CORPORATE SAFETY MANUAL
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1 CORPORATE SAFETY MANUAL Procedure No Revision: Date: May 2005 Total Pages: 9 PURPOSE To make certain that our employees are duly aware of the hazards of blood exposure or other potentially infectious materials. SCOPE This section applies to all Riley Construction Company, Inc. operations. POLICY To present information on the nature of bloodborne diseases in an effort to assist our employees in reducing or eliminating their potential exposure to bloodborne pathogens in their work environments. This procedure will ensure compliance with 29 CFR Riley Construction Company, Inc. operates near various hospitals, clinics and the alike. In the event of an emergency Riley employees have been properly trained to contact the nearest emergency service to provide first aid and CPR to injured employees. If Riley performs work in areas which emergency services are not available within a reasonable time frame then Riley will provide the jobsites with employees who have been properly trained in first aid, CPR and bloodborne pathogens. All blood spills will be cleaned up by an outside contractor in order to control potential exposures to Riley employees. This program has been developed as a guideline for all Riley employees. Since OSHA has not adapted the Bloodborne Pathogens standard for the construction industry Riley will utilize this policy as guideline only, in good faith, to help control accidents and injuries. REGULATORY COMPLIANCE A copy of the Bloodborne Pathogen Standard, 29 CFR will be made available to all employees. Riley employees will be able to review the standard and obtain a copy at any of the following locations. Milwaukee, Kenosha and Lake Bluff Offices. Construction Industry Even though the Bloodborne Pathogen Standard is basically an industrial standard, and the construction industry, as a whole, is exempted from the Standard, there is often an unrecognized
2 employee category to which the Standard does apply even in the construction industry. This is the company employee who has the potential for occupational exposure, the employee performing basic first aid. Note: Riley has decided not to train employees on first aid and CPR as well as clean up procedures regarding bloodborne pathogens since the company works near various health care facilities. If for some reason Riley takes on a project where health care facilities are not located within a reasonable distance and/or time frame the company will then decide to train employees on first aid/cpr and the proper and safe means and methods on clean up procedures regarding bloodborne pathogens. All employees have been properly trained in the event an emergency takes place. Exposure Determination It is Riley's policy that only employees who have been appropriately trained in first aid in bloodborne pathogens and who have the necessary protective equipment available are authorized to assist in the treatment of first aid injuries. No other Riley employee is to make any effort to assist in the first aid treatment of an injury, including efforts to clean the wound, stop the bleeding, bandage the injury, etc., nor is any other employee authorized to assist in the clean-up after an accident in which an employee has been injured, including the removal of blood stains, blood splattered equipment, or first aid materials. All Riley personnel must strictly adhere to this policy. Job Classifications Riley employees who have been designated as either supervisory personnel or safety personnel, and who have successfully completed the required training as outlined in the above paragraph, are the only Riley employees who shall be considered to be in those job classifications that may have occupational exposure. TRANSMISSION OF BLOODBORNE PATHOGENS Illness or disease related to bloodborne pathogens is transmitted through blood and other body fluids including semen, vaginal secretions, loose skin, and body tissue. Riley personnel must recognize that these fluids are potentially harmful and take precautions against contact and/or exposure. Occupational exposure to bloodborne disease such as Human Immunodeficiency Virus (HIV), the Hepatitis B Virus (HBV), and other infectious Hepatitis strains are most often transmitted through breaks in the skin or mucous membranes. This usually occurs through needle sticks or other contaminated broken sharp objects, human bites, or having blood or other body fluids enter existing cuts, abrasions, or body cavities. EXPOSURE CONTROL PLAN (Future) As a direct requirement of the Standard, Riley has established the following Exposure Control Plan, which is designed to eliminate or minimize employee exposure. This Exposure Control Plan will be reviewed and updated at least annually and whenever necessary to reflect new or
3 modified tasks and procedures that may affect occupational exposure. Each Riley employee will have access to this Plan. The project superintendent and safety director has responsibility for program implementation and compliance at his or her specific job site: Maintaining the list of employees who have specific responsibilities for the Exposure Control Plan at this site Insuring that the program is initiated immediately at the beginning of each project and overseeing this program throughout the duration of the job Maintaining and updating the lists of job tasks in which occupational exposure may occur Ensuring that personal protective equipment is available in all appropriate locations and that adequate work controls are initiated and maintained Ensuring that all contaminated and potentially contaminated equipment and materials are effectively decontaminated or appropriately disposed of The Safety Director will be responsible for the following portions of this program: Conducting bloodborne pathogen education and training Overseeing implementation of work practice controls Assisting in setting up and maintaining the Hepatitis B vaccination program Assisting in the coordination of bio-hazard waste disposal Investigation of all "exposure incidents" and overseeing post-exposure evaluation and follow-up processes Copies of this program may be reviewed and/or obtained at the following locations: Safety Directors office The job site Milwaukee, Kenosha and Lake Bluff offices Note: The program described above will be developed, reviewed and implemented on an as needed basis when Riley works in areas which health care facilities are not available within a reasonable time frame. Task Hazard Analysis Generally, most Riley personnel are at a very low risk for exposure to bloodborne pathogens. However, there are some situations in which Riley personnel may come into contact with potentially infectious or contaminated biohazard material. These tasks include: Providing cardio-pulmonary resuscitation (CPR) to an injured worker Providing first-aid assistance to an injured employee; and Conducting clean up of an accident site in which an employee has been injured.
4 These tasks are now to be conducted only by authorized personnel. Universal Precautions Riley has mandated the following "Universal Precautions." This is a concept in which it is universally accepted that human blood and most human body fluids will be treated as if they are known to be infectious for HIV, HBV, and other bloodborne pathogens. These precautionary measures will be taken on every job site to ensure that: Employees do not contact blood or other infectious materials; and All body fluids will be treated as potentially infectious materials. Precautionary Measures Since there is always the potential for accidents in the work place and at project sites, when these incidents involve potentially infectious materials, protecting human health and safety is the primary consideration for all employees involved in the incident. Important precautionary steps for all employees to follow in this situation include: Avoid all contact with blood or other bodily fluids (i.e., vomit, salvia) Wear appropriate PPE when there is a potential to make contact with potentially infectious materials Warn employees in surrounding area of the potential hazards Provide essential first aid only if appropriately trained, approved, and equipped to do so Report all exposure incidents to supervision; and See that all equipment and surfaces contaminated with blood or other body fluids are appropriately decontaminated or suitably disposed of. Engineering Controls and Work Practices Engineering controls utilized at the job site must include: The use of tools, such as a dustpan and brush, to sweep-up all materials suspected of being contaminated and placing them into the proper waste bag; The use of mechanical implements, such as hand extension apparatus, tongs, or other grasping devices, to pickup suspect materials; and Provide an approved disinfectant for the immediate decontamination of suspect materials. The following work practices must also be implemented on each project: Provide hand-washing facilities with potable water, which are readily accessible to potentially exposed employees Provide soap, antiseptic hand cleanser, and disposable towels or antiseptic towels
5 Require employees to wash their hands immediately after removing potentially contaminated gloves or other personal protective equipment Ensure that employees wash any area of the body, and flush mucous membranes with water, as soon as possible after contact with blood or other potentially infectious materials Utilize procedures involving clean up of blood or other potentially infectious materials to ensure that splashing, spraying, splattering, and generation of droplets are minimized Prohibit employees from using mouth pipetting/suctioning of blood or other potentially infectious materials Any item of equipment that may be contaminated as a result of being involved in an accident which an employee was injured will be examined prior to taking any additional action. Equipment found to be contaminated will either be decontaminated or it will be appropriately labeled and disposed of. Personal Protective Equipment A kit, containing personal protective equipment (PPE) required by the bloodborne pathogen standard must be readily available at all Riley facilities and job sites. This protective equipment must not allow blood or other potentially infectious materials to pass through to workers' clothing, skin, or mucous membranes. The equipment in this kit should include: Latex gloves (minimum) Safety glasses (minimum) Protective Clothing (minimum) Liquid splash goggles (preferred) Full-face shield (if potential to splash on face and in mouth) CPR mask with one-way exhalation valve (for use only by trained personnel) Biohazard waste disposal bags A copy of the Exposure Incident Investigation Report In accordance with OSHA requirements, the contents of this kit and our first aid kits should be certified as adequate by a licensed physician or must meet "Minimum Requirements for Industrial Unit-type First-aid Kits referenced in ANSI Z308. If these kits are purchased commercially, the manufacturer should obtain the certification. Hepatitis B Vaccination (Reserved) Riley will make a Hepatitis B vaccination available to those employees who may be affected. The vaccinations will be made available at no cost to the employee, at a time and place that is reasonable, will be performed under the supervision of a licensed physician, and will be provided based on the current recommendations of the U. S. Public Health Service. Employees eligible for this vaccination will be informed about the efficiency, safety, and method of administration and the benefits of the vaccine.
6 There are three groups of employees who can be exempted from this vaccination program. They are: Employees who have previously received the complete series; Employees who have had "antibody testing" that has revealed that the employee is immune; and Employees for whom the vaccine is not recommended for medical reasons. It must be noted, that while Riley can request and offer this vaccination, the employee is under no legal obligation to accept it. However, in those cases where the employee has declined the vaccination, the employee is mandated by the company to sign off stating his or her declination of the vaccination. The sign off verifies that the vaccination was offered by the company and in fact declined by the employee. Post-Exposure Vaccination While not a part of the Hepatitis B vaccination program, a post-exposure vaccination and a medical evaluation will be made available to any employee who has had an accidental exposure incident. Confidential medical evaluations and follow-ups will be made available to all affected employees following the report of an exposure incident. The medical evaluations will include the following elements: Documentation of exposure routes and circumstances of exposure Identification and documentation of source individual The source individual blood will be tested as soon as feasible after consent is obtained in order to obtain the persons HIV/HBV status. Housekeeping Practices Worksites must be maintained in a clean and sanitary condition with efforts being made to ensure the following: In the event that any equipment, environmental, or working surfaces should come into contact with blood or other potentially infectious materials, they will be immediately cleaned and decontaminated All contaminated work surfaces will be effectively decontaminated, with an appropriate disinfectant, as quickly as possible and certainly before the end of the work shift; and All biohazard-contaminated waste, which is to be disposed of, will be placed into red biohazard waste containers.
7 EXPOSURE INCIDENT An exposure incident may involve the eyes, mouth or other mucous membrane, non-intact skin, parental contact with blood or other potentially infectious materials or body fluids that results during the performance of an employee's work. Notification Employees must immediately report exposure incidents to their supervisors to enable timely medical evaluation and follow-up by a health care professional. Each exposure incident must also be reported to the Safety Director as quickly as possible. Post-Exposure Follow-up Following post-exposure evaluation, the health care professional should provide a written opinion to Riley. This opinion should be limited to a statement that the employee has been informed of the results of the evaluation and told of the need, if any, for further treatment. DECONTAMINATION Equipment and other surfaces, which have been contaminated with blood or other body fluids, must be decontaminated. Equipment and surfaces should be initially washed with a 10 percent bleach/water solution, then rinsed with clear water until all visible blood and body fluids has been cleaned up. The water generated during the decontamination can be disposed in the sanitary sewer or absorbed on paper towels for disposal. All solid waste generated should be added to the "Red Bio-Hazard Bag" waste stream. All cleaning shall be contracted out. This will help control potential exposures to Riley employees. EXPOSURE INCIDENT INVESTIGATION In an effort to ensure that we can take the proper steps to prevent exposure incidents, it will be the responsibility of the Safety Director to investigate each exposure incident as quickly as possible after being made aware of the incident. This investigation should contain the following information: The date and time the exposure incident occurred The exact location within the facility or job site the incident occurred What potentially infectious materials were involved in the incident What is the source of the potentially infectious material What activity was being performed when the incident occurred Details of exactly how the incident was caused; The personal protective equipment being used at the time of the incident; The actions taken as a result of the incident; and Documentation of the disposal of waste products
8 After this information is gathered and evaluated, a written summary of the incident should be prepared. This report should include recommendations to ensure that we avoid similar incidents in the future. Exemption There is one exemption to the Bloodborne Pathogen regulation, that is a "Good Samaritan act performed by an employee who would not normally be expected to encounter human blood or other potentially infectious materials in his or her job. RECORDKEEPING There are two types of records required by the bloodborne pathogen standard: Medical Records: A medical record must be established for each employee with occupational exposure. This record must be maintained as a confidential medical record and separate from other personnel records. This record may be kept on site or retained by the health care professional that provides services to the employee. This medical record must contain the employee's name, social security number, hepatitis B vaccination status, and a written opinion by the health care professional. Medical records of exposure must be maintained for a period of 30 years following the employee's last date of employment. Training Records: Training records, which document each training session, must be maintained for a period of at least 3 years. These records must include the date, content, outline, trainer's name and qualifications, and the names and job titles of all persons attending the training sessions.
9 VACCINATION DECLINATION FORM (SAMPLE) Employee Name: Employee Social Security Number: I understand that due to my specialized training as a first aid provider, my occupational exposure to blood or other potentially infectious materials may place me at risk of acquiring Hepatitis B virus (HBV) infection. Even though Riley has given me the opportunity to be vaccinated with Hepatitis B vaccine at no cost to myself, and at a time and place that would not be inconvenient, I have declined the Hepatitis B vaccination at this time. I further understand, that by declining this vaccine, I continue to be at risk of acquiring Hepatitis B, a serious disease. If, in the future, I continue to have occupational exposure to blood or other potentially infectious materials and I want to be vaccinated with Hepatitis B vaccine, I can receive the vaccination series at no cost to me. Employee Signature Date Safety Director's Signature Date
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