Exposure Control Plan for Occupational Exposure to Bloodborne Pathogens

Purpose

The purpose of this Exposure Control Plan is to establish a system that will assure that all employees who have potential contact with human blood/body fluids are protected from infectious agents. The plan is intended to reduce the risk of employees who may have occupational exposure with human blood and other potentially infectious materials during the performance of their duties.

Background

OSHA has defined occupational exposure as meaning any reasonably anticipated skin, eye, mucous membranes or parenteral contact with blood or other potentially infectious material through such events as needle sticks, human bites, cuts, and abrasions. Other potentially infectious materials include:

1. The following body fluids: Semen, vaginal secretions, cerebrospinal fluids, synovial fluid, pleurial fluid, pericardial fluid, perifoneal fluid, amniotic fluid, saliva in dental procedures, any body fluid that is visibly contaminated with blood and all bodily fluids when it is difficult or impossible to differentiate between body fluids.
2. Any unfixed tissues or organ other than intact skin from a human (living or dead): and
3. HIV-containing cell or tissue cultures, organ cultures, and HIV or HBV-containing culture medium or other solutions; and blood, organs or other tissues from experimental animals that are infected with HIV or HBV.

Hepatitis B Virus (HBV): The major mode of HBV transmission for the general population is sexual, both heterosexual and homosexual. Also important is parenteral entry by shared needles covering intravenous drug users and to a lesser extent in needle stick injuries or other exposure of individuals, usually health care workers to blood. HBV has not been found to be transmitted by casual contact, fecal-oral or airborne routes or by contaminated food or drinking water. Contact with fluids such as tears or saliva has not been shown to transmit infection. However, all body fluids should be regarded as potentially contaminated. Despite the similarities in the modes of transmission, the risk of HBV infections in health care settings far exceeds that for HIV infections.

Human Immune Deficiency Disease (HIV): The major modes of HIV transmission for the general population are essentially identical to those for HBV. HIV is caused by a virus that is transmitted in well-defined mechanisms involving the direct introduction of contaminated blood through the skin such as intravenous drug abuse, sexual contact, and cross placental transmission. AIDS transmission has not shown to occur unless the above activities occur. Ordinary social contact and ingestion of food and water have not been shown to result in virus transmission. Contact with fluids such as tears and saliva have not been shown to result in virus transmission. However, all bodily fluids should be regarded as potentially contaminated.

Exposure Determination

1. High Risk. The following are job classifications in which all employees in those job classifications may be expected to have occupational exposure:
   1. Nurses in Health Services
   2. Doctors in Health Services
   3. Campus Police
   4. Emergency Medical Service (EMS)
   5. Trainers in Athletic Department
   6. Academic Researchers working on human body fluids projects.
2. Moderate Risk Job Classifications. The following are job classifications in which some employees may have occupational exposures:
   1. Maintenance personnel in Plant Services
   2. Custodians
   3. Coaches, Assistant Coaches and Athletic Staff
   4. Laundry persons in Athletics
      
       
3. Task and Procedures Risks. The following is a list of tasks and procedures in which occupational exposure may occur.
   1. Cleaning up blood or bodily fluid spills.
   2. Rendering first aid to bleeding victims.
   3. Cardio-pulmonary resuscitation to victims.
   4. Handling contaminants, soiled/exposed materials.
   5. Disposal of/or cleaning up of sharps.

Methods of Compliance

1. Universal Precautions. Universal precautions shall be used to prevent contact with blood or other potentially infectious materials. Under circumstances in which differentiation between bodily fluid types is difficult or impossible, all body fluids shall be considered potentially infectious materials. These precautions are:
   1. Wearing of rubber or latex gloves as a precaution to prevent skin contact with blood and/or bodily fluids.
   2. Hand and skin surfaces washed immediately and thoroughly if contaminated with blood or bodily fluids.
   3. Hands washed immediately after glove removal.
   4. Use of mouthpieces, ventilation or resuscitation devices during resuscitation efforts.
   5. Precautions taken to prevent injuries caused by needles, broken glass or other sharp, potentially contaminated materials.

      Health Service Employees Additional Procedures.

   6. Precautions to prevent injuries caused by needles, scalpels and other sharp instruments used during procedures. To prevent such injuries:
      1. Needles may not be recapped, bent or broken by hand or removed from disposable syringes following use.
      2. Used syringes, needles, scalpel blades and other sharp items placed in puncture resistant containers for proper disposal.
      3. Location of puncture proof containers close to use area.

Engineering Controls

The following engineering controls will be used:

1. Employees will wash hand and skin surfaces immediately and thoroughly after removing gloves or a potential exposure incident.
2. Needles may not be recapped, bent or broken by hand or removed from disposable syringes following use.
3. Used syringes, needles, scalpel blades and other sharp instruments will be placed in puncture resistant containers.
4. Potentially contaminated materials will be placed in double sealed plastic bags, manufactured and purchased for the specific purpose of disposal of materials contaminated with blood or otherwise potential infections.
5. Mouthpieces, ventilation and resuscitation devices will be used during resuscitation efforts.
6. Gloves, rubber or latex, gowns and goggles will be worn when potential exposure to pathogens can or would be anticipated.

Work Practice Controls.

1. Health Services. Universal precautions as established for Health Services employees. See Section IV, Item A.6.

2. Plant Services. The following work practices will be utilized by all Plant Services personnel when encountering any blood or body fluid spills.
   1. Rubber or latex gloves must be worn at all times.
   2. Large spills should be diluted with a germicidal cleaner before being removed.
   3. Remove all visible material and place in plastic bags for proper disposal.
   4. After spill and all materials are picked up, clean area with a germicidal cleaner.
   5. Liquid waste may be flushed down toilets or rinsed down floor drains.
   6. Remove gloves when cleaning is completed and place gloves in an appropriate plastic bag for disposal.
   7. Wash hands thoroughly.

   If sharp objects, such as needles or potentially contaminated broken glass is found, DO NOT touch. Call you supervisor, who will assist you in acquiring a puncture resistant container for disposal. Gloves must be worn.

3. Laundry. The following work practices will be used by the Laundry personnel anytime there is a potential to encounter bloodborne pathogen exposure while laundering Athletic towels and uniforms:
   1. Rubber or latex gloves will be worn.
   2. Towels and uniforms will be handled carefully and not shaken or aired out.
   3. Use a germicidal washing detergent to wash towels and uniforms.
   4. If sharps are encountered, STOP and call you supervisor, who will assist you in acquiring a puncture resistant container.
   5. Wash hands thoroughly after handling laundry.
4. Campus Police/EMS Personnel. When responding to any emergency where blood or other body fluids are suspected and you may become EXPOSED to persons or materials, the following procedures shall be followed:
   1. Wear rubber or latex gloves.
   2. Wash immediately and thoroughly after contact.
   3. Wash hands after glove removal.
   4. CPR - use protective mouthpiece to ventilate or resuscitate during rescue effort.
   5. Use proper containers (plastic bags) when disposing of contaminated material such as bandages, needles or other soiled materials.
   6. Ensure the area is left clean. All hazardous material must be removed to proper containers. (Contact custodian to clean and wash area).
   7. Do not try to recap needles, use proper disposal container, available at Campus Police Station.
   8. Health Services has available proper disposal containers.
   9. All Campus Police and EMS equipment will be cleaned and sterilized if needed after each use.
   10. A statement, indicating proper procedure handling the above situations, shall be included in your report.
   11. Proper cleaning equipment, including germicidal cleaner will be available at Campus Police Station.
5. Athletic Department. The following work practices will be used by the Athletic Department every time there is a potential for contact with bloodborne pathogens:
   1. Wearing gloves as precaution to prevent skin contact with blood and/or bodily fluids.
   2. Hand and skin surfaces washed immediately and thoroughly if contaminated with blood or bodily fluids.
   3. Hands washed immediately after glove removal.
   4. The use of protective mouthpiece if rescue breathing is applied during CPR.
   5. Precautions taken to prevent injuries by needles, scalpels and other sharp instruments:
      1. Needles may not be recapped, bent or broken by hand or removed from disposable syringes following use.
      2. Used syringes, needles and scalpel blades shall be placed in puncture resistant containers for disposal, available in the Head Trainers Office.
   6. Use proper containers (plastic bags) when disposing of contaminated material such as bandages, needles or other soiled materials.
   7. Ensure area is left clean, hazardous material is removed to proper containers, and disinfect all equipment with a germicidal cleaner.

1. Personal protective equipment will be provided in the work environment to individuals to reduce possible exposure or contamination. The following items of personal protective equipment are available through your department:
2. Gloves -- rubber or latex.
3. Goggles.
4. Plastic bags.
5. Puncture resistant containers.

Reusable, potentially contaminated personal protective equipment will be thoroughly washed and disinfected prior to storage or reuse. Disposable equipment will be handled and disposed of in the same manner as contaminated materials.

1. An overview of the OSHA standard.
2. Medical information concerning bloodborne diseases and transmission modes.
3. Procedures which may cause an exposure.
4. Control methods and personal protective equipment.
5. Hepatitis B vaccinations.

Training will be conducted for all employees designated as covered by this plan in Section III. After the initial training, employees will receive annual training.

Hepatitis B Vaccine.

All employees who have been identified as having possible exposure to Blood borne Pathogens will be offered the Hepatitis B vaccine, at no cost to the employee.

Employees who decline the vaccine will sign a declination statement found in Appendix A.

Employees who initially decline the vaccine but who later wish to have it may then have the vaccination at no cost.

Health Services will administer the vaccination, and the Environmental and Occupational Safety Office of Plant Services will be responsible for offering the vaccination, and all associated records.

CAUTION: It should be understood that the HBV vaccination does not eliminate the employee from acquiring HBV. Employees must use universal precautions, use personal protective equipment, and follow appropriate procedures. Failure to do so may cause an individual to acquire HBV, even though they may have been vaccinated.

All employees who incur an exposure will be offered post-exposure evaluation and follow-up to include the following:

1. Documentation of the route of exposure and the circumstances related to the incident.
2. 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) for HIV/HBV infectivity.
3. Results of the testing of the source individual will be made available to the exposed employee.
4. Provide HBV and HIV serological counseling, and safe and effective post-exposure prophylaxis following the current recommendations of the U.S. Public Health Service.

1. Training records, vaccination records, and waivers will be maintained in the Environmental and Occupational Safety Office of the Plant Services Department.
2. Training records are available to employees or employee representatives upon request.
3. Medical records will include the following information:
   1. Employee's name and social security number.
   2. Employee's HBV vaccination status.
   3. Result of examinations, medical testing, and post-exposure evaluation and follow-up procedures.
   4. Health care professional's written opinion.
   5. A copy of the information provided to the health care professional.
4. Medical records will be kept confidential and maintained for at least the duration of employment plus 30 years.

Department Heads have the responsibility to assure that their personnel have received adequate training.

The Human Resources Department shall inform the Environmental and Occupational Safety Office of Plant Services of any new or reassigned employees who require adequate training.