What this is
What is an exposure control plan?
What is an exposure control plan?
A written plan for a specific hazardous substance covering how exposure is assessed, the controls applied in hierarchy order, how engineering controls are maintained and verified, and the monitoring, medical surveillance, training and recordkeeping the applicable standard requires.
What is an action level?
A concentration, typically half the permissible exposure limit, at which obligations begin even though the limit has not been exceeded. Periodic monitoring and, for several substances, medical surveillance are triggered at the action level rather than at the limit, which is a distinction organisations frequently miss.
Scope
When is an exposure control plan required?
This plan addresses a specific substance under a specific standard. General chemical assessment sits alongside it.
Use this template when
- Substances with a specific OSHA standard: lead, silica, hexavalent chromium, benzene, asbestos, formaldehyde, cadmium and others
- Where monitoring has shown exposure at or above an action level
- Introducing a process, material or task that could generate exposure to a regulated substance
- Following a change in process, control, material or work practice affecting exposure
- Where medical surveillance results indicate controls are not adequate
Do not use it for
- General chemical risk assessment, which covers substances without their own standard
- Safety data sheets, which describe the substance rather than your exposure
- Medical surveillance records, which are confidential and held separately
- Respiratory protection programme, which is a distinct requirement under 1910.134
- The bloodborne pathogens exposure control plan, which is a separate regime under 1910.1030
Compliance mapping
Which OSHA substance specific standards requirements does this satisfy?
Each regulated substance has its own standard, with a common architecture and different numbers.
| Clause | Requirement | Where it lands |
|---|---|---|
| 29 CFR 1910 Subpart Z | Substance-specific standards with permissible exposure limits, action levels and associated programmes | Header |
| 1910.1053 (silica) | Respirable crystalline silica: exposure assessment, control methods, medical surveillance and written plan | Control hierarchy |
| 1910.1025 (lead) | Lead: monitoring, engineering and work practice controls, hygiene facilities and medical surveillance | Verification and surveillance |
| 1910.1026 (hexavalent chromium) | Chromium VI: exposure determination, controls, respiratory protection and surveillance | Control hierarchy |
| 1910.1020 | Access to employee exposure and medical records, with retention of exposure records for 30 years | Verification and surveillance |
| 1910.134 | Respiratory protection programme where respirators are used, including fit testing and medical evaluation | Control hierarchy |
| COSHH regs 6, 7, 10 and 11 | Assessment, adequate control, exposure monitoring and health surveillance (GB) | Header |
| COSHH reg.9 | Maintenance, examination and test of engineering controls, including LEV at defined intervals | Engineering control maintenance |
What it does not cover
- General chemical risk assessment, for substances without a specific standard.
- Medical surveillance records, which are confidential and held by occupational health.
- The respiratory protection programme, a distinct requirement with fit testing and medical evaluation.
- Safety data sheets, describing the substance rather than your exposure.
- Bloodborne pathogens exposure control plan, a separate regime with different requirements.
How to complete it
How to complete an exposure control plan, step by step
Work the hierarchy honestly, maintain the controls you rely on, and track the triggers rather than the limit.
Record where results sit relative to both the action level and the permissible exposure limit, and state which obligations are active as a result. Periodic monitoring and, for several substances, medical surveillance begin at the action level, and a plan that only references the limit will miss the point at which duties start.
Respiratory protection is permitted while engineering controls are being installed, where they are not feasible, or during specified operations. Where respirators are the standing control, the plan should record why engineering controls are not feasible, because that determination is what an inspector examines.
Local exhaust ventilation loses capture velocity through duct fouling, damper drift, fan wear and hood damage, and none of that is audible or visible. Thorough examination and test at defined intervals, and routine capture checks between them, are the only way to know a system still does what the assessment assumed.
Exposure records generally require thirty years of retention and medical records the duration of employment plus thirty. That outlasts most document systems, most employees and frequently the process itself, and it needs a deliberate arrangement rather than the default retention period applied to operational records.
What auditors find
Most common exposure control plan findings
Findings here concentrate on triggers, on control maintenance and on records.
| Finding | Clause | What fixes it |
|---|---|---|
| Exposure tracked against the limit only, with no reference to the action level. | 1910 Subpart Z | Obligations begin at the action level; record position against both. |
| Periodic monitoring not established after an action level exceedance. | 1910.1053(d) | Monitoring frequency is prescribed by the result; apply the schedule the standard sets. |
| Respirators used as the standing control with no feasibility determination. | 1910.1026(f) | Record why engineering controls are not feasible; respirators are not a default. |
| Local exhaust ventilation not examined and tested at the required interval. | COSHH reg.9 | LEV degrades silently; examination and test at least every 14 months in Great Britain. |
| Medical surveillance not offered where the standard requires it. | 1910.1025(j) | Surveillance triggers are prescribed and are frequently tied to the action level. |
| Exposure records retained for a general document period rather than 30 years. | 1910.1020(d) | Set retention explicitly; the requirement outlasts most systems. |
| Employees not informed of their monitoring results. | 1910.1053(d)(6) | Notification is required, usually within a defined period, and in writing. |
| Housekeeping and hygiene provisions not addressed for the substance. | 1910.1025(i) | Several standards specify washing, changing and eating provisions explicitly. |
| Plan not revised after a process, material or control change. | 1910.1053(f) | Change affects exposure; the written plan requires review. |
| Regulated areas not established or signposted where required. | 1910.1026(e) | Demarcation and access control are specific requirements for several substances. |
Case in point
Case in point: sixty percent of the limit
A fabrication operation monitored welder exposure to hexavalent chromium and recorded results at around sixty percent of the permissible exposure limit. The result was reported internally as compliant with a comfortable margin, and no further monitoring was scheduled.
The standard sets an action level at half the limit. Results above it trigger periodic monitoring at a prescribed frequency and bring employees within the medical surveillance provisions. The operation was above the action level and had treated the position as satisfactory because it was below the limit.
The gap was not in the measurement, which was accurate, or in the controls, which were reasonable. It was that nobody had read what the action level obliges.
The template
The template, field by field
The form exactly as it installs. Every field, option, score and conditional rule is editable, and the links to other templates come with it.
4 sections
- Reference
- HLT-008
- Archetype
- Plan
- Record ID
- ECP2-2026-000
- Scoring
- Not scored
- Direction
- n/a
- Singleton
- No
- Basis
- OSHA substance specific standards
- Links
- Links Substance, SEG; feeds CAPA
- Tags
- Hygiene, Control
- Sections
- 4
- Fields
- 48
- Follow up fields
- 3
- Repeating sections
- 0
- Links out
- 4
Header
14 fieldsPlan ID*
Auto sequence. Format ECP-2026-000.
The record's own ID. Other templates point at this value.
Status*
Drives who this goes to next.
- Planned2 pts
- In progress2 pts
- Complete3 pts
- Deferred0 pts
- Open0 pts
- Closed3 pts
- Overdue0 pts
Version*
Issue Date*
Next Review Due*
Site*
Site ID*
Format SITE-000.
Links to FDN-001 Site ID
Plan Owner*
Occupational Health Provider
Approved By*
Agent*
Areas Covered*
Workers Covered*
Work Down, Not Straight To Masks
Most exposure control plans arrive at respirators within two steps. Elimination, substitution and enclosure protect everybody without depending on anyone remembering anything.
Control hierarchy
12 fieldsElimination Assessed*
- Yes3 pts
- No0 pts
Elimination Applied*
- Yes4 pts
- Partly2 pts
- No0 pts
Why Not Applied
Substitution Assessed*
- Yes3 pts
- No0 pts
Substitution Applied*
- Yes4 pts
- Partly2 pts
- No0 pts
New Hazards Assessed
- Yes3 pts
- No0 pts
Enclosure Or Automation Applied*
- Yes4 pts
- Partly2 pts
- No0 pts
Local Exhaust Ventilation Applied*
- Yes3 pts
- Partly1 pt
- No0 pts
General Ventilation Adequate*
- Yes3 pts
- Marginal1 pt
- No0 pts
Administrative Controls Applied*
- Yes2 pts
- No1 pt
Job Rotation Used
Rotation shares the dose. It does not reduce total exposure across the group and should not be the main control.
- No3 pts
- Yes, as supplement1 pt
- Yes, as main control0 pts
PPE Applied*
- Yes1 pt
- Not required3 pts
- No0 pts
Engineering control maintenance
6 fieldsLEV Systems Listed*
- Yes3 pts
- Partly1 pt
- No0 pts
LEV Thorough Examination Frequency*
Statutory examination is typically every fourteen months, with more frequent visual checks.
- Every 6 months4 pts
- Every 12 to 14 months3 pts
- Longer0 pts
- Never0 pts
LEV On PM Schedule*
- Yes3 pts
- No0 pts
Airflow Indicators Fitted*
A gauge on the hood tells the operator whether the extraction is actually working.
- Yes, all hoods3 pts
- Some1 pt
- None0 pts
Operator Checks Defined*
- Yes3 pts
- No0 pts
Failure Response Defined*
- Yes3 pts
- No0 pts
Verification and surveillance
16 fieldsMonitoring Programme Defined*
- Yes3 pts
- No0 pts
Monitoring Frequency*
- Quarterly or better4 pts
- Annually3 pts
- Every 2 to 3 years1 pt
- None0 pts
Health Surveillance Linked*
- Yes3 pts
- Not required3 pts
- No0 pts
Training Requirements Defined*
- Yes3 pts
- No0 pts
Worker Consultation Held*
- Yes3 pts
- No0 pts
Records And Retention Defined*
Exposure records for carcinogens must often be kept for forty years.
- Yes3 pts
- No0 pts
Plan Document
Document ID
Format DOC-0000.
Links to FDN-008 Document ID
Action Required*
Raise the action record, then enter its reference here.
- No2 pts
- Yes0 pts
Priority
- High0 pts
- Medium1 pt
- Low3 pts
CAPA ID
Format CAPA-2026-00000.
Links to FDN-014 CAPA ID
Action Owner
Occupational Hygienist*
Signature*
Site Manager*
Second Signature*
HLT-008 · record IDs look like ECP2-2026-000 · Links Substance, SEG; feeds CAPA
Open in KnowellaRun it with agents
From a document you fill in to a programme that runs itself
The plan governs exposure to a regulated substance. What fails is the action level nobody tracked and the extraction nobody tested.
Tracks results against both the action level and the limit, states which obligations are active, and schedules monitoring and surveillance from the result.
Holds local exhaust ventilation as an asset with examination and test intervals, since controls degrade silently between assessments.
Flags process, material and control changes as plan review triggers, and watches retention obligations that outlast normal document cycles.
Delivers the substance-specific training the standards require, which differs from general hazard communication training.
This template lives in KnowHealth — employee wellbeing. Exposure monitoring, health surveillance, case management and return to work.
Meet KnowHealth→Glossary
Exposure Control Plan definitions and key terms
- Permissible exposure limit
- The OSHA maximum airborne concentration, typically as an eight-hour time-weighted average.
- Action level
- Usually half the permissible exposure limit, at which monitoring and often medical surveillance obligations begin.
- Time-weighted average
- Exposure averaged across a work period, the basis for most limits.
- Short-term exposure limit
- A limit applying to a shorter period, typically fifteen minutes, applicable to some substances alongside the TWA.
- Regulated area
- A demarcated area with controlled access where exposure exceeds or may exceed the limit, required for several substances.
- Medical surveillance
- Health monitoring required by the standard, triggered by exposure at defined levels or durations.
- Thorough examination and test
- The scheduled inspection and testing of local exhaust ventilation, at least every 14 months in Great Britain.
- Exposure record
- Monitoring data and related information, requiring thirty-year retention under 1910.1020.
FAQ
Frequently asked questions about exposure control plan
Why does the action level matter more than the limit?+
Because it is what activates ongoing obligations. Most substance-specific standards set an action level at around half the permissible exposure limit, and crossing it triggers periodic monitoring at a prescribed frequency and, for several substances, brings employees within medical surveillance. A result at sixty percent of the limit is above the action level and is not a comfortable margin.
Can we rely on respirators?+
Only in defined circumstances: while engineering controls are being installed, where engineering and work practice controls are not feasible, or during specified operations. Where respirators are the standing control, the plan needs a recorded determination that engineering controls are not feasible, and that determination is what an inspector will examine.
How long must records be kept?+
Exposure records generally for thirty years, and medical records for the duration of employment plus thirty years, under 29 CFR 1910.1020. That outlasts most document management systems and most of the people involved, so it requires a deliberate arrangement rather than the default retention applied to operational records.
How do we know engineering controls still work?+
By testing them. Local exhaust ventilation loses capture velocity through duct fouling, damper drift, fan wear and hood damage, none of which is audible or visible from the workstation. Thorough examination and test at the required interval, with routine capture checks between, is what establishes that the system still performs as the assessment assumed.
Do employees see their results?+
Yes, and it is required. The standards specify notification of monitoring results, usually in writing and within a defined period, and 1910.1020 gives employees a right of access to their exposure and medical records. Building notification into the monitoring process avoids a request being treated as unusual when it arrives.
Keep going
Related templates and programmes
Industries this is written for
Programmes this belongs to
Used together in Occupational Health Surveillance
Similar Exposure Group Register
Groups workers who share the same tasks, agents and exposure patterns
Qualitative Exposure Assessment
Rates likely exposure using professional judgement, task knowledge and existing data, before any sampling
Personal Air Sampling Record
Records a sample taken from a worker's breathing zone over a shift
Area Monitoring Record
Records fixed point sampling in a work area rather than on a person
Noise Dosimetry Record
Records a worker's noise exposure over a full shift using a personal dosimeter
Chemical Exposure Assessment
Assesses exposure to a specific chemical across the tasks where it is used
More in Exposure Monitoring
Similar Exposure Group Register
Groups workers who share the same tasks, agents and exposure patterns
Qualitative Exposure Assessment
Rates likely exposure using professional judgement, task knowledge and existing data, before any sampling
Personal Air Sampling Record
Records a sample taken from a worker's breathing zone over a shift
Area Monitoring Record
Records fixed point sampling in a work area rather than on a person
Noise Dosimetry Record
Records a worker's noise exposure over a full shift using a personal dosimeter
Chemical Exposure Assessment
Assesses exposure to a specific chemical across the tasks where it is used
Written and reviewed by
Siddarth Singh
Founder & Chief Executive Officer, Knowella
Certified Safety Professional and industrial and systems engineer with more than a decade inside food supply chain, freight and manufacturing operations. This page was written against the current text of the standards it cites, not against secondary summaries of them.
- Certified Safety Professional (CSP), Board of Certified Safety Professionals
- MBA, University of Chicago Booth School of Business
- MS and BS, The Ohio State University, Industrial and Systems Engineering
- Six Sigma Black Belt
Sources and last review. Reviewed 16 August 2026 against:
- 29 CFR 1910 Subpart Z, toxic and hazardous substances, OSHA
- 29 CFR 1910.1053, respirable crystalline silica, OSHA
- 29 CFR 1910.1020, access to employee exposure and medical records, OSHA
- 29 CFR 1910.134, respiratory protection, OSHA
- Control of Substances Hazardous to Health Regulations 2002, regulations 7, 9, 10 and 11 (GB)
This page is general guidance, not legal advice. Confirm requirements with your jurisdiction’s regulator.