What is an Exposure Control Plan (ECP)?
An Exposure Control Plan (ECP) is a product of an organization’s chemical or health and safety management system that provides direction and expectations to prevent exposures to workers. Based on where you operate, your regulatory authority may require you to have one or more exposure control plans. These written documents are specific to your organization and worksite, any exposure hazards workers may encounter while performing routine and non-routine tasks, and the protective measures available. Certain regulatory bodies (WorkSafe BC, OSHA in USA, and OH&S in AB) require employers to develop exposure control plans (ECP). The ECPs may have different titles based on the jurisdiction, but they have similar requirements and intent.
When do I need an Exposure Control Plan?
There are different drivers for an ECP; It may be integrated into your Health and Safety or Loss Control Management System or it may be a requirement based on your regulatory authority.
In British Columbia for example, employers are required under Section 5.54 of the Occupational Health and Safety Regulation (OHSR) to develop an Exposure Control Plan (ECP) when workers are or may be exposed to certain designated substances at concentrations that exceed 50% of the exposure limit or cannot be measured as well as toxic process gases. If this exposure potential exists, the employer is required to look for a substitute or develop an exposure control plan.
What happens if I don’t have an Exposure Control Plan?
If an employer fails to develop and implement an exposure control plan. Orders can be issued by the regulator to motivate action and compliance and with the potential for stop work order.
Why does the regulatory body want me to have an Exposure Control Plan?
Occupational health statistics indicate that more than 50% of all fatalities in Alberta and British Columbia are due to occupational disease. In 2015, WorkSafe BC stats indicated that there were 122 deaths due to occupational disease and 72 were due to worksite exposures. Overall, there is a trend for more claims for occupational disease/illnesses being recognized and accepted by workers compensation boards. ECP’s are meant to control the hazards and eliminate or mitigate the risks associated with potential exposure. Regulators want to see that prevention from occupational disease is being taken seriously and included in health and safety management systems.
More than 50% of all fatalities in AB and BC are attributed to occupational disease. In 2015, out of 122 occupational disease deaths 72 were due to worksite exposures (WorkSafe BC 2015).
Occupational Diseases and Illnesses of concern:
- All cancers/malignancies attributed to chemical exposures
- All dermatitis claims, including latex sensitization and chemical burns
- Solvent induced neurotoxicity e.g. painter’s syndrome
- Asbestosis, silicosis
- Asthma, bronchitis, rhinitis, fibrosis, alveolitis, hypersensitivity pneumonitis, emphysema
- Chronic Obstructive Pulmonary Disease (COPD)