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Policy GBGAA-R
In accordance with the OSHA Bloodborne Pathogens standard, 29 CFR 1910, 1030, the following exposure control plan has been developed:
Introduction
Purpose
The purpose of the Exposure Control Plan is to provide and maintain a safe working environment for all employees by eliminating and/or minimizing occupational exposure to bloodborne pathogens, including but not limited to Hepatitis B Virus (HBV) and the Human Immunodeficiency Virus (HIV). It is the responsibility of the employer to provide and maintain appropriate engineering controls and personal protective equipment, and to develop and promote safe work practices. It is also expected that employees will practice and follow the guidelines set forth by this plan.
Definitions
Blood: Human blood, human blood components, and products made from blood.
Bloodborn pathogens: pathogenic microorganisms that are present in human blood and can cause disease in humans. These pathogens include but are not limited to Hepatitis B Virus (HBV) and Human Immunodeficiency Virus (HIV)
CDC: Centers for Disease Control and Prevention
Clinical Laboratory: A work-place where diagnostic or other screening procedures are performed on blood or other potentially infectious materials.
Contaminated: The presence or other reasonably anticipated presence of blood or other potentially infectious materials on an item or surface.
Contaminated Laundry: Laundry which has been soiled with blood or other potentially infectious materials or may contain sharps.
Contaminated Sharps: Any contaminated object that can penetrate the skin including, but not limited to, needles, scalpels, broken glass, broken capillary tubes, and exposed ends of dental wire.
Decontamination: The use of physical or chemical means to remove inactivate, or destroy bloodborne pathogens on a surface or item to the point they are no longer capable of transmitting infectious particles and the surface or item is rendered safe for handling, use or disposal.
Engineering Controls: Controls that isolate or remove the bloodborne pathogens hazard from the workplace.
Exposure Incident: A specific eye, mouth, or other mucous membrane non-intact skin, or parenteral contact with blood or other potentially infectious materials that results from the performance of an employee’s duties.
Handwashing Facilities: Facility providing an adequate supply of running potable water, soap, and single use towels or a hot air drying machine.
Licensed Healthcare Professional: Person whose legally permitted scope of practice allows him or her to perform the activities required for Hepatitis B vaccination and post-exposure evaluation and follow-up.
HBV: Hepatitis B Virus
HIV: Human Immunodeficiency Virus
Occupational Exposure: Reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee’s duties.
Other Potentially Infectious Materials (OPIM): See bottom of page 2 of this Exposure Control Plan.
Parenteral: Piercing mucous membranes or the skin barrier through such events as needle sticks, human bites, cuts, and abrasions.
Personal Protective Equipment (PPE): Specialized equipment worn by an employee for protection against a hazard. General work clothes (e.g. uniforms, pants, shirts, or blouses) not intended to function as protection against a hazard are not considered to be personal protective equipment.
Source Individual: Any individual, living or dead, whose blood or other potentially infectious material may be a source of occupational exposure to the employee.
Sterilize: The use of a physical or chemical procedure to destroy all microbial life including highly resistant bacterial endospores.
Universal Precautions: See Attachment I of this Exposure Control Plan.
Work Practice Controls: Controls that reduce the likelihood of exposure by altering the manner in which a task is performed.
Scope
This plan covers all employees who could be “reasonably anticipated”, as a result of the performance of their job duties, to come into contact with blood or other potentially infectious materials. “Good Samaritan” acts, such as assisting a co worker with a nosebleed, would not be considered an occupational exposure.
Background
The Center for Disease Control and Protection (CDCP) has recognized the following as linked to the potential transmission of HBV, HIV, and other bloodborne pathogens in the occupational setting:
blood/blood product or components any body fluid visibly contaminated with blood
semen
pleural fluid
vaginal secretions
pericardial fluid
amniotic fluid
peritoneal fluid
synovial fluid
cerebrospinal fluid
saliva (in dentistry)
And all body fluids in situations where it may be difficult or impossible to differentiate between body fluids.
These substances shall be collectively referred to as blood and “other potentially infectious material” (OPIM) for the remainder of this document.
Exposure Determination
OSHA requires employers to perform an exposure determination concerning which employees may insure occupational exposure to blood or other potentially infectious materials. The exposure determination is made without regard to the use of personal protective equipment (i.e. employees are considered to be exposed even if they wear personal protective equipment). This exposure determination is required to list all job classifications in which all employees may be expected to incur such occupational exposure, regardless of frequency. At this facility the following job classifications are in this category:
School Nurse
Elementary School Clerks
School Administrators
Playground Aides
Athletic Trainer
In addition, OSHA requires a listing of job classifications in which some employees may have occupational exposure. Since not all the employees in these categories would be expected to incur exposure to blood or other potentially infectious materials, tasks or procedures that would cause these employees to have occupational exposure are also required to be listed in order to clearly understand which employees in these categories are considered to have occupational exposure. The job classifications and associated tasks for these categories are as follows:
Job Classification Tasks/Procedures
Special Education: Self-contained…………………….Restraining out-of-control students
Classroom Employees…………………………………Diapering students
Bus Drivers & Custodians……………………………..Cleaning OPIM (other potentially infectious materials)
(See Attachment 2, 2a, 2b, and 2e)
Implementation Schedule And Methodology
Universal Precautions
Universal Precautions will be observed at each school in order to prevent contact with blood or other potentially infectious materials. All blood or OPIM will be considered infectious regardless of the perceived status of the source individual. (See Attachment 1).
OSHA also requires that this plan include a schedule and method of implementation for the various requirements of the standard. The following complies with this equipment.
Personal Protective Equipment
All PPE used at this school will be provided without cost to employees. PPE will be chosen based on the anticipated exposure to blood or other potentially infectious materials. The protective equipment will be considered appropriate only if it does not permit blood or other potentially infectious materials to pass through or reach the employees’ clothing, skin, eyes, mouth, or other mucous membranes under normal conditions of use and for the duration of time which the protective equipment will be used.
Gloves shall be worn where it is reasonably anticipated that employees will have hand contact with blood, OPIM, non-intact skin, and mucous membranes. Gloves will be provided by the school nurse.
Disposable gloves used at this facility are not to be washed or decontaminated for re-use and are to be replaced as soon as practical when they become contaminated or as soon as feasible if they are torn, punctured, or when their ability to function as a barrier is compromised. Utility gloves may be decontaminated for re-use provided that the integrity of the glove is not compromised. Utility gloves will be discarded if they are cracked, peeling, torn, punctured, or exhibit signs of deterioration or when their ability to function as a barrier is compromised. (See Attachment 3 and 3a).
Masks in combination with eye protection devices, such as goggles or glasses with solid shield, or chin length face shield, are required to be worn whenever splashes, spray, spatter, or droplets of blood or other potentially infectious materials may be generated and eye, nose, or mouth contamination can reasonably be anticipated. Situations at the school which would require such protection are as follows:
*children with a documented history of vomiting, spitting, etc.
Engineering Controls
Engineering and work practice controls will be utilized to eliminate or minimize exposure to employees at this facility. Where occupational exposure remains after institution of these controls, personal protective equipment shall also be utilized.
At the schools the following engineering controls will be utilized:
Handwashing sinks
Eyewash stations
The above controls will be examined and maintained on a regular schedule. The schedule for reviewing the effectiveness of the controls is as follows:
Handwashing sinks and eye wash stations will be maintained daily by the custodian.
Gloves will be reordered as needed by the school nurses.
Work Practice Controls
All tasks will be performed in a manner that will reduce the risk of exposure. Personnel in areas where exposure hazards exist are expected to adhere to the following:
Food and drink shall not be kept in refrigerators, freezers, shelves, cabinets or countertops where blood or OPIM are stored or present. ii. Hands will be washed after removing gloves or as soon as possible after contact with blood or body fluids.
All PPE will be worn or used by employees as instructed in this document, as outlined during training and as specified by policy, procedure, or protocol. This would be expected to include whenever the employee makes the assessment that is reasonable to anticipate that parenteral, skin, clothing, or mucous membrane contact with blood or OPIM might occur.
All procedures shall be performed in a manner as to minimize splashing and/or spraying of blood or OPIM.
Needles/sharps: Sharps will be disposed of in an OSHA approved container located in each school.
Hepatitis B Vaccine
All employees who have been “identified as having possible exposure to blood or other potentially infectious material” because of their job (Exposure Determination) (See Attachment 2, 2a, 2b, & 2c) will be offered Hepatitis B vaccine free of charge. These workers must be immunized against Hepatitis B or sign a declaration form. (See Attachment 2d) Any employee who declines the vaccine initially may request it, free of charge, at any future date. New employees must be offered this vaccine within ten (10) working days of their initial assignments to work.
The Superintendent’s office will be responsible for assuring that the appropriate counseling is provided, the vaccine is offered and that all paperwork is completed and waiver or declination forms are assigned.
Housekeeping Practices
Each school will be cleaned and decontaminated according to the following schedule: (See Attachment 7)
Decontamination will be accomplished by utilizing the following materials: (See Attachment 7)
All contaminated work surfaces will be decontaminated after completion of procedures and immediately or as soon as feasible after any spill of blood or other potentially infectious materials, as well as the end of the work shift if the surface may have become contaminated since the last cleaning.
All trash receptacles shall be inspected and replaced daily, decontaminated and/or lined or a regularly scheduled basis. (See Attachment 7)
Any broken glassware which may be contaminated will not be picked up directly with the hands. The following procedures will be used: Maintenance/custodial staff will use brush and dust pan and dispose of pieces in an appropriate container. These cleaning tools shall be decontaminated according to procedures. (See Attachment 7)
Post-Exposure Evaluation and Follow-Up
When the employee incurs an exposure incident, it should be reported to: Benefits Specialist in Central Office. This follow-up will include the following:
Documentation of the route of exposure and the circumstances related to the incident.
If possible, the identification of the source individual, and if possible, the status of the source individual. The blood of the source individual will be tested (After consent is obtained) for HIV/HBV infectivity.
The employee will be offered the option of having their blood collected for testing of the employees HIV/HBV serological status. The blood sample will be preserved for up to 90 days to allow the employee to decide if the blood should be tested for HIV serological status. However, if the employee decides prior to that time that testing will or will not be conducted then the appropriate action can be taken and the blood sample discarded.
The employee will be offered post exposure prophylaxis in accordance with the current recommendations of the U.S. Public Health Service.
The employee will be give appropriate counseling concerning precautions to take during the period after the exposure incident. The employee will also be given information on what potential illnesses to be alert for and to report any related experiences to appropriate personnel.
The Superintendent’s Office has been designated to assure that the policy outlined here is effectively carried out as well as to maintain records related to this policy.
Interaction With Healthcare Professionals
A written opinion shall be obtained from the health care professional who evaluates employees of this school. Written opinions will be obtained in the following instances:
When the employee is sent to obtain the Hepatitis B vaccine.
Whenever the employee is sent to a health care professional following an exposure incident.
Health care professionals shall be instructed to limit their opinions to:
Whether the Hepatitis B vaccine is indicated and if the employee has received the vaccine, or for evaluation following and incident.
That the employee has been informed of the results of the evaluation, and
That the employee has been told about any medical conditions resulting form exposure to blood or OPIM. (Note that the written opinion of the employer is not to reference any personal medical information)
Follow-Up
Each exposure will be documented in accordance with 29 CFR 1910.30. Access to Employee Exposure and Medical Records. Records shall be maintained for at least the duration of employment plus 30 years.
Each exposure record shall include:
The name and social security number of the employee.
A copy of the employee’s HBV vaccination status including dates and any records relative to the employee’s ability to receive the vaccination.
A copy of all tests, exams, and follow-up procedures
The employer’s copy of the health care professional’s written opinion
A copy of the information provided to the health care professional.
These records shall not be disclosed to anyone without the employee’s express written consent, except as required by OSHA regulations or state law. All records, whether pertaining to the exposed person or the source individual, will be maintained in a separate, locked, confidential file.
Exposure shall be recorded on the OSHA 200 form if medical treatment is required, or if duties are restricted or time lost in accordance with OSHA guidelines.
In-Service Training
Implementation
All requirements for the training will be implemented by September 30, 1993 and training shall be conducted by individuals knowledgeable on the subject matter as it relates to the control of bloodborne pathogens and to the specific tasks being performed.
Training will be provided at no cost to all employees and during reasonable normal working hours.
This training will be updated annually. Employees will receive additional training when new procedures are added. This additional training will be limited to the new procedures or modifications.
Content
Training for all employees will be conducted prior to initial assignment to tasks where occupational exposure may occur. Training will be conducted in the following manner:
Training for employees will include an explanation of the following:
The OSHA standard for Bloodborne Pathogens
Epidemiology and symptomatology of bloodborne diseases
Modes of transmission of bloodborne pathogens
This Exposure Control Plan, i.e. points of the plan, lines of responsibility, how the plan will be implemented, etc.
Procedures which might cause exposure to blood or other potentially infectious materials at the schools
Control methods which will be used at the schools to control exposure to blood or other potentially infectious materials
PPE available at the schools and who should be contacted
Post exposure evaluation and follow-up
Hepatitis B vaccine program at the schools
Training Record Keeping
All records required by the OSHA standard 29 CFR 1910.1030 will be maintained by the Superintendent’s office
Training records shall be maintained for three years from training date. They shall include: the date of training, the contents or summary of the training, the names and qualifications of theperson conducting the training, and the names and job classifications of the person attending the training.
The availability and transfer of these training records will be in accordance with 29 CFR 1910.1030, the Bloodborne Pathogens Standard
The outline for the training material is located in the offices of the school nurses
Reviewed: December 12, 2017, January 12, 2018
*Please excuse any formatting errors.
