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Blood Borne Pathogens Exposure Control Plan

CODE: JLCCA-R

Maine School Administrative District No. 31

BLOOD BORNE PATHOGENS EXPOSURE CONTROL PLAN


Purpose

The purpose of this plan is to reduce the risk of infection with Hepatitis B Virus (HBV), Human Immunodeficiency Virus (HIV), and other blood borne pathogens among employees of M.S.A.D. #31.  The plan identifies specific tasks and procedures which place employees in certain job classifications at increased risk for infection with these agents.  The plan also describes measures to be taken following an occupational exposure incident involving blood and other potentially infectious materials.  The plan also outlines work practices and precautions which, if followed carefully, can significantly reduce the risk of occupational transmission of HBV, HIV, and other blood borne pathogens to M.S.A.D. #31 employees.

Exposure Determination
OSHA requires employers to perform an exposure determination concerning which employees may incur 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.

Job Classifications

All school employees, excluding substitutes, tutors, and crossing guides.

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.

Occupational Exposure means 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.  It is recognized that employees in the following job classifications have occupational exposure:

    Job Classifications
  •  School nurse
  •  All teachers
  •  Principals and school secretaries
  •  Custodians
  •  P.E. instructors and coaches
  •  Educational technicians
  •  Maintenance staff
  • Transportation staff
IMPLEMENTATION SCHEDULE AND METHODOLOGY
OSHA requires that this plan include a schedule and method of implementation for the various requirements of the standard.  The following complies with this requirement:

Compliance Methods

I.    Precautions
      Universal precautions will be observed in this school system in order to prevent contact with blood or other potentially infectious
      materials.  All blood or other potentially infectious material will be considered infectious regardless of the perceived status of the
      source individual.  The concept of universal precautions stresses that all individuals should be assumed to be infectious for HBV, HIV,
      and other blood borne pathogens.

        Universal precautions shall be followed when employees are likely to be exposed to blood, certain other body fluids (amniotic,
        pericardial, peritoneal, pleural, synovial, cerebrospinal fluids, semen, and vaginal secretions), or any fluid visibly contaminated
        with blood.  HBV and HIB have not been documented from exposure to other bodily fluids (feces, nasal secretions, sputum, sweat,
        tears, urine, vomitus, and saliva).  Therefore, the blood borne concerns do not apply to these fluids, unless they are visibly
        contaminated with blood.  However, when employees encounter body fluids, uncontrolled, emergency circumstances in which the
        differentiation between fluid types is difficult, if not impossible, they should treat all body fluids as potentially hazardous and use
        universal precautions as defined by the following practice controls.

II.    Engineering and Work Practice Controls
       Engineering and work practice controls will be utilized to eliminate or minimize exposure to employees.  Engineering controls are
       objects which isolate or remove the blood borne pathogens from the workplace (such as sharps containers).  Work practice controls
       are measures which reduce the likelihood of exposure by altering the manner in which the task is performed (such as picking up
       broken glass with a broom and dustpan, not with hands).  When occupational exposure remains after implementation of these
       controls, personal protective equipment shall also be used.

Engineering Controls

    a.    Sharps container(s)
           There will be a hard plastic container for disposal of lances or needles.  The building administrator/designee will be responsible\
           for the storage of this container which will be disposed of in the school's household trash as long as it is sealed and labeled as
            contaminated.

    b.    Plastic bags
           A supply of trash bags for collecting contaminated waste will be available for use by the school employees.  All trash which might
           contain blood stained items such as bathroom waste with sanitary napkins and tampons and waste resulting from first aid
           treatment needs to be doubled-bagged by the attending school employee as soon as possible after the collection of it and prior to
           the transportation of it.

Work Controls

    a.    Hand washing
           Hand washing constitutes the single most important control.  Hand washing facilities are available to the employees who incur
           exposure to blood or other potentially infectious materials to skin surfaces other than hands, wash the affected area with soap
           and water.  For exposure of potentially infectious materials to mucous membranes, employees shall flush the affected membranes
           with water immediately or as soon as feasible for 10-15 minutes.

            Antiseptic hand cleansers and paper towels or antiseptic towelettes shall be placed in areas where a sink is not readily available.
            Employees will wash hands with soap and water as soon as is feasible after using antiseptic hand cleansers or towelettes.

    b.    Oral/Mucosal inoculation
            Employees shall not eat, drink, smoke, or apply cosmetics oxlip balm or handle contact lenses in the immediate work area where
            there is a likelihood of occupational exposure.

     c.    Surface Contamination
            Hard surfaces, equipment, and small items which are not disposable will be disinfected to prevent exposure to others. 
            Reusable shared equipment of items (large and small) which may be contaminated with blood or other potentially infectious
            materials shall be examined prior to use and disinfected as soon as feasible after contamination.  For example:  first aid items -
            soaking tweezers and scissors in a bleach solution.  Athletic equipment - cleaning bloodied chinstraps.

The administrator/designee will be responsible for examining and maintaining the above controls.

III.    Personal Protective Equipment


M.S.A.D. #31 shall provide appropriate personal protective equipment (PPE) to all employees who have an occupational exposure to blood or other potentially infectious materials.  Employees shall be instructed in the circumstances and techniques for proper use and method of disposal or reuse of equipment.  The cost of this equipment shall be borne by the School Department.

Gloves in appropriate sizes shall be readily accessible at the work site.  Suitable alternatives will be provided to employees who are allergic to the gloves normally provided.

Gloves shall be worn when:

    1.     It can be reasonably anticipated that employee's hands will come into contact with blood or other potentially infectious materials,
            mucous membranes, or non-intact skin.
    2.     Handling items or surfaces soiled with blood or other potentially infectious materials.
    3.     It can be reasonably anticipated that the employee will receive a contaminated sharp stick.
    4.     Responding to or providing first aid treatment.
    5.     Emptying trash and cleaning areas according to numbers 1, 2, and 3 above.


Disposable (single use) gloves, such as surgical or examination gloves, shall be replaced as soon as practical when contaminated or as soon as feasible if they are torn, punctured, or when their ability to function as a barrier is compromised.  Disposable gloves shall be changed between each student contact, and shall not be washed or decontaminated for reuse.

Rubber utility gloves may be decontaminated for reuse if the integrity of the gloves is not compromised.  They must be discarded if they are cracked, peeled, torn, punctured, or exhibit other signs of deterioration or when their ability to function as a barrier is compromised.

Masks in combination with eye protection devices and/or protective body clothing are required to be worn when splashed, sprays, splatter, or droplets of blood or other potentially infectious materials may be generated on nose, mouth, eye, non-intact skin, or clothing contamination can reasonably be anticipated.

School situations which would require such protection may include the following:

Example:  The catherization of a student with bloodied urine.

IV.    Housekeeping

M.S.A.D. #31 shall ensure that all fixed work sites are maintained in a clean and sanitary condition.  Contaminated work surfaces shall be decontaminated with an approved disinfectant.  All contaminated work surfaces will be decontaminated with approved disinfectant as provided by the school after completion of procedures and immediately or as soon as feasible after any spill of blood or other potentially infectious materials, as well as at the end of the work day if the surface may have become contaminated since the last cleaning.

The school system's buildings will be cleaned and decontaminated according to the following schedule:
                Bathroom, kitchen, and cafeteria daily
                Trash emptied daily
                Floors washed daily
                Bathroom floors and all carpets sanitized annually

All bins, pails, cans, and similar receptacles as well as protective coverings for equipment intended for reuse which have a reasonable likelihood of being contaminated with blood or other potentially infectious materials shall be inspected daily and decontaminated as soon as possible after contamination by the building administrator/designee.

Sharps (glass, windows, plastics, and metal pieces) that are contaminated with blood or other potentially infectious materials shall not be stored or processed in a manner that requires employees to reach by hand into the waste containers where these sharps are placed.

Contaminated broken sharps must be removed by mechanical means only (e.g. brush and dustpan, tongs, or forceps) and discarded as soon as is feasible in containers that are:

    1. Closable
    2. Puncture resistant
    3. Leak proof on sides and bottom
    4. Identified as contaminated

During use, containers for contaminated sharps shall be easily accessible to employees.  When moving containers of sharps from the area of use, containers shall be closed immediately prior to removal or replacement to prevent spillage or protrusion of contents during handling, storage, transport, or shipping.  Reusable containers shall not be opened, emptied, or cleaned manually or in any other manner which would expose employees to the risk of cuts or punctures.

Contaminated disposal protective equipment shall be bagged using the red trash bags before disposal into regular trash.

V.    Contaminated Laundry

Contaminated laundry includes linen, uniforms, clothing, or other articles which have been soiled or are likely to have been soiled with blood or other potentially infectious materials, or may contain sharp objects such as needles or broken glass.

Contaminated laundry should be handled as little as possible.  In general, it should be bagged as soon as it is feasible and should not be sorted or rinsed at work.  M.S.A.D. #31 will expect its employees to have in his/her possession a change of clothing; however, one size fits all/an all purpose suit per building will be provided should his/her clothing become soiled with blood or other potentially infectious materials.

If an employee has contact with contaminated laundry, protective gloves shall be worn.

All contaminated laundry shall be transported to a secondary facility so designated by the school for laundering.

HBV VACCINATION PLAN

The School Department shall make the Hepatitis B vaccination series available to all employees who have occupational exposure, and post-exposure evaluation and follow-up to all employees who have had an exposure incident.  The vaccination and follow-up procedures shall be made available at no direct cost to the employee through the school nurse.  All procedures shall be given according to standard medical practice.  All laboratory tests shall be performed by an accredited laboratory.

Hepatitis B vaccination shall be made available to employees after required training is complete, and within 10 working days of initial assignment to all employees who have occupational exposure unless:

    1.     The employee has previously received the complete Hepatitis B vaccination series (proof required);
    2.     Antibody testing has revealed that the employee is immune (done on own); or
    3.     The vaccine is contraindicated for medical reasons.

If a routine booster dose of Hepatitis V vaccine is recommended by the Center for Disease Control at a future date, such booster dose(s) shall be made available in accordance with this plan.

If an employee chooses not to receive HBV vaccination, the employee must sign a letter of declination.  Employees who initially decline vaccination may request it at any future date, if they are still covered by this exposure control plan.  Any employee who has not received the vaccine but who is exposed may received the vaccine with post-exposure evaluation and follow-up procedure as outlined below.

POST EXPOSURE AND FOLLOW-UP

An exposure incident is defined as a specific eye, mouth, other mucous membrane, non-intact skin, or parenteral contact with blood or other potentially infectious material that results from the performance of the employee's duties.  In the event of an exposure, the employee will have the opportunity, at no cost to the employee through Work Med, to receive a confidential medical evaluation immediately following the incident.  The medical evaluation and follow-up will consist of the following elements:

    1.     Documentation of the routes of exposure.
    2.     Documentation of infectious agent(s) known to be present in blood or other body fluid(s) to which the employee was exposed.
            A good faith attempt will be made to obtain consent from the source patient to collect and test his/her blood for the presence
            of HIV and HBV.  If an employer learns of HBV or HIV status of the source individual, the employee shall be informed of the Maine
            State Law as it concerns medical confidentiality in general, and the disclosure of the identity and infectious status of the source
            individual.  M.S.A.D. #31 and the employee both bear liability should the source individual's confidentiality be breached.
    3.     The exposed employee will be offered serologic HIV/HBV testing in the manner recommended by the Center for Disease Control
            as soon as possible after the incident and the opportunity for retesting as recommended by the CDD.  Testing will be performed
            at an accredited laboratory at no cost to the employee.
    4.     Pretest and post-test counseling shall be provided in conjunction with HIV serologic testing as required by Maine State Law.
    5.     Post exposure HIV testing, prophylaxis will be done when medically indicated by the school's physician at no cost to the employee.

The health care professional's written opinion of the affected employee shall be obtained within 15 days of the completion of the evaluation.  One copy of the written opinion shall be provided to superintendent/designee and the employee upon request.  Findings or diagnoses shall remain confidential and shall not be included in the written report.

INFORMATION AND TRAINING

All employees shall participate in a training program as follows:

    1.     At the time of initial assignment to tasks where occupational exposure may take place, or
    2.     At the time of the implementation of this Exposure Control Plan, and
    3.     At least annually thereafter.

M.S.A.D. #31 shall provide additional training when changes such as modification of tasks or procedures or institution of new tasks or procedures affect the employee's occupational exposure.  The additional training may be limited to addressing the new exposures created.

Material appropriate in content and vocabulary to educational level, literacy, and language of employees shall be used.

Training for employees will include an explanation of the following:

    1.     The OSHA standard for blood borne pathogens.
    2.     Epidemiology and symptomatology of blood borne diseases.
    3.     Modes of transmission of blood born pathogens.
    4.     This Exposure Control Plan, i.e., points of the plan, lines of responsibility, how the plan will be implemented, etc.
    5.     Procedures which might cause exposure to blood or other potentially infectious materials.
    6.     Control methods which will be used to control exposure to blood or other potentially infectious materials.
    7.     Personal protective equipment available and who should be contacted concerning exposure.
    8.     Post exposure evaluation and follow-up.
    9.     Hepatitis B vaccine program.

RECORD KEEPING

M.S.A.D. #31 shall establish and maintain an accurate record for each employee with occupational exposure in accordance with OSHA 29 CFR 1910.20.

The record shall include:

    1.     The name, job title/classification, department, and social security number of the employee.
    2.     A copy of the employee's Hepatitis B vaccination status including the dates of all Hepatitis B vaccinations and any medical records
            relative to the employee's ability to receive vaccination, such as the Hepatitis B Declination Statement or statement of medical
            contradiction to vaccine.
    3.     A copy of the written opinion issued by the medical practitioner subsequent to an exposure incident.
    4.     The Employee's Report of Exposure.

Employee medical records shall be kept confidential and shall not be disclosed or reported without the employee's express written consent to any person within or outside the workplace except as required by this section or as may be required by law, including the Workers Compensation statues.

M.S.A.D. #31 shall maintain the employee medical records for at least the duration of employment plus 30 years in accordance with OSHA 29 CFR 1910.20.

Training Records

Training records shall include the following information:

    1.     The dates of the training sessions.
    2.     The contents or summary of the training sessions.
    3.     The names and qualifications of persons conduction the training.
    4.     The names and job titles of all persons attending the training sessions.

Training records shall be maintained by the School Department for three years from the date on which the training occurred.

Record Availability


Employee medical records and training records shall be made available upon request to the Assistant Secretary of Labor for Occupational Safety and Health or the Director of the National Institute for Occupation Safety and Health or their designated representative(s) for examination and copying.

Employee training records shall be provided upon request for examination and copying to employees or to their designated representative(s).

Employee medical records shall be provided upon request for examination and copying to the subject employee and to anyone having the written consent of the subject employee.

Plan Review

The Exposure Control Plan shall be reviewed and updated at least annually and whenever necessary to reflect new or modified tasks and procedures which affect occupational exposure and to reflect new or revised employee positions with occupational exposure.


First Reading:        05/16/2001
Second Reading:    06/20/2001
Adopted:               06/20/2001