This is West Liberty University’s Bloodborne Pathogens Program. It meets all OSHA requirements and applies to all our work operations.
The health and safety specialist will be responsible for overall direction of the Safety Program.
Introduction
Our University has adopted this program in order to implement 29 CFR 1910.1030, the OSHA standard regulating occupational exposure to blood or other potentially infectious materials (Bloodborne Pathogens). Bloodborne Pathogens are pathogenic microorganisms in human blood that can cause disease in humans. They include the Hepatitis B virus (HBV) and the human immunodeficiency virus (HIV). HIV is the virus that causes AIDS (Acquired Immunodeficiency Syndrome). HBV causes Hepatitis B, a serious liver disease.
Occupational transmission of HIV is relatively rare, but the lethal nature of HIV requires us to take every possible measure to prevent exposure. The purpose of a program is to limit occupational exposure to blood and other potentially infectious materials because any exposure could result in transmission of Bloodborne Pathogens that could lead to disease or death.
The hazard of exposure can be minimized or eliminated by the use of a combination of engineering and work practice controls, personal protective clothing and equipment, training, medical surveillance, hepatitis B vaccination, signs and labels, and other provisions.
This Written Plan will 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. A copy of the plan must be accessible to employees and made available to OSHA and NIOSH representatives in accordance with applicable legal and constitutional provisions.
Scope
This program covers anyone who, as the result of performing the duties of their job, could be reasonably anticipated to face contact with blood or other potentially infectious materials (OPIM). ‘Good Samaritan’ acts such as assisting a co-worker with a nosebleed would not be considered occupational exposure.
Potentially infectious materials include the following human body fluids: semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva in dental procedures, any body fluid that is visibly contaminated with blood, and all body fluids in situations where it is difficult or impossible to differentiate between body fluids.
They also include any unfixed tissue or organ (other than intact skin) from a human (living or dead); and human immunodeficiency virus (HIV)-containing cell or tissue cultures, organ cultures, and HIV or HBV-containing culture medium or other solutions; as well as blood, organs or other tissues from experimental animals infected with HIV or HBV.
Infections from these materials are not spread by casual contact in the workplace. However, precautions need to be taken against contact with them.
Because there is no population that is risk free for HIV or HBV infectivity, any person who has occupational exposure to blood or other potentially infectious material is included within the scope of the OSHA standard.
It should also be noted that the following are included within the coverage of the OSHA standard if there is occupational exposure to:
- Part-time, temporary, and health care workers known as ‘per diem’ employees.
- Employees trained in first aid and designated by the employer as responsible for rendering medical assistance as part of his/her job duties.
Exposure Determination
As the result of an ‘exposure determination’ which the OSHA standard requires, this Exposure Control Plan has identified and listed those jobs, tasks and procedures in which occupational exposure may occur while at work. Persons holding those jobs will receive the training, protective equipment, vaccination, and other matters required by the OSHA standard. Employees will be individually advised by supervision of the requirements that apply to them.
For OSHA purposes, the ‘exposure determination’ is made without regard to the use of personal protective equipment. We will continue to review exposure determinations and make additions to and deletions from the list as appropriate.
Control Methods
This Exposure Control Plan includes a combination of engineering and work practice controls as well as Personal Protective Equipment requirements.
The basic rule of exposure control known as ‘universal precautions’ must be observed. It requires that, in those situations where differentiation between body fluid types is difficult or impossible, all body fluids shall be considered potentially infectious materials.
An engineering control is the use of available technology and devices to isolate or remove hazards from the worker. The engineering controls for this OSHA standard include but are not limited to: puncture-resistant sharps containers, splashguards, and self-sheathing needles. The engineering controls that we have put in place will be examined and maintained or replaced on a regular basis to ensure their effectiveness.
Personal protective equipment (PPE) controls are covered in this plan. Work practice controls are alterations in the manner in which a task is performed in an effort to reduce the likelihood of a person’s exposure to blood or other potentially infectious materials (OPIM).
PPE rules include:
- There are hand-washing facilities readily accessible to all affected people and all workstations. Hands and other affected skin areas shall be washed with soap and water after removing gloves or other personal protective equipment and as soon as possible after contact with body fluids or OPIM.
- All personal protective equipment (PPE) should be removed immediately, or as soon as possible upon leaving the work area, and placed in an appropriately designated area or container for storage, washing, decontamination, or disposal.
- Used needles and other sharps shall not be sheared, bent, broken, recapped, or reheated by hand.
- All procedures involving blood or other potentially infectious material shall be performed in such a manner as to minimize splashing and spraying.
Sharps Injury Log
The employer shall establish and maintain a sharps injury log for the recording of injuries from contaminated sharps. The information in the sharps injury log shall be recorded and maintained in such manner as to protect the confidentiality of the injured employee (29 CFR 1910.1030(h)(5)(i)(A) ).
The requirement to establish and maintain a sharps injury log shall apply to any employer who is required to maintain a log of occupational injuries and illnesses under the Recordkeeping rule.
This Sharps Injury log is separate from the log of injuries and illnesses kept under Part 1904. Employers who are already partially exempt from Part 1904 recordkeeping requirements (See 29 CFR 1904.1 and 1904.2) are not required to keep a sharps injury log, but are encouraged to do so.
The sharps injury log shall be maintained for the period required by 29 CFR 1904.6.
The log must include the type and brand of device involved in the incident, the department or work area where the exposure incident occurred and an explanation of how the incident occurred so that the intended evaluation of risk and device effectiveness can be accomplished. More information may be included; however, the confidentiality of the injured person must be maintained throughout the process. If the nature of the incident is such that determining the type and brand of the device would increase the potential for additional exposure (e.g., housekeeper stuck through trash bag), the type/brand may be recorded as ‘Unknown’.
The purpose of the log is to aid in the evaluation of devices being used in the workplace and to quickly identify problem areas at the University. Thus, it should be reviewed regularly and during the review and update of the Exposure Control Plan.
If the data is made available to other parties (e.g., supervisors, safety committees, employees, employee representatives), any information that directly identifies a person or any information that could reasonably be used to identify the person must be withheld. Logs must be saved for at least five years following the end of the calendar year that they cover.
Exposure Incidents
The new recordkeeping rule effective January 1, 2002, requires (29 CFR 1904.8) that all employers, whether or not they are covered by the bloodborne pathogens standard, record all work-related needle sticks and cuts from sharp objects that are contaminated with another person’s blood or OPIM on the 300 Log as an injury. The person’s name must not be entered on the 300 Log. (See the requirements for privacy cases in paragraphs 1904.29(b)(6) – (b)(9) ).
If the person is later diagnosed with an infectious bloodborne disease, the identity of the disease must be entered and the classification must be changed to an illness. If a person is splashed or exposed to blood or OPIM without being cut or punctured, the incident must be recorded on the OSHA 300, if it results in the diagnosis of a bloodborne illness or it meets one or more of the recording criteria in 29 CFR 1904.7.
Work Rules
- Eating, drinking, smoking, applying cosmetics or lip balm, and handling contact lenses are prohibited in work areas where there is a reasonable likelihood of occupational exposure.
- Food and drink shall not be kept in refrigerators, freezers, shelves, and cabinets or on countertops or bench tops where blood or other potentially infectious materials are present.
- All procedures involving blood or other potentially infectious materials shall be performed in such a manner as to minimize splashing, spraying, spattering, and generation of droplets of those substances.
- Specimens of blood or other potentially infectious materials shall be placed in a container, which prevents leakage during collection, handling, processing, storage, transport, or shipping. We will also observe the following:
- Equipment which may become contaminated with blood or other potentially infectious material will be examined prior to servicing or shipping and be decontaminated as necessary, unless it can be demonstrated that decontamination of such equipment or portions of such equipment is not feasible.
The container for storage transport or shipping shall be labeled or color-coded in accordance with the rules for labels and signs (‘Communication of Hazards’). It also must be closed prior to being stored, transported or shipped. When Universal Precautions are used in the handling of all specimens, the labeling/color-coding of specimens is not necessary provided containers are recognizable as containing specimens. This exemption only applies while such specimens/containers remain within the facility. Labeling or color-coding is required when such specimens/containers leave the facility.
- If outside contamination of the primary container occurs, the primary container shall be placed within a second container which prevents leakage during handling, processing, storage, transport, or shipping and will be labeled or color-coded.
- If the specimen could puncture the primary container, the primary container shall be placed within a secondary container which is puncture-resistant in addition to the above characteristics.
- A readily observable label will be attached to the equipment. It will also state which portions remain contaminated.
- The above information shall be conveyed to all affected employees, the servicing representative, and/or the manufacturer, as appropriate, prior to handling, servicing, or shipping so that appropriate precautions will be taken.
Personal Protective Equipment Rules
The Exposure Control Plan requires the use of personal protective equipment (PPE). PPE is specialized clothing or equipment used by a person to protect themselves from direct exposure to blood or other potentially infectious materials. For purposes of this OSHA standard, PPE includes but is not limited to: gloves; gowns; laboratory coats; fluid-resistant aprons; head and foot coverings; face shields or masks and eye protection; mouthpieces; resuscitation bags; pocket masks; or other ventilation devices. They are to be used, as appropriate, when there is a potential for exposure to blood or other potentially infectious materials. Many such items are accompanied by written warnings, directions or instructions.
Those items of PPE that are appropriate for the work done are available in a variety of sizes and readily accessible. Those persons required to wear them will be individually advised by their supervisor. The University will provide for the cleaning, laundering or disposal of PPE and will repair or replace it as needed in order to maintain its effectiveness.
Surgical or examination gloves, however, must be replaced when visibly soiled. They will not be washed or disinfected for re-use. Utility gloves, on the other hand, may be cleaned and disinfected for re-use if they show no signs of deterioration.
Any employee who has not been advised by his/her supervisor that any such item of PPE is required but who desires to wear it while at work may obtain the desired PPE by requesting it from their immediate supervisor.
The following personal protective equipment rules apply:
- The University will provide at no cost to any employee, appropriate personal protective equipment such as, but not limited to, gloves, gowns, laboratory coats, face shields or masks and eye protection, and mouthpieces, resuscitation bags, pocket masks, or other ventilation devices.
- Personal protective equipment will be considered ‘appropriate’ only if it does not permit blood or other potentially infectious material to pass through, to, or reach the employees work clothes, street clothes, undergarments, 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.
- Each supervisor must ensure that his/her subordinate employees use appropriate personal protective equipment unless that employee temporarily and briefly declines to use personal protective equipment when, under rare and extraordinary circumstances, it is the employee’s professional judgment that in the specific instance at issue, its use would have prevented the delivery of health care or public safety services or would have posed an increased hazard to the safety of the worker or co-worker. When the employee makes this judgment, the circumstances shall be investigated and documented in order to determine whether changes can be instituted to prevent such occurrences in the future.
- Appropriate personal protective equipment in the appropriate size will be readily accessible at the worksite or will be issued to the employee who is to use it.
- The University will clean, launder, and dispose of all required personal protective equipment and shall repair or replace it as needed in order to maintain its effectiveness at no cost to any employee.
- If a garment(s) is penetrated by blood or other potentially infectious materials, the garment(s) will be removed immediately or as soon as feasible.
- All personal protective equipment will be removed prior to leaving the work area.
- When personal protective equipment is removed, it will be placed in an appropriately designated area or container for storage, washing, decontamination or disposal.
- Masks in combination with eye protection devices, such as goggles or glasses with solid side shields, or chin-length face shields, will 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 be reasonably anticipated.
- Appropriate protective clothing such as, but not limited to, gowns, aprons, lab coats, clinic jackets, or similar outer garments will be worn in occupational exposure situations. The type and characteristics will depend upon the task and degree of exposure anticipated.
- Surgical caps or hoods and/or shoe covers or boots will be worn in instances when gross contamination can reasonably be anticipated (e.g., autopsies, orthopedic surgery).
- Disposable gloves will be worn for procedures where body fluids are handled. The use of gloves is particularly important in the following circumstances: If the worker has cuts, abraded skin, chapped hands, dermatitis, or similar conditions, and whenever it can be reasonably anticipated that the employee may have hand contact with blood, other potentially infectious materials, mucous membranes, and non-intact skin; and when handling or touching contaminated items or surfaces.
The following cleaning and decontaminating procedures will be followed where body fluids or blood are present:
- Gloves must be of appropriate material, usually intact latex or intact vinyl, of appropriate quality for the procedures performed, and of appropriate size for the person who is to wear them. Surgical or examination gloves may not be reused.
- General-purpose utility gloves may be decontaminated and reused.
- General-purpose gloves will not be used if they are peeling, cracked, or discolored or if they have punctures, tears, or other evidence of deterioration.
- The use of masks and protective eyewear or face shields is required when contamination of mucous membranes (eyes, mouth, or nose) with body fluids may occur through splashes or aerosolization of these fluids (such as surgical or dental procedures).
Vaccination, Post Evaluation, and Follow-Up
The Hepatitis B vaccine and vaccination series and post-exposure evaluation and follow-up, including prophylaxis, will be made available at an accredited laboratory at no cost, to all employees whose jobs involve the risk of direct contact with blood or other potentially infectious material. Each such employee will be vaccinated unless he/she specifically declines. An employee who declines the vaccination must execute a Hepatitis B Vaccination Declination Form attached to this plan. Vaccination will also be available under the same circumstances to all employees who have had an exposure incident.
Vaccinations shall be given at a reasonable time and placed under the supervision of a licensed health care professional according to standard medical practices and the then current recommendations of the U.S. Public Health Service. The healthcare professional responsible for the employee’s Hepatitis B vaccination shall be provided with a copy of the OSHA Bloodborne Pathogens standard.
For those employees who have occupational exposure, the vaccinations will be given after the employee has received the training and education that is provided for in the Exposure Control Plan but within ten days of initial assignment unless (a) the employee has previously received the complete Hepatitis B vaccination series, (b) antibody testing has revealed that the employee is immune, or (c) the vaccine is contraindicated for medical reasons.
In no case will participation in a prescreening program be made a prerequisite for receiving hepatitis B vaccination. If an employee initially declines Hepatitis B vaccination but at a later date while still covered under the OSHA standard, decides to accept the vaccination, hepatitis B vaccination will be made available at that time. Those employees who decline to accept the hepatitis B vaccination must sign a statement to that effect.
If a routine booster dose(s) of hepatitis B vaccine is recommended by the U.S. Public Health Service at a future date, such booster dose(s) will be made available under the same circumstances stated above.
In the event of an exposure incident, a confidential medical evaluation and follow-up of the incident will be made available to the employee involved. It will include documentation of the route of exposure, HBV and HIV status of the source patient(s), if known and if permitted by law, and the circumstances under which the exposure occurred. The source patient(s) shall be notified of the incident and an attempt will be made to obtain consent to collect and test the source’s blood in order to determine the presence of HIV and/or HBV infection. A blood sample shall be collected from the exposed worker as soon as possible after the exposure incident for determination of HIV and HBV status.
The rules for handling exposure incidents are found in the OSHA standard, 29 C.F.R. 1910.1030(f)(3)-(6). They include the following:
- Immediately following a report of an exposure incident, a confidential medical evaluation and follow-up will be made.
- Documentation of the route(s) of exposure, and the circumstances under which the exposure incident occurred.
- Identification and documentation of the source individual unless it can be established that identification is infeasible or prohibited by state or local law.
- The source individual’s blood shall be tested as soon as feasible and after consent is obtained in order to determine HBV and HIV infectivity. If consent is not obtained, it must be established that legally required consent cannot be obtained. When the source individual’s consent is not required by law, the source individual’s blood, if available, shall be tested and the results documented.
- When the source individual is already known to be infected with HBV or HIV, testing for the source individual’s known HBV or HIV status need not be repeated.
- Results of the source individuals testing will be made available to the exposed employee and the employee shall be informed of applicable laws and regulations concerning disclosure of the identity and infectious status of the source individual.
- The exposed employee’s blood will be collected and tested as soon as feasible after consent is obtained.
- If the employee consents to baseline blood collection, but does not give consent at that time for HIV serologic testing, the sample shall be preserved for at least 90 days. If, within 90 days of the exposure incident, the employee elects to have the baseline sample tested, such testing shall be done as soon as feasible.
- The healthcare professional evaluating the employee after an exposure incident will be provided with:
- A copy of the OSHA Bloodborne Pathogens standard.
- A description of the exposed employee’s duties as they relate to the exposure incident.
- Documentation of the route(s) of exposure and circumstances under which exposure occurred.
- Results of the source individual’s blood testing.
- All medical records relevant to the appropriate treatment of the employee including vaccination status which it is our responsibility to maintain.
- A copy of the evaluating healthcare professional’s written opinion will be obtained within 15 days of the completion of the evaluation.
The healthcare professional’s written opinion for Hepatitis B vaccination will be limited to whether Hepatitis B vaccination is indicated for an employee, and if the employee has received such vaccination. The healthcare professional’s written opinion for post-exposure evaluation and follow-up will be limited to information that the employee has been informed of the results of the evaluation and the employee will be told about any medical conditions resulting from exposure to blood or other potentially infectious materials which require further evaluation or treatment. All other finding or diagnoses shall remain confidential and shall not be included in the written report.
Medical records required by the OSHA Bloodborne Pathogens standard will be maintained in accordance with the requirements of the OSHA standard on Access to Employee Exposure and Medical Records, 29 C.F.R. 1910.1020.
Waste Disposal
Contaminated needles and other contaminated sharps will not be bent, recapped, or removed except where required by a specific medical procedure or in those situations where it can be demonstrated that there is no feasible alternative. In such cases recapping or needle removal must be accomplished through the use of a mechanical device or a one-handed technique. Shearing or breaking of contaminated needles is prohibited.
Immediately after use, contaminated reusable sharps will be placed in appropriate containers until properly reprocessed. The containers for reusable sharps, as well as those that are to be discarded, will be:
- Puncture resistant
- Labeled or color-coded
- Leak proof on the sides and bottom
Reusable sharps that are contaminated with blood or other potentially infectious materials will not be stored or processed in a manner that requires employees to reach by hand into the containers where those sharps have been placed. Disposal of all infectious waste will be in accordance with applicable Federal, State, and local regulations.
All infectious waste will be placed in closable, leak proof containers or bags that are color-coded, labeled and tagged. Disposal syringes, needles, scalpel blades and other sharp items will be placed in puncture-resistant containers for disposal. Puncture-resistant sharps containers will be easily accessible to workers and located in area where they are commonly used.
Double-bagging prior to handling, storing, and/or transporting infectious waste is necessary if the outside of a bag is contaminated with blood or other potentially infectious materials. Lab specimens of body fluids will be transported in a container that will prevent leaking and disposed of in accordance with institutional policies and regulatory requirements.
Regulated waste will be placed in containers which are:
- Closable,
- Constructed to contain all contents and prevent leakage of fluids during handling, storage, transport or shipping,
- Labeled or color-coded, and
- Closed prior to removal to prevent spillage or protrusion of contents during handling, storage, transport, or shipping.
Communication of Hazards
Warning labels or tags that comply with 29 C.F.R. 1910.145(f) must be used to identify the presence of an actual or potential biological hazard. They shall be affixed to containers of regulated waste, refrigerators and freezers containing blood or other potentially infectious material; and other containers used to store, transport or ship blood or other potentially infectious materials, except as provided otherwise in this part of our Exposure Control Plan.
The labels will contain the word ‘BIOHAZARD‘ and the biological hazard symbol shown in this plan.
- The labels will be fluorescent orange or orange-red or predominantly so, with lettering or symbols in a contrasting color.
- Containers of blood, blood components, or blood products that are labeled as to their contents and have been released for transfusion or other clinical use are exempted for these labeling requirements.
- Individual containers of blood or other potentially infectious materials that are placed in a labeled container during storage, transport, shipment or disposal are exempted from the labeling requirements.
- Labels required for contaminated equipment will be in accordance with this part and shall also state which portions of the equipment remain contaminated.
- Regulated waste that has been decontaminated need not be labeled or color-coded.
- The word and message must be understandable to all employees who may be exposed to the identified hazard.
- Labels/tags shall be an integral part of the container or affixed as close as feasible to the container by string, wire, or adhesive or other method that prevents their loss or unintentional removal.
- Red bags or red containers may be substituted for labels.
- All employees shall be informed of the meaning of the various labels, tags, and the color-coding system.
Housekeeping Practices
- All work areas must be maintained in a clean and sanitary condition at all times.
- Housekeeping workers must wear appropriate PPE including general-purpose utility gloves during all cleaning of blood or other potentially infectious materials and during decontaminating procedures.
- Initial clean-up of blood or other potentially infectious materials will be followed with the use of an approved hospital disinfectant chemical germicide that is tuberculocidal or a solution of 5.25 percent sodium hypo chlorite (household bleach) diluted between 1:10 and 1:100 with water.
- Equipment contaminated with blood or other potentially infectious material will be checked routinely and decontaminated if possible prior to servicing or shipping.
- All equipment and environmental and working surface will be cleaned and decontaminated after contact with blood or other potentially infectious materials.
- Contaminated work surfaces will be decontaminated with an appropriate disinfectant after completion of procedures; immediately or as soon as feasible when surfaces are overtly contaminated or after any spill of blood or other potentially infectious materials; and at the end of the work shift if the surface may have become contaminated since the last cleaning.
- Protective coverings, such as plastic wrap, aluminum foil, or imperviously-backed absorbent paper used to cover equipment and environmental surfaces, shall be removed and replaced as soon as feasible when they become overtly contaminated or at the end of the work shift if they may have become contaminated during the shift.
- All bins, pails, cans and similar receptacles intended for reuse which have a reasonable likelihood for becoming contaminated with blood or other potentially infectious materials will be inspected and decontaminated on a regularly scheduled basis and cleaned and decontaminated immediately or as soon as feasible upon visible contamination.
- Broken glassware, which may be contaminated, will not be picked up directly with the hands. It shall be cleaned up using mechanical means, such as brush and dustpan, tongs, or forceps.
Laundry Practices
- Contaminated laundry shall be handled as little as possible with a minimum of agitation.
- Contaminated laundry will be bagged or containerized at the location where it was used and shall not be sorted or rinsed in the location of use.
- Contaminated laundry will be placed and transported in bags or containers and labeled or color-coded. When Universal Precautions are used in the handling of all soiled laundry, alternative labeling or color-coding is sufficient if it permits all employees to recognize the containers as requiring compliance with Universal Precautions.
- Whenever contaminated laundry is wet and presents a reasonable likelihood of soak-through of, or leakage from, the bag or container, the laundry will be placed and transported in bags or containers, which prevent soak-through and/or leakage of fluids to the exterior.
- Employees who have contact with contaminated laundry must wear protective gloves and other appropriate personal protective equipment.
- When contaminated laundry is shipped off-site to a second facility which does not utilize Universal Precautions in the handling of all laundry, the facility generating the contaminated laundry must place it in bags or containers which are labeled or color-coded.
- The material for the bags or containers used in laundry collection must prevent soak-through or leakage of fluids to the exterior, if the contaminated laundry is wet and presents a reasonable likelihood of soak-through or leakage. Not all contaminated laundry must be placed in such bags and containers only laundry wet enough to leak or soak through and expose workers handling the bags/containers to blood or OPIM.
- Employees having direct contact with contaminated laundry must wear protective gloves and any other appropriate personal protective equipment, in order to prevent or reduce contact exposure to blood or OPIM. Any other personal protective equipment required must be determined on a case-by-case basis.
- The laundry workers must wear protective gloves and other appropriate personal protective equipment to prevent exposure to blood or other potentially infectious material during handling and sorting of linen.
- Laundry that is contaminated with blood or other potentially infectious materials or that may contain contaminated needles or sharps will be treated as if it were HBV/HIV infectious and handled as little as possible with a minimum of agitation.
- Contaminated laundry will be bagged at the location where it was used and shall not be sorted or rinsed in patient areas.
- Contaminated laundry shall be placed and transported in bags that are labeled or color coded and that prevent liquid seepage if such a potential exists.
Training and Education of Employees
All employees with occupational exposure must participate in a training program which will be provided at no cost to affected employees during normal working hours. The training will be provided at the time of initial assignment to tasks where occupational exposure may take place and at least annually thereafter.
For employees who have received training on bloodborne pathogens in the year preceding the effective date of the OSHA standard, only training with respect to the provisions of the standard which were not included need be provided. Annual training for all employees will be provided within one year of their previous training.
Additional training will be provided 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 will be used.
The Training program will contain the following:
- An accessible copy of the regulatory text of the OSHA bloodborne pathogens standard and an explanation of its contents.
- A general explanation of the epidemiology and symptoms of bloodborne diseases.
- An explanation of the modes of transmissions of bloodborne pathogens.
- An explanation of our Exposure Control Plan and the means by which the employee can obtain a copy.
- An explanation of the appropriate methods for recognizing tasks and other activities that may involve exposure to blood and other potentially infectious materials.
- An explanation of the use and limitations of methods that will prevent or reduce exposure including appropriate engineering controls, work practices, and personal protective equipment.
- Information on the types, proper use, location, removal, handling, decontamination and disposal of personal protective equipment.
- An explanation of the basis for selection of personal protective equipment.
- Information on the Hepatitis B vaccine, including information on its efficacy, safety, method of administration, the benefits of being vaccinated, and that the vaccine and vaccination will be offered free of charge.
- Information on the appropriate actions to take and person to contact in an emergency involving blood or other potentially infectious materials.
- An explanation of the procedure to follow if an exposure incident occurs, including the method of reporting the incident and the medical follow-up that will be made available.
- Information on the post-exposure evaluation and follow-up that we are required to provide for the employee following an exposure incident.
- An explanation of the signs and labels and/or color coding required by the OSHA bloodborne pathogens standard.
- An opportunity for interactive questions and answers with the person conducting the training session.
- The person conducting the training will be knowledgeable in the subject matter covered by the elements contained in the training program as it relates to the particular work place that the training will address.
- Training records will be maintained for three years from the date on which the training occurred and will include the following:
- Dates of training sessions
- Contents or summary of training program, including the trainers name and qualifications
- Job titles and names of all persons attending the training session
Recordkeeping
- An accurate record of each worker’s reported exposure incident to blood or other potentially infectious materials must be established and maintained in accordance with applicable OSHA recordkeeping regulations. Such records will be kept confidential and not be disclosed or reported to any person within or outside the workplace without the employee’s express written consent except as may be required by law or OSHA regulation.
- Needle stick injuries will be included on the OSHA 300 occupational injury and illness log if medical treatment such as gamma globulin is administered by licensed medical personnel.
- HBV and HIV will be recorded on the OSHA 300 log if the illnesses can be traced back to an occupational injury or other exposure incident that occurred on the job.
- Medical records will be kept for each employee with occupational exposure for the duration of employment plus 30 years.
- Records will be maintained of Hepatitis B vaccination status (including all dates) on all employees.
- The medical records that will be maintained will include the results of any examinations, testing results and follow-up procedures, as well as a copy of the health care professional’s written opinion and a copy of the information provided to the health care professional (if any).
- The employee medical records will also include the name and social security number of the employee and a copy of the employee’s hepatitis B vaccination status including the dates of the hepatitis B vaccinations.