COVID-19 and Workplace Exposure Control Plans

Employers are responsible to provide workers with a safe and healthy workplace by identifying hazards and implementing measures to either eliminate or minimize the risk to workers. This includes protecting workers from exposure to biological agents such as the novel coronavirus (COVID-19) we are currently battling.

What is an Exposure Control Plan (ECP)?

An ECP is a written document that identifies all the tasks in the workplace where occupational exposure is possible, determines the risk associated with each task, and lays out the steps required to prevent or minimize exposure.

According to the Occupational Health and Safety Regulation (section 6.34(1)), an ECP must be based on the precautionary principle. This means that in developing and implementing and ECP, employers must err on the side of caution, even when definitive scientific proof is lacking. This principle is particularly relevant in the context of COVID-19, where our knowledge about the virus, how it is transmitted and its health impacts are still quite limited.

The purpose of an exposure control plan is to eliminate or minimize the risk of exposure to a hazard – in this case, COVID-19. The ECP is also meant to minimize the risk of disease if an exposure does occur. As such, developing an ECP is not just extra paperwork. It is an important tool for protecting workers.

When is an ECP needed?

Sections 5.54 and 6.34 of the Occupational Health and Safety Regulation require an exposure control plan in every workplace where workers might face occupational exposure to a biological agent, such as COVID-19.

The plan must be developed and implemented as soon as possible after the hazard is identified.

What does an ECP have to include?

A risk assessment completed by a qualified person. The employer must ensure a qualified person (usually an occupational hygienist or infection control specialist) conducts a risk assessment to identify the potential for occupational exposure by any route of transmission.

A list of all work activities that could potentially expose workers. A list describing all the tasks where there is a risk of exposure, their location at the worksite, the workers involved, and the level of risk should be compiled. This allows workers to see and understand where exposure is possible, and areas that might have been missed as the plan was created.

Control measures to eliminate or minimize the risk of exposure. Engineering control measures must be considered before defaulting to administrative control measures. An example of an engineering measure could be installing a plexiglass barrier. An administrative measure could mean implementing a new way to complete a task, like limiting the number of customers/visitors to a worksite at any given time.

Infection control precautions must be in place for all work activities where there is a risk of exposure.

Procedures must be in place to:

• address housekeeping practices – keeping workplaces free from accidental spills, splashes or other accidental contamination
• work procedures for dealing with contaminated items
• work procedures to ensure hazardous substances are disposed of correctly

A description of the personal protective equipment (PPE) needed.  Requirements for PPE must be clear, and workers must be trained in proper use of the PPE. With the corona virus, routes of transmission are through indirect contact, direct contact with droplets or by airborne transmission (during aerosolizing procedures). More information about the coronavirus and appropriate PPE is available here (link to PPE bulletin).

Worker education and training – provided and documented. Workers must be informed of the contents of the exposure control plan, and they must receive the education, training and supervision to safely carry out their work when faced with potential exposure. Records must be kept on who received this training.

A record of workplace exposures. Employers are required to maintain a record of workers who have been exposed to biological or chemical agents at work.

Note: If you have been exposed to a biological or chemical hazard, we encourage you to register your exposure with WorkSafeBC's Exposure Registry Program. Your details will remain in their database because many diseases have a long latency period and may not manifest for over twenty years. Registering your exposure may make it easier to have a future claim accepted if it was a result of the registered occupational exposure.

What is the role of the JOHS committee or worker health and safety representative?

The JOHS committee or worker health and safety representative should be involved in the development of the ECP. In addition, the OHS Regulation (section 5.54(3)) requires that the ECP is reviewed annually and updated as necessary in consultation with the JOHS committee or worker health and safety representative.

If an employer has a general plan that covers many worksites, committees or worker reps should review the plan and recommend revisions to ensure that the risk assessment, control measures, safe work procedures and training are suited to your specific worksite. 

You are encouraged to discuss exposure control plans at your next OHS committee meeting. With the current corona virus pandemic, it is evident many employers are ill-prepared to address this outbreak at the worksite. OHS committees have a critical role to play in ensuring that employers are meeting their obligations to protect workers' health and safety.

Where can I get more information?

• WorkSafeBC: Preventing exposure to COVID-19 in the workplace
• WorkSafeBC has a helpful resource called "Controlling Exposure: Protecting Workers from Infectious Disease": 
• An older but still useful guide to developing ECPs for healthcare or healthcare-like settings is Creating and Reviewing Exposure Control Plans from the BC Occupational Health & Safety Agency For Healthcare.