you nothing and stays confidential.
4. Write down the time, the trip number, what happened, and what touched what. The plan owner needs it for Part 7.

**What the company does**

1. Send the employee for a confidential medical evaluation at once, at no cost to them.
2. Name the rider as the source in Part 7, unless you cannot identify them or state or local law forbids it. The rider's blood is tested only with consent where the law requires it. If consent cannot be obtained, write that down.
3. Give the clinic a copy of the standard, the employee's duties as they relate to the incident, how the exposure happened, any test results for the rider, and the employee's vaccine records.
4. Get the clinician's written opinion and give the employee a copy within 15 days of the end of the evaluation.
5. Fill in Part 7, and change the plan if the review shows a gap.

### Part 7: Exposure incident review (confidential)

| Field | Entry |
|---|---|
| Date and time | |
| Employee and job title | |
| Trip number and place (van, rider's home, facility curb) | |
| What happened, step by step | |
| Route: needlestick, cut, bite, splash to eye, nose, or mouth, or contact with broken skin | |
| Object involved, with type and brand if it was a sharp | |
| Protective gear worn at the time | |
| Rules from Part 3 followed, and any not followed | |
| Employee's last bloodborne pathogens training date | |
| Rider identified as the source? If not, why not | |
| Clinic, and time the employee was seen | |
| Written opinion given to the employee on | |
| What we changed afterward | |
| Reviewed by, and date | |

### Part 8: Training record

Train at first assignment and within one year of each employee's last session, at no cost and during working hours, in words and a language each employee understands.

| Topic covered | Done |
|---|---|
| A copy of the bloodborne pathogens standard, and what it says | |
| Bloodborne diseases, their symptoms, and how they spread | |
| This plan, and how to get a copy | |
| Which tasks in our vans can involve blood or body fluids | |
| How gloves, controls, and work practices help, and their limits | |
| Where protective gear is kept, how to put it on, take it off, and throw it away, and why we chose it | |
| The hepatitis B vaccine: how well it works, safety, how it is given, its benefits, and that it is free | |
| Who to call and what to do in an emergency with blood | |
| What to do after an exposure, how to report it, and the free medical follow-up | |
| Red bags, labels, and the biohazard symbol | |
| Time for questions with the trainer | |

| Session date | Trainer name and qualifications | Attendee name | Job title | Signature |
|---|---|---|---|---|
| | | | | |
| | | | | |
| | | | | |

### Part 9: Yearly review and staff input

| Review date | What changed (services, jobs, vans, products) | Safer products we looked at, and what we chose | Staff who gave input, by name or job title | Reviewed by |
|---|---|---|---|---|
| | | | | |
| | | | | |

### Part 10: Records and how long we keep them

| Record | How long | Where it is kept |
|---|---|---|
| Training records (Part 8) | 3 years from the training date | |
| Medical records: Parts 4, 5, and 7, test results, and written opinions | Length of employment plus 30 years, kept confidential | |
| Sharps injury log, if we keep OSHA injury logs | 5 years after the year it covers | |
| This plan and each yearly review | The current version stays where every covered employee can read it | |

## What the standard requires, part by part

Every element the federal standard asks for has a place in the template. The sample text in Parts 2 and 3 is a starting point. OSHA's own model plan (OSHA 3186) warns that a template must be tailored to the workplace, and that no required item should be dropped.

| Template part | What it covers | 29 CFR 1910.1030 |
|---|---|---|
| Part 1 | Plan owner, clinic, and where staff read the plan | (c)(1)(iii) and (f)(1)(ii) |
| Part 2 | Jobs and tasks with exposure | (c)(2) |
| Part 3 | Universal precautions, controls, gear, cleanup, waste, and laundry | (d) |
| Parts 4 and 5 | Vaccine offer and declination | (f)(2) and Appendix A |
| Part 6 | Evaluation and follow-up after an exposure | (f)(3) to (f)(5) |
| Part 7 | Review of each exposure incident | (c)(1)(ii)(C) and (f)(3)(i) |
| Part 8 | Training topics and training records | (g)(2) and (h)(2) |
| Part 9 | Yearly review, safer devices, and staff input | (c)(1)(iv) and (v) |
| Part 10 | Medical and training records, and the sharps log | (h) |

A few rules matter more in a van than in a clinic:

- **A van is a worksite.** OSHA's enforcement directive says the housekeeping rules reach non-fixed workplaces such as ambulances, not just buildings (CPL 02-02-069). So the cleaning schedule, disinfectant, and waste rules apply inside every vehicle.
- **Gear has to be where the work is.** Protective equipment must be readily accessible at the worksite or issued to employees, in the right sizes, with alternatives for anyone allergic to the usual gloves (1910.1030(d)(3)(iii)). A box of gloves at the office does not cover a driver two counties away.
- **When there is no running water.** Where washing up is not feasible, you supply antiseptic hand cleaner with towels or antiseptic towelettes, and staff wash with soap and running water as soon as they can (1910.1030(d)(2)(iv)).
- **Laundry stays at work.** The employer cleans, launders, and disposes of protective gear at no cost to the employee (1910.1030(d)(3)(iv)), and OSHA's directive says home laundering of it is not permitted.
- **Disinfectant choice.** The Part 3 rule follows OSHA's March 9, 2010 letter, which accepts EPA-registered tuberculocidal disinfectants and household bleach (5.25 percent) diluted between 1:10 and 1:100 for blood, but not soap and water alone. EPA says products on its lists, List S included, meet the standard when used as labeled (page updated August 24, 2026). Contact times and the cleaning steps are in the [vehicle cleaning checklist](https://nemtguide.com/templates/nemt-vehicle-cleaning-checklist/).

### The vaccine and the declination

The vaccine and the full series are free to the employee, given at a reasonable time and place, by or under a licensed health care professional (1910.1030(f)(1)). You offer it after the vaccine training topic in Part 8 and within 10 working days of first assignment, unless the employee already had the full series, a test shows immunity, or the vaccine is medically ruled out (f)(2)(i). The declination wording in Appendix A is mandatory. Do not shorten it or add to it.

### After an exposure

The steps in Part 6 come from the standard's list of what a post-exposure evaluation includes (f)(3) and what the clinic receives (f)(4). The first aid steps for the driver follow CDC NIOSH guidance (February 13, 2025): wash punctures and cuts with soap and water, flush splashes with water, rinse eyes, report to a supervisor, and seek care right away. After an exposure, the clinician's written opinion to you is limited to whether the employee was told the results and about any condition that needs follow-up (f)(5). Every other finding stays confidential.

### Training and records

Training happens at first assignment and within one year of the last session, plus extra training when tasks change (g)(2). Training records list the dates, a summary of the content, the trainer's name and qualifications, and each attendee's name and job title, kept 3 years (h)(2). Medical records stay confidential and are kept for the length of employment plus 30 years (h)(1).

If you keep OSHA injury logs, you also keep a sharps injury log with the device type and brand, where it happened, and how (h)(5), for the 5 years that 29 CFR 1904.33 sets. Whether you keep injury logs at all depends on your headcount, which the [OSHA guide](https://nemtguide.com/guides/osha-for-nemt/) explains. For a full incident write-up beyond Part 7, use the [incident report form](https://nemtguide.com/templates/nemt-incident-report-form/).

## Broker and state rules that require bloodborne training

Many programs require the training whether or not OSHA covers you:

- **Kentucky.** Drivers and escorts in the human service transportation program need orientation and safety training that includes bloodborne pathogens, and every vehicle carries a first aid kit and a spill kit (603 KAR 7:080, Sections 12(7)(g) and 13(5)(v), certified effective April 25, 2025). See the [Kentucky guide](https://nemtguide.com/states/kentucky/).
- **Oregon.** Drivers for coordinated care organization rides complete and keep current a certification in first aid, CPR, and blood spill procedures before driving any member (OAR 410-141-3925(5)(c), effective January 1, 2022). See the [Oregon guide](https://nemtguide.com/states/oregon/).
- **Virginia.** Stretcher van drivers and assistants complete DMAS-approved training in first aid, handling blood borne pathogens, and stretcher transfers, and every vehicle carries a spill kit (DMAS fee-for-service requirements, updated May 26, 2026). See the [Virginia guide](https://nemtguide.com/states/virginia/).
- **Verida.** As of October 2026, its provider training list puts spill kit and bloodborne pathogens training under first aid and CPR, and drivers finish spill kit training during credentialing, before the owner's orientation and contracting. See the [Verida page](https://nemtguide.com/brokers/verida/).

Spill kit contents differ by program. The [first aid kit checklist](https://nemtguide.com/templates/nemt-first-aid-kit-checklist/) compares what several states and brokers name, and the [emergency plan](https://nemtguide.com/templates/nemt-emergency-plan/) covers the rest of what a driver does when something goes wrong on the road.

### When an outside course counts as your OSHA training

A broker's or state's course can count toward the standard's training when it covers every topic in Part 8 and meets two conditions in OSHA's enforcement directive (CPL 02-02-069). First, a generic course, even an interactive computer one, counts only when you add your own site-specific information, such as where the plan is kept and what to do after an exposure. Second, trainees must be able to reach a qualified trainer with questions during the training. A phone line works. Email counts only if the trainer answers as the questions come in. So after an outside course, hold a short session on Parts 1, 3, and 6, and record it in Part 8.

## State Plan states with their own standard

A State Plan can write its own bloodborne pathogens rule, because OSHA requires State Plans to be at least as effective as federal OSHA, not identical to it. Check yours on OSHA's State Plans page before you finish the template. Two examples:

- **California, 8 CCR 5193.** Your plan must also be consistent with your Injury and Illness Prevention Program (8 CCR 3203). It adds written procedures for a sharps injury log, for finding and choosing engineering controls, and for involving employees in each review. Every employer logs each exposure incident with a sharp within 14 working days of the report, whether or not it keeps OSHA injury logs. The California log also records the body part, the task, and the employee's view of what could have prevented it, and is kept 5 years. Each yearly review evaluates the exposure incidents since the last one. California's declination statement reads the same, with "blood or OPIM" in place of the longer phrase.
- **Washington, chapter 296-823 WAC.** Washington keeps its own bloodborne pathogens chapter (last updated September 22, 2020). Your plan must also name the infection control system you use, such as universal precautions, and an employee who asks for a copy gets one within 15 days (WAC 296-823-11010). Resuscitation devices such as masks, mouthpieces, or barrier shields must be readily available to every employee who can be expected to do resuscitation (WAC 296-823-15025).

If you run vans in California, the [California guide](https://nemtguide.com/states/california/) covers the rest of what a NEMT company needs there.

## Frequently asked questions

### Does a small NEMT company need an exposure control plan?

Yes, if even one employee has occupational exposure, meaning reasonably anticipated contact with blood or other potentially infectious materials on the job. The bloodborne pathogens standard, 29 CFR 1910.1030, has no small business exemption. It covers part-time and temporary staff too. An owner who drives alone with no employees falls outside OSHA, but brokers such as Verida and states such as Kentucky still require bloodborne pathogens training.

### Does cleaning up vomit or urine count as exposure?

It can. OSHA counts any body fluid visibly mixed with blood, and every body fluid when you cannot tell what it is, as potentially infectious. In a van at the end of a long shift, drivers often cannot tell. So write spill cleanup into Part 2 for every job that does it, and train drivers to treat every spill as infectious.

### Can a driver refuse the hepatitis B vaccine?

Yes. You must offer it at no cost, after training and within 10 working days of the driver's first assignment to tasks with exposure. A driver who declines signs the exact statement in Appendix A of the standard, shown in Part 5, and can take the vaccine later at no cost while still covered. You may not require a blood test first as a condition of getting the vaccine.

### How often do I have to update the exposure control plan?

At least once a year, and any time tasks or job titles with exposure change, such as adding stretcher service or hiring a van cleaner. Each review also records the safer products you considered. California employers must also review every exposure incident since the last update and involve employees in the review (8 CCR 5193).

### Where do I keep the plan?

Somewhere every covered employee can reach it during a shift, such as a binder at dispatch or a shared file drivers know how to open. OSHA's enforcement directive (CPL 02-02-069) says a plan kept only on a computer counts only if employees are trained to use it, and that an employee who asks gets a paper copy within 15 working days.

### Do I report a needlestick to OSHA?

Only if it leads to an in-patient hospital admission, which you report to OSHA within 24 hours (29 CFR 1904.39). State Plan states can set their own reporting rules. If you keep OSHA injury logs, a cut or stick from a sharp object contaminated with another person's blood is always recordable, and the employee's name stays off the log (29 CFR 1904.8). Employers who keep those logs also keep a sharps injury log under 1910.1030(h)(5).

## Official resources

- [eCFR: 29 CFR 1910.1030, the full bloodborne pathogens standard and Appendix A](https://www.ecfr.gov/current/title-29/section-1910.1030)
- [OSHA: Bloodborne pathogens and needlestick prevention](https://www.osha.gov/bloodborne-pathogens)
- [OSHA 3186: Model exposure control plan](https://www.osha.gov/sites/default/files/publications/osha3186.pdf)
- [EPA: Disinfectant lists, including List S for bloodborne pathogens](https://www.epa.gov/pesticide-registration/selected-epa-registered-disinfectants)
- [CDC NIOSH: What to do after a needlestick or blood exposure](https://www.cdc.gov/niosh/healthcare/risk-factors/bloodborne-infectious-diseases.html)
- [OSHA: State Plans map and contacts](https://www.osha.gov/stateplans)