CALUMET COUNTY BLOODBORNE PATHOGEN & NEEDLE STICK PREVENTION PROGRAM

Transcription

1 CALUMET COUNTY BLOODBORNE PATHOGEN & NEEDLE STICK PREVENTION PROGRAM Subject: Originator: Bloodborne Pathogen Protection Brian Margan, ARM, Senior Risk Control Specialist Matthew Marmor, Safety Manager Review Frequency: Annually Forwarded by: Loss Control Committee Date: Approved by: Calumet County Administrator Date: Date of Last Revision: February 2011 Calumet County Bloodborne Pathogen Program Revision: December 2012

2 TABLE OF CONTENTS 1.0 DEFINITIONS PURPOSE SCOPE AND APPLICATION RESPONSIBILITIES Program Administrator Personnel Department/Human Resources Director Department Heads Employees Employee Non-Compliance PROGRAM ELEMENTS Employee Exposure Determination Methods of Compliance Implementation and Control Universal Precautions Engineering and Work Practice Controls Personal Protective Equipment Housekeeping Hepatitis B Vaccination and Post-exposure Evaluation and Follow-up Communication of Hazards to Employees Information and Training PROGRAM EVALUATION DOCUMENTATION AND RECORDKEEPING ATTACHMENTS TABLE 1 Required Bloodborne Pathogen PPE Use at Calumet County TABLE 2 - Calumet County Positions in Bloodborne Pathogen Program TABLE 3: Calumet County Bloodborne Pathogen Hazard Analysis FORM 4: Calumet County HBV Offer-Refusal Form FORM 5: Calumet County Exposure Incident Report Form FORM 6: Sharps Injury Log Example FORM 7: Training Documentation FORM 8: Calumet County Solicitation for Input From Potentially Exposed Employees APPENDIXES OSHA Standard Page 2 of 36

3 1.0 DEFINITIONS Blood means human blood, human blood components, and products made from human blood. Bloodborne Pathogens means 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). Clinical Laboratory means a workplace where diagnostic or other screening procedures are performed on blood or other potentially infectious materials. Contaminated means the presence or the reasonably anticipated presence of blood or other potentially infectious materials on an item or surface. Contaminated Laundry means laundry that has been soiled with blood or other potentially infectious materials or may contain sharps. Contaminated Sharps means 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 wires. Decontamination means the use of physical or chemical means to remove, inactivate, or destroy bloodborne pathogens on a surface or item to the point where they are no longer capable of transmitting infectious particles and the surface or item is rendered safe for handling, use, or disposal. Engineering Controls means controls (e.g., sharps disposal containers, selfsheathing needles, safer medical devices, such as sharps with engineered sharps injury protections and needleless systems) that isolate or remove the bloodborne pathogens hazard from the workplace. Exposure Incident means a specific eye, mouth, other mucous membrane, nonintact skin, or parenteral contact with blood or other potentially infectious materials that results from the performance of an employee's duties. Hand washing Facilities means a facility providing an adequate supply of running potable water, soap and single use towels or hot air drying machines. Licensed Healthcare Professional is a person whose legally permitted scope of practice allows him or her to independently perform the activities required by paragraph (f) Hepatitis B Vaccination and Post-exposure Evaluation and Followup. HBV means hepatitis B virus. HIV means human immunodeficiency virus. Page 3 of 36

4 Needleless Systems means a device that does not use needles for: (1) The collection of bodily fluids or withdrawal of body fluids after initial venous or arterial access is established; (2) The administration of medication or fluids; or (3) Any other procedure involving the potential for occupational exposure to bloodborne pathogens due to percutaneous injuries from contaminated sharps. 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. Other Potentially Infectious Materials means (1) 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; (2) Any unfixed tissue 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 HBVcontaining culture medium or other solutions; and blood, organs, or other tissues from experimental animals infected with HIV or HBV. Parenteral means piercing mucous membranes or the skin barrier through such events as needle sticks, human bites, cuts, and abrasions. Personal Protective Equipment (PPE) is specialized clothing or 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. Production Facility means a facility engaged in industrial-scale, large-volume or high concentration production of HIV or HBV. Regulated Waste means liquid or semi-liquid blood or other potentially infectious materials; contaminated items that would release blood or other potentially infectious materials in a liquid or semi-liquid state if compressed; items that are caked with dried blood or other potentially infectious materials and are capable of releasing these materials during handling; contaminated sharps; and pathological and microbiological wastes containing blood or other potentially infectious materials. Research Laboratory means a laboratory producing or using research-laboratoryscale amounts of HIV or HBV. Research laboratories may produce high concentrations of HIV or HBV but not in the volume found in production facilities. Page 4 of 36

5 Sharps with engineered sharps injury protections means a non-needle sharp or a needle device used for withdrawing body fluids, accessing a vein or artery, or administering medications or other fluids, with a built-in safety feature or mechanism that effectively reduces the risk of an exposure incident. Source Individual means any individual, living or dead, whose blood or other potentially infectious materials may be a source of occupational exposure to the employee. Examples include, but are not limited to, hospital and clinic patients; clients in institutions for the developmentally disabled; trauma victims; clients of drug and alcohol treatment facilities; residents of hospices and nursing homes; human remains; and individuals who donate or sell blood or blood components. Standard Sterilize means the use of a physical or chemical procedure to destroy all microbial life including highly resistant bacterial endospores. Universal Precautions is an approach to infection control. According to the concept of Universal Precautions, all human blood and certain human body fluids are treated as if known to be infectious for HIV, HBV, and other bloodborne pathogens. Work Practice Controls means controls that reduce the likelihood of exposure by altering the manner in which a task is performed (e.g., prohibiting recapping of needles by a two-handed technique). 2.0 PURPOSE Calumet County is committed to providing a safe and healthy work environment for its entire staff. In pursuit of this goal, the following exposure control plan (ECP) is provided to eliminate or minimize occupational exposure to bloodborne pathogens in accordance with OSHA Standard, 29 CFR , Occupational Exposure to Bloodborne Pathogens (hereinafter Standard ). 29 CFR ( (c)) Calumet County s Exposure Control Plan follows OSHA Exposure Control guidance: Exposure Determination criteria used to identify potential job functions or activities where employee exposures to bloodborne pathogens may occur; Methods used protect employees from bloodborne pathogens; Hepatitis B Vaccination direction; Post-Exposure Evaluation and Follow-up guidelines, including investigation and evaluation of circumstances surrounding exposure incidents; Methods used to communicate bloodborne pathogen hazards to employees; Program recordkeeping requirements; and, Accessibility of this plan to employees. Page 5 of 36

6 Feasible engineering controls such as sharps disposal containers and shelf-sheathing needles are a first line of defense; however, engineering controls have not always been feasible for some of our operations, nor have always completely controlled the identified hazards. In situations where effective engineering controls are not feasible, or while they are being instituted, protective equipment must be used. The work processes requiring bloodborne pathogen personal protective equipment (PPE) use at Calumet County are outlined in Table 1 (attached to this plan). 3.0 SCOPE AND APPLICATION The exposure control plan (ECP) is a key document to assist Calumet County in implementing and ensuring compliance with the Standard, thereby protecting our employees. Calumet County has determined that specified employees, as a condition of their duties, are reasonably anticipated to have skin, eye, mucus membrane, or parenteral contact with blood or other potentially infectious materials. Identified positions are found primarily in the Health Department, Sheriff s Office, Facility Maintenance Department, Highway Department, and Parks Department. Those employees who are determined to have occupational exposure to blood or other potentially infectious materials (OPIM) must comply with the procedures and work place practices outlines in this ECP. Employees participating in the bloodborne pathogen program do so at no cost to themselves. Calumet County bears the expense associated with occupational related training, provision of Hepatitis B vaccine, bloodborne pathogen PPE, medical evaluation and follow-up when needed Calumet County does not operate HIV or HBV Research Laboratories or Production Facilities. Employees covered by the bloodborne pathogens Standard receive an explanation of this ECP during their initial training session. The bloodborne pathogens Standard will also be reviewed during an employee s annual refresher training. employees can review this plan at any time during their work shifts by contacting their immediate supervisor. If requested, the Program Administrator will provide an employee with a copy of the ECP free of charge within 15 days of the request. Page 6 of 36

7 4.0 RESPONSIBILITIES. 4.1 Program Administrator The Calumet County Safety Manager (Phone: ) is designated as the qualified program administrator and is responsible for the administration the bloodborne pathogen program. Duties of the Program Administrator, in cooperation with Department Heads and the Human Resources Director, include: Identify affected positions to be covered under the ECP Identify work areas, processes or tasks, and evaluation of bloodborne pathogen hazards. Coordination/selection of bloodborne pathogen PPE options. Arranging for or conducting bloodborne pathogen training, documentation of training, and providing the written ECP to employees, OSHA, and NIOSH representatives. Maintain, review, and update the ECP annually, and whenever necessary to include new or modified tasks and procedures that affect occupational exposure and to reflect new or revised employee positions with occupational exposure. Implement the ECP for Calumet County, including records maintenance. 4.2 Personnel Department/Human Resources Director Collaborate in identifying positions covered under this plan. Responsible to ensure that all medical actions required by the Standard are performed and that appropriate employee health and OSHA records are maintained. Retain documentation and records required by the OSHA Standard. 4.3 Department Heads Department Heads, or designee, shall be responsible for the following within their respective Departments: Being knowledgeable about the bloodborne pathogen program requirements and location of the written plan. Implementing the bloodborne pathogen program within their respective department and ensuring that the program is understood and followed by their employees and annual refresher training is provided. Understanding of Incident Reporting steps and Medical Evaluation process. Ensuring the availability of appropriate bloodborne pathogen PPE. Being aware of tasks requiring the use of bloodborne pathogen. Continually monitoring work areas and operations to identify bloodborne pathogen hazards. Notify Program Administrator when engineering control devices or task procedures change. Page 7 of 36

8 Coordinating with the Program Administrator to address bloodborne pathogen hazards including PPE selection, or other concerns regarding the program. Forward employee bloodborne pathogen training records to the Safety Manager. Monitoring employee bloodborne pathogen PPE use to ensure that protective equipment is used in accordance with certifications. Provide and maintain all necessary personal protective equipment (PPE), engineering controls (e.g., sharps containers), labels, and red bags as required by the Standard. Ensure that adequate supplies of PPE, in appropriate sizes, are available along with appropriate engineering control devices. Ensure that proper clean-up and disposal of materials is completed. 4.4 Employees Each employees has the responsibility to wear his/her bloodborne pathogen PPE when and where required, and in the manner in which they were trained. Employees must also: Care for and maintain issued bloodborne pathogen PPE as instructed. Immediately inform their supervisor if exposed to blood, other potentially infectious materials (OPIM), or receive a parenteral injury. Inform their supervisor or the Program Administrator of any bloodborne pathogen hazards that they feel are not adequately addressed in the workplace and of any other concerns that they have regarding the program. 4.5 Employee Non-Compliance Employees may be subject to disciplinary action in accordance with the County s Personnel and General Administrative Policies for non-compliance with bloodborne pathogen protection requirements. 5.0 PROGRAM ELEMENTS 5.1 Employee Exposure Determination 29 CFR ( (c)(2) The Program Administrator in coordination with Department Heads will evaluate job tasks to assess the occupational bloodborne pathogen hazard presence and potential employee exposure for each job title/classification. This exposure determination is made without regard to the use of personal protective equipment. (29 CFR (c)(2)(ii)) Page 8 of 36

9 The Program Administrator will coordinate hazard evaluations for each task, operation, or process, where bloodborne pathogen hazards may be present in routine operations or during an emergency. The hazard evaluation will include: 1) Identification and development of a list of workplaces, or task processes, where bloodborne pathogen hazards may occur. 2) Surveying the workplace, reviewing vendor information, and talking with employees and supervisors. A bloodborne hazard analysis for Calumet County worksites may be found in Table 3 (attached to this plan). Calumet County performs governmental services. Employees with job titles listed in Table 2 have been identified as all having occupational exposure to bloodborne pathogens. This list includes part time, temporary, contract, and per diem employees covered by the Standard as required. Contracted service or temporary employment companies are expected to provide and document training, vaccine administration, and medical evaluation and follow-up for affected employees as required under the OSHA Standard. Calumet County will make available to contracted or temporary agency personnel working on behalf of the county annual BBP training and PPE at no cost to the employee, or contracted or temporary employment agency. 5.2 Methods of Compliance Implementation and Control 5.3 Universal Precautions (29 CFR (d)(1)) employees will utilize universal precautions. blood or other body fluid will be considered infectious regardless of the perceived status of the source individual. Under circumstances in which differentiation between body fluid types is difficult or impossible, all body fluids shall be considered potentially infectious materials. 5.4 Engineering and Work Practice Controls (29 CFR (d)(2)(i)) Engineering controls and work practice controls will be used to prevent or minimize exposure to bloodborne pathogens. Calumet County identifies the need for changes in engineering controls and work practices through safety committee meetings, review of OSHA records, incident Page 9 of 36

10 investigation/reviews, and employee input obtained through solicitations. The Program Administrator is responsible for ensuring recommendations are implemented. Engineering controls shall be examined and maintained or replaced on a regular schedule to ensure their effectiveness. (29 CFR (d)(2)(ii)) New procedures and new products are reviewed regularly through professional magazines, institutional practices, and professional associations. The specific engineering controls and work practice controls in place are listed below: Selection and use of nasal spray vaccine over vaccination Sharps disposal containers Self-sheathing needles Retractable needles Retractable butterfly needles Needle protection devices Absorbent materials used for liquid management/clean-up Needleless systems Where occupational exposure remains after institution of these controls, personal protective equipment shall also be used. Sharps disposal containers are available through the Health Department for all county departments. Filled sharps containers for disposal shall be returned to the Health Department. Employees utilizing sharps containers need to monitor and replace containers to avoid overfilling. Calumet County sharps policy is that contaminated needles and other contaminated sharps shall not be bent, recapped, removed, sheared or purposely broken. (29 CFR (d)(2)(vii) Calumet County policy is to use containers that are puncture resistant, labeled or color-coded in accordance with 29 CFR , and leak proof on the sides and bottom. Hand washing facilities are provided and readily accessible to most employees identified in the ECP. Department Heads or their designee will identify accessible hand washing facilities to new employees during orientation. (29 CFR (d)(2)(iii)) For employees where hand washing facilities are not feasible, Calumet County will provide an appropriate antiseptic hand cleaner in conjunction with clean cloth or paper towels, or antiseptic towelettes. Employees who need to use alternative hand cleaners shall wash their hands with soap and water as soon as feasible. (29 CFR (d)(2)(iv)) Page 10 of 36

11 Supervisors shall ensure that employees wash their hands immediately or as soon as feasible after removal of gloves or other personal protective equipment. (29 CFR (d)(2)(v)) Supervisors shall ensure that employees wash hands and any other skin with soap and water, and flush mucous membranes with water immediately or as soon as feasible following contact of such body areas with blood or other potentially infectious materials. (29 CFR (d)(2)(vi)) 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. (29 CFR (d)(2)(ix)) Food and drink shall not be kept in refrigerators, freezers, shelves, cabinets or on countertops or bench tops where blood or other potentially infectious materials are present. (29 CFR (d)(2)(x)) 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 these substances. (29 CFR (d)(2)(xi)) Mouth pipetting or suctioning of blood or other potentially infectious materials is prohibited. (29 CFR (d)(2)(xii)) Specimens of blood or other potentially infectious materials shall be placed in a container that prevents leakage during collection, handling, processing, storage, transport, and shipping. (29 CFR (d)(2)(xiii)) Additionally, the container shall be closed prior to storage, transport, or shipped and shall be labeled or color-coded consistent with the Standard. (29 CFR (d)(2)(xiii)(A)) 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 is labeled or color-coded according to the requirements of the Standard. (29 CFR (d)(2)(xiii)(B)) If the specimen could puncture the primary container, the primary container shall be placed within a secondary container that is puncture-resistant in addition to the preceding. (29 CFR (d)(2)(xiii)(C)) Equipment that may become contaminated with blood or other potentially infectious materials shall be examined prior to servicing or shipping and shall be decontaminated as necessary, unless Calumet County can demonstrate that decontamination of such equipment or portions of such equipment is not feasible. (29 CFR (d)(2)(xiv)) Page 11 of 36

12 A readily observable label in accordance with the Standard shall be attached to the equipment stating which portions remain contaminated. (29 CFR (d)(2)(xiv)(A)) Calumet County shall ensure that this information is 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. (29 CFR (d)(2)(xiv)(B)) 5.5 Personal Protective Equipment ( (d)(3)) Provision. PPE is provided to Calumet County employees at no cost to the employee. (29 CFR (d)(3)(i)) The Program Administrator, Department Head or their designee, provides training to employees in the use of the appropriate PPP for specific tasks or procedures. Applicable and suitable bloodborne pathogen PPE has been selected based on the following criteria to protect the employee from occupational exposure: Based on the type of exposure and quantity of these substances reasonably anticipated to be encountered. Personal protective equipment shall be considered appropriate only if it does not permit blood or other infectious materials to pass through to or reach the employee s work or street clothing, skin, eyes, mouth or mucous membranes under normal conditions of use and for the duration of time which the protective equipment will be used. (29 CFR (d)(3)(i)) New procedures and new products applicable and feasible to the workplace. Bloodborne pathogen hazard analysis. The types of PPE available to employees are as follows: Gloves Gowns Laboratory coats Face shields Eye protection - goggles Surgical Masks Mouthpieces Resuscitation bags Pocket masks or other ventilation devices Page 12 of 36

13 Use. Calumet County policy is that Department Heads, through their established line of supervision, are responsible to ensure all employees use appropriate personal protective equipment. Calumet County however recognizes that situations may arise where employees temporarily and briefly decline to use personal protective equipment when, under rare and extraordinary circumstances, it was the employee s professional judgment that in the specific instance 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. (29 CFR (3)(ii)) Calumet County has identified the following circumstances where this provision applies: Law enforcement officers unexpectedly attacked by, or occur contact with a bleeding suspect. Healthcare workers with an apparently stable patient begins to hemorrhage profusely, putting the patient s life in immediate jeopardy. Whenever an employee makes this judgment, the circumstances shall be investigated and documented in order to determine whether changes can be instituted to prevent occurrences in the future. (29 CFR (d)(3)(ii)) Accessibility. Department Heads, through their established line of supervision, are responsible to make available PPE in the appropriate sizes and readily accessible at the worksite, or is issued to employees. (29 CFR (d)(3)(iii)) Hypoallergenic gloves, glove liners, powderless gloves, or other similar alternatives shall be readily accessible to those employees who are allergic to the gloves normally provided. Cleaning, Laundering, and Disposal. Consistent with the OSHA Standard, Calumet County shall incur the expense to clean, launder, and dispose of personal protective equipment used by employees. (29 CFR (d)(3)(iv)) Cleaning of employee work clothing contaminated with blood or OPIM is coordinated through respective department policy. Repair and Replacement. Calumet County shall repair or replace personal protective equipment as needed to maintain its effectiveness, at no cost to the employee. (29 CFR (d)(3)(v)) Employees shall remove immediately, or as soon as feasible, any garment contaminated by blood or other potentially infectious materials, in such a way as to avoid contact with the outer surface. (29 CFR (d)(3)(vi)) Page 13 of 36

14 Employees shall remove PPE after it becomes contaminated and before leaving the work area. (29 CFR (d)(3)(vii)) Immediate replacement PPE shall be available to employees during work hours, from their immediate departmental supervisor or departmental store. When PPE is removed it shall be placed in an appropriately designated area or container for storage, washing decontamination or disposal. (29 CFR (d)(3)(viii)) The procedure for handling used PPE is as follows: PPE contaminated by blood or OPIM may be disposed of in the regular trash as long as contaminate is not be released through droplets or be squeezed out of the material (actual squeezing to test is prohibited for employees if material presents a risk of spreading dispose of as grossly contaminated). Gross contamination of PPE, where fluids may drip or be squeezed out, shall be securely placed in a leak-proof red bag, identified as a bio-hazardou, and shall be maintenance notified for proper disposal. Gloves. Employees shall wear appropriate gloves when it is reasonably anticipated that there may be hand contact with blood or OPIM, and when handling or touching contaminated items or surfaces. Employees shall replace gloves if torn, punctured or contaminated, or if the gloves ability to function as a barrier is compromised. (29 CFR (d)(3)(ix-ix(A))) Never wash or decontaminate disposable gloves (single use) for reuse. (29 CFR (d)(3)(ix)(B)) Utility gloves may be decontaminated for reuse if their integrity is not compromised. Discard utility gloves if they show signs of cracking, peeling, tearing, puncturing, or deterioration. (29 CFR (d)(3)(ix)(C)) The Department Head, through the normal chain of supervision, shall instruct new employees within their Department where to obtain gloves and the tasks that require the use of gloves. Masks, Eye Protection, and Face Shields. Employees shall wear appropriate face and eye protection when splashes, sprays, spatters, or droplets of blood or OPIM pose a hazard to the eye, nose, or mouth. (29 CFR (d)(3)(x)) When face and eye PPE is removed it shall be placed in an appropriately designated area or container for storage, washing decontamination or disposal. (29 CFR (d)(3)(viii)) Page 14 of 36

15 Gowns, Aprons, and Other Protective Body Clothing. Appropriate protective clothing such as gowns, aprons, lab coats, clinic jackets, or similar outer garments shall be worn in occupational exposure situations. (29 CFR (d)(3)(xi)) Surgical caps or hoods and shoe covers or boots shall be worn in instances when gross contamination can reasonably be anticipated (e.g., autopsies). (29 CFR (d)(3)(xii)) 5.6 Housekeeping General. Department Heads, through the normal chain of supervision, shall determine and implement an appropriate written schedule for cleaning and sanitizing the work area based on the following criteria (29 CFR (d)(4)(i)): Location of work area Type of surface(s) to be cleaned Type of contaminant present Tasks or procedures performed in the area equipment and environmental and working surfaces shall be cleaned and decontaminated after contact with blood or other potentially infectious materials. (29 CFR (d)(4)(ii)) Employees may utilize a disposable sanitary work surface cover for vaccination clinics. Contaminated work surfaces shall be decontaminated with an appropriate disinfectant (solution of bleach and water ten percent (10%) or an equivalent) after completion of procedures, immediately or as soon as feasible when surfaces are overtly contaminated of after any spill of blood or other potentially infectious materials, and at the end of the work shift. (29 CFR (d)(4)(ii)(A)) bins, cans, and similar receptacles intended for reuse which have a reasonable likelihood for becoming contaminated with blood or other potentially infectious materials shall be inspected and decontaminated on a regularly scheduled basis and cleaned and decontaminated immediately, or as soon as feasible, upon visible contamination. (29 CFR (d)(4)(ii)(C)) Broken glassware which may be contaminated shall not be picked up directly with the hands. It shall be cleaned up using mechanical means, such as a brush and dust pan, tongs, or forceps. (29 CFR (d)(4)(ii)(E)) Regulated Waste. Page 15 of 36

16 Contaminated Sharps Discarding and Containment. Contaminated sharps shall be discarded immediately or as soon as feasible in containers that are closable, puncture resistant, leak proof on sides and bottom, and labeled or color-coded consistent with this Standard. (29 CFR (d)(4)(iii)(A)(1)) During use, containers for contaminated sharps shall be easily accessible to personnel and located as close as is feasible to the immediate area where sharps are used or can be reasonable anticipated to be found (e.g. laundries). (29 CFR (d)(4)(iii)(A)(2)(i)) Containers shall be maintained upright throughout use and replaced routinely and not be allowed to overfill. (29 CFR (d)(4)(iii)(A)(2)(ii-iii)) When moving containers of contaminated sharps from the area of use, the containers shall be closed immediately prior to removal or replacement to prevent spillage or protrusion of contents during handling, storage, transport or shipping. The container shall be placed in a secondary container if leakage of the primary container is possible. The second container shall be closable, constructed to contain all contents and prevent leakage during handling, storage and transport, or shipping. The second container shall be labeled or color-coded to identify its contents. Reusable containers shall not be opened, emptied or cleaned manually or in any other manner that would expose employees to the risk of percutaneous injury. The Health Department will accept sharps containers which will be picked up by an outside vendor. Other regulated Waste Containment. Other regulated waste shall be placed in containers which are closable, constructed to contain all contents and prevent leakage of fluids during handling, storage, transportation or shipping. The waste shall be labeled and placed in a color-coded red bag and closed prior to removal to prevent spillage or protrusion of contents during handling, storage, transport or shipping. Disposal of all regulated waste shall be in accordance with applicable United States and local regulations. Calumet County departments maintain agreements with certified regulated waste disposal companies for pick-up and disposal of regulated wastes on an as needed basis. Sheriff s Department Stericycle, Inc. (limited use every 1-2 years) Health Department Stericycle, Inc. (sharps management) Page 16 of 36

17 Laundry. Laundry contaminated with blood or OPIM shall be handled as little as possible. (29 CFR (d)(4)(iv)(A)(1)) Contaminated laundry shall be placed in appropriately marked (biohazard labeled, or color-coded red bag) bags. Any employee who handles contaminated laundry shall wear appropriate PPE to prevent contact with blood or OPIM. (29 CFR (d)(4)(iv)(B)) If the laundry is sent off-site, then the laundry service accepting the laundry shall be notified of the potential contamination and utilize Universal Precautions in the handling of the laundry. Whenever contaminated laundry is wet and presents a reasonable likelihood of soak-through or of leakage from the bag or container, the laundry shall be placed and transported in bags or containers which prevent soak-through or leakage of fluids to the exterior. (29 CFR (d)(4)(iv)(A)(3)) 5.7 Hepatitis B Vaccination and Post-exposure Evaluation and Follow-up ( (e)) General. Calumet County shall make the Hepatitis B vaccination and vaccination series available to all employees identified in the exposure determination section of this plan, at no cost to the employee, and shall provide post-exposure evaluation and follow-up to all employees who have had an exposure incident. (29 CFR (e)(1)(i)) The Personnel Department, shall ensure that all medical evaluations and procedures including the Hepatitis B vaccine and vaccination series and postexposure follow-up, including prophylaxis, are (29 CFR (f)(2)(ii)): Made available at no cost to the employee. Made available to the employee at a reasonable time and place. Performed by, or under the supervision of, a licensed physician or by, or under the supervision of another licensed health care professional. Provided according to the recommendations of the United States Public Health Service current at the time of the evaluation and procedures take place. tests shall be performed at an accredited laboratory at no cost to the employee. Page 17 of 36

18 Hepatitis B Vaccination. Hepatitis B vaccinations shall be made available after the employee has received training about the HBV, including information of its efficacy, safety, method of administration, the benefits of being vaccinated, and that the vaccine and vaccination series will be offered free of charge, within ten (10) working days of initial assignment to all employees identified with occupational exposure. (29 CFR (f)(2)(i)) Participation in a pre-screening program shall not be a prerequisite for receiving hepatitis B vaccination. (29 CFR (f)(2)(ii)) Vaccination is encouraged unless: Documentation exists that the employee has previously received the series; Antibody testing reveals that the employee is immune; or Medical evaluation shows the vaccination is contraindicated. If a routine booster dose of Hepatitis B vaccine is recommended by the U.S. Public Health Service at a future date, such booster doses shall be made available at no cost to the employee. (29 CFR (f)(2)(v)) Form 4: Calumet County HBV Offer-Refusal Form will be used to document offering of the free Hepatitis B vaccine series to employees identified with occupational exposure. Upon completion of vaccine series, or an employee s written refusal, the original form shall be sent to the Calumet County Personnel Department. The Calumet County Health Department will provide the initial HBV series for all employees identified as having occupational exposure. Post-exposure Evaluation and Follow-up. An employee that experiences any level of exposure to blood or OPIM shall wash the exposed area with soap and water, or a disinfectant, as promptly as possible. The employee needs to notify their supervisor and complete/submit a Calumet County Employee Incident Report. In addition to initial first aid (clean the wound, flush eyes or other mucus membranes, etc.), an employee that experiences a work related exposure incident (a specific eye, mouth, other mucous membrane, non-intact skin, or parenteral contact with blood or other potentially infectious materials) must be referred for a confidential medical exposure evaluation through Affinity Occupational Health, or through a licensed physician, with all laboratory tests being conducted in accredited laboratories (29 CFR (f)(3)). Employees shall be offered evaluation services through Affinity Occupational Health or another healthcare professional anytime a question arises concerning whether or not an exposure incident has occurred. Page 18 of 36

19 Evaluations and follow-ups shall be provided at no cost to the employee. If an exposure incident occurs outside of regular business hours the employee will be referred to either the Calumet Medical Center or St. Elizabeth s Emergency Room for evaluation. The Calumet County Personnel Department should be notified by phone (leave a message) at whenever an exposure incident has occurred. The confidential medical evaluation and follow-up will include the following elements: Documentation of the route of exposure, and the circumstances under which the exposure incident occurred. (29 CFR (f)(3)(i)) Identification and documentation of the source individual, unless it can be established that the identification is infeasible or prohibited by Wisconsin Statute or local law. (29 CFR (f)(3)(ii)) 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, the Corporation Counsel or District Attorney shall establish 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. (29 CFR (f)(3)(ii)(A)) When the source individual is already known to be infected with HBV or HIV, testing for the source individual s HBV or HIV status need not be repeated. (29 CFR (f)(3)(ii)(B)) Results of the source individual s testing shall be made available to the exposed employee, and the employee shall be informed of applicable laws and regulations protecting confidentiality of the source individual. (29 CFR (f)(3)(ii)(C)) The exposed employee s blood shall be collected as soon as feasible and tested after consent can be obtained. (29 CFR (f)(3)(iii)(A)) 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 the 90 days of the exposure incident, the employee elects to have the baseline sample tested, such testing shall be done as soon as feasible. (29 CFR (f)(3)(iii)(B)) Post-exposure prophylaxis, when medically indicated, as recommended by the U.S. Public Health Service; (29 CFR (f)(3)(iv)) Page 19 of 36

20 Counseling (29 CFR (f)(3)(v)); and Evaluation of reported illnesses. (29 CFR (f)(3)(vi)) Calumet County shall ensure that the healthcare professional responsible for the employee s Hepatitis B vaccination is provided a copy of the OSHA Standard 29 CFR (29 CFR (f)(4)(i)) The Personnel Department shall ensure that Affinity Occupational Health, or other health care professional evaluating an employee after an exposure incident, is provided the following (29 CFR (f)(4)(ii)): A copy of the OSHA Standard 29 CFR A description of the exposed employee s duties as they relate to the exposure incident. Written documentation of the route of exposure and circumstances under which exposure occurred. Results of the source individual s blood testing, if available. medical records relevant to the employee, including vaccination status. Healthcare Professional s Written Opinion. The Personnel Department shall receive and provide the employee with a copy of the evaluating healthcare professional s written opinion within 15 working days of the completion of the evaluation. (29 CFR (f)(5)) The health care professional s written opinion for HBV vaccination shall be limited to whether HBV vaccination is indicated for an employee, and if the employee has received such vaccination. The health care professional s written opinion for post-exposure follow-up shall be limited to the following information: A statement that the employee has been informed of the results of the evaluation; and A statement that the employee has been told about any medical conditions resulting from exposure to blood or OPIM which require further evaluation of treatment. other findings or diagnosis shall remain confidential and shall not be included in the written report. (29 CFR (f)(iii)) 5.8 Communication of Hazards to Employees (29 CFR (1030(g)) Page 20 of 36

21 Labels. The Department Head, through the normal chain of supervision, shall ensure that biohazard labels be affixed to containers of regulated waste, refrigerators and freezers containing blood or other potentially infectious materials, and other containers used to store, transport or ship blood or other potential infectious materials. (29 CFR (g)(1)(i)(A)) The universal biohazard symbol shall be used. The label shall be fluorescent orange or orange-red or predominantly so, with lettering and symbols in a contrasting color. Labels shall be affixed as close as feasible to the container by string, wire, adhesive, or other method that prevents their loss or unintentional removal. Red bags or containers may be substituted for labels 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 requirement. Labels required for contaminated equipment shall be consistent with the color and contrasting symbol/lettering, and state what portions of the equipment remain contaminated. Regulated waste that has been decontaminated need not be labeled or color-coded. (29 CFR (g)(1)(i)(I)) 5.9 Information and Training. The Human Resources Director will ensure that all employees with occupational exposure participate in a training program provided during working hours and at no cost to the employee. (29 CFR (g)(2)(i)) Employees will initially be trained at the time of initial assignment to tasks where occupational exposure may take place and at least annually thereafter. (29 CFR (g)(2)(ii)(A-B)) Annual training for all employees shall be provided within one year of their previous training. (29 CFR (g)(2)(iv)) Additional training will be provided whenever modification of tasks or procedures or institution of new tasks or procedures affect the employee s occupational exposure. This training may be limited to addressing the new exposures created. (29 CFR (g)(2)(v)) employees who have occupational exposure to bloodborne pathogens receive training on the epidemiology, symptoms, and transmission of blood borne pathogen diseases. In addition the training program covers, at a minimum, the following elements: Page 21 of 36

22 A copy and explanation of the OSHA bloodborne pathogen Standard. An explanation of the Calumet County ECP and how to obtain a copy. An explanation of methods to recognize tasks and other activities that may involve exposure to blood and OPIM, including what constitutes an exposure incident. An explanation of the use and limitations of engineering controls, work practices, and PPE. An explanation of the types, uses, location, removal, handling, decontamination, and disposal of PPE. An explanation of the basis for PPE selection. Information on the Hepatitis B vaccine, including information on its efficacy, safety, method of administration, the benefits of being vaccinated, and that the vaccine will be offered free of charge. Information on the appropriate actions to take and persons to contact in an emergency involving blood or OPIM. An explanation of the procedure to follow if an exposed 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 Calumet County is required to provide for the employee following an exposure incident. An explanation of the signs and labels and color coding required by the Standard and used at Calumet County facilities. An opportunity for interactive questions and answers with the person conducting the training session. Training materials for Calumet County are available through the Safety Manager (phone ). 6.0 PROGRAM EVALUATION (29 CFR (c)(1)(iv)) The Program Administrator and Loss Control Committee shall review this program annually. The Program Administrator will conduct periodic evaluations of the workplace, in coordination with Department Head or their designee, to ensure that the provisions of this program are being implemented. The evaluations will include regular consultations with employees deemed at risk from bloodborne pathogens and their supervisors, site inspections, hazard evaluation and a review of records. Problems identified will be noted in an inspection log and addressed by the Program Administrator. These findings will be reported to Calumet County Administrator, and the report will list plans to correct deficiencies in the bloodborne pathogen program and target dates for the implementation of those corrections. Page 22 of 36

23 Revise the county plan if changes in technology eliminate or reduce exposure to bloodborne pathogens. Document annually consideration and implementation of appropriate commercially available and effective safer medical devices designed to eliminate or minimize occupational exposure. (29 CFR (c)(1)(v)) Solicit input from non-managerial employees responsible for direct patient care who are potentially exposed to injuries from contaminated sharps in the identification, evaluation, and selection of effective engineering and work practice controls and shall document the solicitations in the Exposure Control Plan. 7.0 DOCUMENTATION AND RECORDKEEPING (29 CFR (h)) 7.1 Medical Records. A medical records file shall be maintained for each employee identified at risk for occupational exposure, in accordance with 29 CFR , Access to Employee Exposure and Medical Records, by the Personnel Department. This record shall include: The name and social security number of the employee; 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 vaccinations. A copy of all results of examinations, medical testing, and follow-up procedures related to an exposure incident. Calumet County s copy of the healthcare professional s written opinion related to an exposure incident. A copy of the information provided to the healthcare professional as required for an exposure incident. The Calumet County Personnel Department shall ensure that employee medical records required by the Standard are kept confidential; and not 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. (29 CFR (h)(1)(iii)) These medical records shall be maintained by the Personnel Department for at least the duration of employment plus 30 years in accordance with 29 CFR (29 CFR (h)(1)(iv)) 7.2 Training Records. The Personnel Department will maintain training records for employees with occupational exposure to bloodborne pathogens. This record shall include: Page 23 of 36

24 The dates of the training sessions; The contents or a summary of the training sessions; The names and qualifications of persons conducting the training; and The names and job titles of all persons attending the training sessions. Training records shall be maintained for 3 years from the date on which the training occurred. (29 CFR (h)(2)(ii)) 7.3 Availability. Calumet County shall ensure that all records required to be maintained by this section shall be made available upon request to the Assistant Secretary and the Director for examination and copying. (29 CFR (h)(3)(i)) Employee training records shall be provided upon request to the employee or the employee s representative within 15 working days. requests should be addressed to the Program Administrator. (29 CFR (h)(3)(ii)) Employee medical records required by this section shall be provided upon request for examination and copying to the subject employee, to anyone having written consent of the subject employee, and to the Director and to the Assistant Secretary in accordance with 29 CFR (29 CFR (h)(3)(iii)) 7.4 OSHA Recordkeeping. An exposure incident shall be evaluated to determine if the incident meets OSHA s Recordkeeping Requirements (29 CFR 1904). This determination and the recording activities will be completed by the Personnel Department. 7.5 Sharps injury log. The Calumet County Personnel Department has established, and maintains, a sharps injury log for the recording of percutaneous injuries from contaminated sharps. The information in the sharps injury log shall be recorded and maintained in such a manner as to protect the confidentially of the injured employee. The sharps injury log shall contain at a minimum: (29 CFR (h)(5)(i)) 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. A written copy of this program and the OSHA Standard is kept in the Program Administrator s office and is available to all employees who wish to review it. The Calumet County Bloodborne Pathogen Program has also been posted to the County Intranet to increase employee and supervisor access to the document. Employees can review this plan at any time during their work shifts by contacting their immediate supervisor. If requested, the Program Administrator will provide an employee with a copy of the ECP free of charge and within 15 days of the request. Page 24 of 36

25 Copies of this written Bloodborne Pathogen Program and all revisions shall be distributed to the following: 1. Program Administrator 2. Human Resources Director 3. Captain Sheriff s Office 4. Human Services Director 5. Highway Commissioner 6. Parks Director 7. Courthouse Maintenance Supervisor 8. Health Department Director 9. Medical Examiner 10. Corporation Counsel 8.0 Attachments Table 1: Required Bloodborne Pathogen PPE Use at Calumet County Table 2: Positions Required To Participate in BBP Program Table 3: Calumet County Bloodborne Pathogen Hazard Analysis Form 4: Calumet County HBV Offer-Refusal Form Form 5: Calumet County Exposure Incident Report Form Form 6: Sharps Injury Log Example Form 7: Training Documentation Form Form 8: Calumet County Solicitation for Input From Potentially Exposed Employees Page 25 of 36

26 TABLE 1 Required Bloodborne Pathogen PPE Use at Calumet County Personal Protective Equipment Gloves Gloves Gloves/eye-face protection Gloves Gloves Gloves Gloves Department/Process/Task Health/vaccination Maintenance/clean-up following injury Medical Examiner/autopsy Corrections/addressing bleeding inmate Housekeeping/clean-up Parks/Garbage pick-up Sheriff s Dept/accident or response to medical Page 26 of 36

27 TABLE 2 - Calumet County Positions in Bloodborne Pathogen Program DEPT JOB TITLE EXPOSURE Sheriff s Office Investigator Patrol Officer Patrol Corporal Police School Liaison Officer Special Investigator Patrol Sergeant Corrections Officer Lieutenant Sheriff (Elected Office) Captain Jail Administrator Jail Sergeant Public Health Public Health Nurse Housekeeping Aide Director Assistant Director Secretary Secretary/Technician HHC/Hospice Agency Aide HHC/Hospice Agency RN HHC/Hospice Agency Supervisor HHC/Hospice Agency LPN Bilingual Nutrition Educator Hospice Social Worker Public Health Assistant/Technician Public Health Nutritionist Medical Examiner Medical Examiner Chief Deputy Medical Examiner Deputy Medical Examiner Human Services Economic Support Assistant Economic Support Financial/Employment Specialist Economic Support Resource Specialist Calumet County Bloodborne Pathogen Program Revision: February 2011 Page 27 of 3

28 CSW IV Access Supervisor CSW IV Long Term Support Supervisor CSW IV Comprehensive Community Services Supervisor CSW IV Clinical CSP Manager CSW IV Family Services Supervisor Human Services Worker Psychiatric Nurse CSP HS Prof. II HS Prof. III Highway Dept Highway Commissioner Patrol Superintendent Shop Foreman Mechanic Large Motor Grader Operator Loader Operator Center Striping Machine Operator Patrol Worker Truck Driver Backhoe Operator Maintenance Maintenance Coordinator Maintenance Worker Relief Maintenance Janitor Parks Dept Janitor Park Equip Operator Ranger/Maint Worker Park Mechanic Calumet County Bloodborne Pathogen Program Revision: February 2011 Page 28 of 3

29 TABLE 3: Calumet County Bloodborne Pathogen Hazard Analysis Department Task Contaminants Exposure Controls Sheriff s Office Highway Department Courthouse Maintenance Parks Department Patrol Work Blood and OPIM 1 st Aid/Accident scene Patrol Work Blood Altercation with/arrest of bleeding suspect Corrections Needle stick Pat down of suspect Corrections OPIM Thrown at Highway clean up Accident clean-up Garbage cleanup OPIM, sharps, needle stick Blood and OPIM OPIM, sharps, needle stick Public Health Vaccinations Needle stick, Blood Home Health/ Hospice Needle stick, blood, OPIM officers Hand picking up trash Hand picking up trash Vaccinations Patient Care Gloves, CPR mask, disinfectant wash, BBP PPE kit gloves Gloves, mechanical devices Gloves, mechanical devices Gloves, auto capping needles Gloves, auto capping needles Calumet County Bloodborne Pathogen Program Revision: February 2011 Page 29 of 3

30 FORM 4: Calumet County HBV Offer-Refusal Form Employee Hepatitis B Vaccine Immunization Consent/Non-Consent Form/Vaccine Administrative Record 1. I hereby acknowledge that I have received, read, and understand the State Division of Health form #4860 HEPATITIS B VACCINE WHAT YOU NEED TO KNOW. 2. I understand that due to my occupational exposure to blood or other potentially infectious materials I maybe at risk of acquiring Hepatitis B virus (HBV) infection. 3. I understand that I have been given the opportunity to be vaccinated with the Hepatitis B vaccine series, at no charge to myself. 4. I understand if I decline the vaccine, I continue to be at risk of acquiring Hepatitis B, a serious disease. 5. I understand, that 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 series at no charge to me. With the foregoing in mind, I hereby: (print full name) Give my consent to receive a series of three vaccinations for the Hepatitis B vaccine. Decline the Hepatitis B vaccine at this time, understanding the potential risks of exposure and that I may in the future receive the vaccine at no charge to me. Signature Date VACCINE ADMINISTRATION Date VACCINE LOT # INJECTION SITE R.N Imm general hep b consent non-consent form vaccine administrative record Calumet County Bloodborne Pathogen Program Revision: February 2011 Page 30 of 3

31 Calumet County Bloodborne Pathogen Program Revision: February 2011 Page 31 of 3

32 Calumet County Bloodborne Pathogen Program Revision: February 2011 Page 32 of 3

33 FORM 5: Calumet County Exposure Incident Report Form Calumet County SHARPS INJURY REPORT Supervisor to forward this report to Calumet County Personnel Department. Calumet County Bloodborne Pathogen Program Revision: February 2011 Page 33 of 3