Safety Policy and Procedure

Safety Policy and Procedure Policy Number: 025 Authorized By: The Cianbro Companies Alan Burton Title: Bloodborne Pathogens Effective Date: 04/18/94 Page 1 of 11 1 Status 1.1 Update of existing policy, effective 03/02/10. 2 Purpose 2.1 The risk of bloodborne disease transmission is higher than ever unless we prepare for it. In the event there is an incident, we need to be prepared to prevent exposures and know what action to take should there be an exposure. 3 Applicability 3.1 This policy applies to all subsidiary companies and departments of the Cianbro Companies. 3.2 All organizations are required to comply with the provisions of this policy and procedure. 4 Definitions 4.1 Bloodborne pathogen exposure: Any situation where an individual has contact with someone else s blood directly onto his/her non-intact skin, or into the eyes or mouth. 4.2 Decontamination: 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. 4.3 Epidemiology: The study of disease in populations. 4.4 Hepatitis B: An inflammation (irritation and swelling) of the liver due to the hepatitis B virus (HBV). The hepatitis B virus spreads through the body and other body fluids. 4.5 Non-intact skin: Skin with dermatitis, hangnails, cuts, abrasions, chafing, open or uncovered wounds, etc. 4.6 Qualified individual: One who is knowledgeable in the subject matter, in the bloodborne pathogen standard, and can relate both to the workplace that the team members are working in. Project Superintendent or their designated qualified person (i.e. Safety Specialist) shall perform the training. 4.7 Universal precautions: An approach to infection control. All human blood and certain human body fluids are treated as if known to be infectious for bloodborne pathogens. 5 Policy 5.1 This plan has been provided to eliminate or minimize occupational exposure to bloodborne pathogens in accordance with OSHA standards, thereby protecting our team members. Policy: 025 Bloodborne Pathogens Rev. 03/02/10 Page 1

6 Responsibilities 6.1 Corporate Safety is responsible to ensure implementation of this exposure control plan. This plan will be maintained, reviewed, and updated at least annually, and whenever necessary to include new or modified tasks and procedures. 6.2 Those team members who are determined to have occupational exposure to blood or other potentially infectious materials must comply with the procedures and work practices outlined in this plan. 6.3 Top Project Management will provide and maintain all necessary personal protective equipment (i.e. disposable gloves, eye protection, etc). They will ensure that all equipment is available in appropriate sizes. 6.4 Top Project Management will be responsible for ensuring that all medical actions required by the standard are performed and that appropriate team member health and OSHA records are maintained. 6.5 Top Project Management will be responsible for training, documentation of training, and making the written exposure control plan available to team members. Policy: 025 Bloodborne Pathogens Rev. 03/02/10 Page 2

7 Bloodborne Pathogens Index 7.1 Training Requirements... 3 7.2 Engineering and Work Practice Controls... 3 7.3 Exposure Determination... 4 7.4 Notification Requirements... 4 7.5 Exposure Incident Report... 5 7.6 Source Identification and Testing Procedure... 5 7.7 Post Exposure Evaluation and Follow-up... 5 7.8 Personal Protective Equipment (PPE)... 6 7.9 Hepatitis B Vaccination... 6 7.10 Decontamination... 7 7.11 Medical Waste Disposal... 8 7.12 Recordkeeping... 8 9.1 Appendix A Exposure Incident Report... 9 9.2 Appendix B Hepatitis B Vaccination Decline Form... 11 Please Note: Training manual for presenter and student is located on the intra net under Resources Manuals Monthly Safety Training Calendar & Material 4.0 April & 4.1 April. 7.1 Training Requirements 7.1.1 Training shall be performed for all team members during initial orientation and at least annually. Annually is defined as within 12 months of their previous training. 7.1.2 The training program shall provide an opportunity for interactive questions and answers and the training program must be performed by a qualified individual. 7.1.3 The training program must cover at a minimum the following elements: A copy of the Bloodborne Pathogen Standard and an explanation of its contents; General explanation of the epidemiology and symptoms of bloodborne diseases; Explanation of the modes of transmission of bloodborne pathogens; Cianbro s Bloodborne Pathogen Exposure Control Plan/Policies and how a team member can obtain a copy of these items; Ways of recognizing tasks and other activities that may involve exposure to blood and other potentially infectious materials; Explanation of the use and limitations of methods that will prevent or reduce exposure; Information on the types, proper use, location, removal, handling, decontamination and disposal of PPE and waste; Explanation on how to select PPE; Information on the Hepatitis B vaccine, including information on its efficacy, safety, method of administration, the benefits of being vaccinated, and the vaccine and vaccination will be offered free of charge; Information on the appropriate actions to take and persons to contact in an emergency involving blood or other potentially infectious materials; Information on the post-exposure evaluation and follow up; Information on completing the Exposure Incident Report Form; Explanation on signs and labeling; Location of the puncture resistant biohazard container for sharps (needles). A copy of an adequate training program can be found on cianbro.net power point presentation of this Safety Policy and Procedure. 7.2 Engineering and Work Practice Controls 7.2.1 Engineering and work practice controls shall be used to eliminate or minimize team member exposure. 7.2.2 When provision of hand washing facilities are not feasible, appropriate antiseptic hand cleanser in conjunction with clean cloth/paper towels or antiseptic towelettes shall be provided. 7.2.3 Team members shall wash their hands immediately or as soon as feasible after removal of gloves or other personal protective equipment. Policy: 025 Bloodborne Pathogens Rev. 03/02/10 Page 3

7.2.4 Contaminated needles and other contaminated sharps shall not be bent, recapped, or removed. Shearing or breaking of needles is prohibited. 7.2.5 Immediately or as soon as possible after use, contaminated sharps shall be placed in appropriate containers, which shall be leak-proof, labeled, and puncture resistant. 7.2.6 Eating, drinking, smoking, applying cosmetics or lip balm, and handling contact lenses are prohibited in work areas where there is a likelihood of occupational exposure. 7.2.7 Minimize the presence of broken glass in work areas. Use a small broom and dustpan to pick up broken glass and/or sharps. 7.2.8 Team members are not to touch/clean up any biohazards which would include, but are not limited to, blood, body fluids, sharps (needles) or soiled clothing. They are to contact their safety department or project manager who will conduct a safe clean up as outlined in this policy. 7.2.9 Do not use spray bottles that can mist the germicide into the area because people then breathe in the germicide and/or scatter the bloodborne pathogen(s). 7.3 Exposure Determination 7.3.1 All team members at a Cianbro jobsite and/or facility may have the potential of having an occupational exposure. Universal precautions shall be observed to prevent contact with blood or other potentially infectious materials. Under circumstances in which differentiation between body fluid types is difficult or impossible, all body fluids shall be considered potentially infectious materials. Safety Specialists are probably the personnel with the highest risk of having an occupational exposure since they deal with injury management and first aid functions on a regular basis. Tasks that may pose a potential for an occupational exposure without regard to the use of personal protective equipment are: Personnel required to decon an area; Personnel required to handle waste disposal; Personnel who perform certain janitorial tasks; Personnel who are required to clean up a jobsite where sharps, broken glass, fecal material, etc. have been discarded (i.e., bridge abutment once occupied by homeless people); Personnel who perform first aid and/or CPR. Personnel who try to recap Bee Sting or insulin needles/pens. DO NOT RECAP. 7.4 Notification Requirements 7.4.1 Contact the immediate Supervisor, Project Manager/Superintendent and the Safety Specialist immediately should an exposure incident occur. 7.4.2 Supervisor, Project Manager/Superintendent and the Safety Specialist must report the incident to the Corporate Safety Department within 2 hours by telephone of the exposure incident. 7.4.3 The Safety Specialist shall immediately complete the Exposure Incident Report Form in Appendix B and Cianbro s First Report of Incident. Fax a copy to the Corporate Safety Department within 24 hours of the incident. 7.4.4 The Safety Specialist, unless he/she is the exposed, shall complete the source I.D. and secure the source s agreement (verbal) to be tested for HIV/HBV. (Note: The source has a right to refuse testing.) NOTE: Following an exposure incident, prompt medical evaluation and counseling is imperative. Timeliness is an important factor for effective medical treatment. Medical evaluation must occur on the same day as the exposure. 7.4.5 If Safety Specialist is exposed; all Safety Specialist responsibilities outlined in this section (Notification Requirements) must be the responsibility of the Project Manager/Superintendent. Policy: 025 Bloodborne Pathogens Rev. 03/02/10 Page 4

7.4.6 The Safety Specialist, unless he/she is exposed, shall arrange a post exposure medical evaluation at an approved clinic from Cianbro s Clinic Listing or if there is not one available contact OMC at 1-800-575-6537 for the exposed individual and HIV/HBV testing for the source individual. Notify the Manager of Environmental Hazards or the Safety Department Supervisor immediately. 7.4.7 Corporate Safety Department will be responsible for notifying Occupational Medical Consulting (OMC) in Leeds, Maine and EAP at 1-800-769-9819 within 30 minutes of their notification. 7.5 Exposure Incident Report 7.5.1 No incident is too small. Any incident involving contact with body fluids will require the Safety Specialist and/or Project Manager/Superintendent to complete the Exposure Incident Report found in Appendix A. Each blank on the form must be properly completed and be as specific as possible when completing it. 7.5.2 The report must be completed in strictest of confidence. When completing the report ensure that the exposed individual is interviewed on a one on one basis. DO NOT interview the exposed person in front of others. Also, keep all information confidential. DO NOT discuss the obtained exposure incident report form information with other workers. 7.5.3 It is essential that immediate notification and action be taken following an exposure incident. Time is of the Essence. Any time someone comes in physical contact with the blood of someone else without proper personal protection, it constitutes an exposure incident and must be reported immediately in order for a physician to determine if an exposure has occurred. 7.6 Source Identification and Testing Procedure 7.6.1 The Safety Specialist responding to the exposure event shall identify the exposure source individual(s) in the Exposure Incident Report providing the source individual agrees in writing to such identification. The Safety Specialist will obtain written consent for and arrange for follow-up medical evaluation and testing of the source. Voluntary source testing should follow the established Bloodborne Pathogen Post-Exposure Medical Evaluation Protocol. 7.6.2 The source must be made aware that the results of the testing for HIV and HBV infectivity will be made available to the exposed team member for use in completing necessary medical evaluation and treatment. The source must be assured that actual test results will not be forwarded to the employer. No source testing is to proceed without the written consent from the source. If the source refused identification and/or evaluation testing, notify the Corporate Safety Department of the situation and proceed with the evaluation of the exposed team member(s). 7.6.3 NOTE: If the Safety Specialist is the exposed individual or source individual this responsibility falls on the Project Manager/Superintendent. Confidentiality is crucial in these matters! 7.7 Post Exposure Evaluation and Follow-up 7.7.1 Cianbro personnel complete exposure incident report. 7.7.2 Cianbro personnel complete source identification and secure source s verbal agreement to be tested. 7.7.3 Cianbro personnel arrange post exposure medical evaluation for exposed and HIV/HBV testing for source. Notify the Corporate Safety Department simultaneously. 7.7.4 The Corporate Safety Department notifies Occupational Medical Consulting (OMC) immediately. 7.7.5 Occupational Medical Consulting a) contacts local provider (assures appropriate form utilization, procedure and results reporting), and b) exposed name to recall. Re-check 30 days to assure completion/record forwarding, etc. Policy: 025 Bloodborne Pathogens Rev. 03/02/10 Page 5

7.7.6 The Clinic completes encounter(s) per protocol (interviews, counsels, and tests) and forwards Post Exposure Medical Evaluation Results Reporting Form to Occupational Medical Consulting after each visit. 7.7.7 Occupational Medical Consulting forwards standard compliant medical opinion to Cianbro. 7.7.8 Source individual and exposed individual shall be notified of results by OMC. 7.7.9 The clinic will bill OMC at RR 1, PO Box 3380, Leeds, Maine 04263. 7.8 Personal Protective Equipment (PPE) 7.8.1 The following equipment must be made available at no cost to team members at each jobsite and must be used when an incident occurs: Disposable (single use) latex or rubber gloves. These items shall be worn when handling contaminated items or supplying aid to an injured person(s). These items must be made part of each first aid kit. A double layer of gloves must be worn if incident is major and there is a lot of blood. Surgeon s mask/goggles/face shields. These items shall be worn if splashes or splatters of potentially infectious materials are expected. These items must be made part of each first aid kit. This item can only be worn when dealing with bloodborne pathogens. Antiseptic towelettes or waterless hand cleaner. If hand washing is not feasible, team members shall use antiseptic towelettes or waterless hand cleaner to clean their hands. However, team members will wash their hands in soap and warm, running water as soon as feasible. Protective Body Clothing. Appropriate protective body clothing shall be worn in occupational exposure situations. The type and characteristics will depend upon the task and degree of exposure anticipated A disposable CPR mask shall be part of the first aid kit. NOTE: If a resuscitation bag is available it shall only be used by trained, qualified individuals. Biohazard labels. These labels shall be use to mark containers and bags containing contaminated items. Puncture Resistant Containers. At least one of these containers should be made available at jobsites and at fixed facilities. These containers shall be used for the disposal of glass contaminated material, needles (from use of bee sting kits, diabetes, EPI pens, etc.) and any other sharps. Red Biohazard Bags. These items should be on every jobsite and at every fixed facility. These items can become part of the first aid kit(s). 7.8.2 Proper Sequence of Doffing Personal Protective Clothing Soiled or stained boot covers will be removed first. Then remove outer gloves, if present. Soiled or stained aprons or suits will be removed by rolling apparel into itself. This will keep the contaminants trapped inside and the clean part of the apparel will be on the outside. Remove surgical mask. Remove inner layer of gloves (or only layer of gloves). Remember to only the touch the inside of the second glove. The rule of thumb is to only touch Dirty to Dirty and Clean to Clean. Dispose of all PPE as biohazard waste. 7.9 Hepatitis B Vaccination 7.9.1 The Hepatitis B vaccination consists of a series of three (3) shots. The series must be completed once an individual begins the series. The second shot is received one (1) month after the first shot of the series, and the third shot is received five (5) months after the second shot of the series. Following the 3-dose series more than 90% of the individuals develop Hepatitis B antibodies. However, please note that 10% of the individuals given the series may not develop the antibodies. Immunity lasts for about 5- Policy: 025 Bloodborne Pathogens Rev. 03/02/10 Page 6

7 years at which time it may be necessary to have a booster shot to re-establish immunity. 7.9.2 Individuals receiving the vaccination have reported no serious adverse reactions. Some common reactions have been swelling and warmth around the injection site, headache, nausea, dizziness, and low grade fever which usually subsides within 48 hours. 7.9.3 The series is offered to Cianbro Safety Specialists and non-contracted janitorial personnel at no cost to them provided they complete the series. The series will also be offered to individuals who have suffered an exposure and have received a medical evaluation and counseling at no cost to them. 7.9.4 NOTE: If a Safety Specialist or janitorial personnel start the series and do not finish it, the cost will be incurred by the team member. 7.9.5 All new Safety Specialists and/or janitorial personnel shall be offered the HBV vaccination within 10 days of starting work at Cianbro Corporation. If team members decline the vaccination, they must sign the Hepatitis B Vaccination Decline Form (Appendix B). It must be made clear to the team member that if they choose to decline, they may later opt to receive the vaccine at no cost to them. 7.9.6 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 shall be made available. 7.9.7 The Regional Human Resource Managers must notify the Supervisor of the Corporate Safety Department whenever a person is hired or placed into a safety role/position. 7.10 Decontamination 7.10.1 Hand washing with an anti-bacterial soap is required whenever a person comes in contact with body fluids, even if personal protective equipment (i.e., gloves) has been worn. If facilities for hand washing are not and cannot be made available, an appropriate antiseptic hand cleaner in conjunction with clean towels or antiseptic towelettes must be available and the hands washed with an anti-bacterial soap and running water as soon as feasible. 7.10.2 If blood or other body fluids accumulate on a soil surface, the area must be cleaned by removing the soil and placing it in a red biohazard bag. All visible signs of stained soil must be placed into the red biohazard bag(s). 7.10.3 If blood or other body fluids accumulate on a solid, impervious surface (concrete floor, counter, table, etc.) wipe up the spill with paper towels or other absorbent material. After the area has been wiped up, flood the area with a solution of 1 ½ cup of liquid chlorine bleach to 1 gallon of fresh water (1 part bleach to 10 parts water) and allow to stand for 10 minutes. Do not pre-mix and store this solution, it must be mixed prior to immediate use. 7.10.4 If blood or other body fluids accumulate on a rug, it can either be handled as a biohazard waste and disposed of in a red biohazard bag or be washed with a strong germicidal chemical after it has been pre-cleaned. 7.10.5 Any items that come in contact with blood or other body fluids must be pre-cleaned and then disinfected using the 1:10 bleach to water mixture immediately after the incident. 7.10.6 If clothing becomes contaminated with blood or bodily fluids, remove as soon as feasible and place in a red biohazard bag. Items may be sent to a laundry service that is capable of handling this type of material. Once the items have been properly washed, they may be returned to the owner. 7.10.7 Individuals performing the decontamination must be properly protected with gloves, fluid proof suit and where applicable, respiratory protection and rubber boots. Goggles shall be worn over safety glasses or instead of safety glasses if splashing of blood or body fluids is likely. All personal protective clothing, gloves, boots, and respirator filters shall be handled as medical waste and placed in red biohazard bags. See Medical Waste Disposal section for proper disposal procedures. Policy: 025 Bloodborne Pathogens Rev. 03/02/10 Page 7

7.11 Medical Waste Disposal 7.11.1 The selection of procedures for disposal of infective waste is determined by the relative risk of disease transmission and application of local, state, and federal regulations. 7.11.2 Wastewater from decontamination procedures may be carefully poured down a drain connected to a sanitary sewer where permitted. 7.11.3 All other infectious waste destined for disposal shall be placed in a closable, leak proof container or bag that is red in color and labeled using the biohazard label. It will be closed prior to removal to prevent spillage or protrusion of contents during handling, storage, transport, or shipping. If outside contamination of a container or bag occurs or is likely to occur, then a second leak proof container or bag which is red, closable and labeled shall be placed over the outside of the first container/bag. 7.11.4 This type of material cannot go into the regular trash. This would be in violation of local, state, and federal regulations. 7.11.5 Clean Harbors or Laidlaw Environmental can be contracted for disposal of medical waste. This option of course can be expensive. Therefore, work with your local hospital and/or clinic to see if they will accept medical waste generated as a result of an incident. 7.12 Recordkeeping 7.12.1 All team member medical records will be kept confidential and will not be disclosed or reported without the team member s expressed written consent to any person within or outside the workplace, except as required by law. 7.12.2 Team member medical records shall be maintained for at least the duration of employment plus 30 years. 7.12.3 Team member medical records shall be provided upon written request of the team member or to anyone having written consent of the team member within 15 working days. Requests for medical records should be sent to OMC - Occupational Medical Consulting, RR 1, P.O. Box 3380, Leeds, Maine 04263, ATTN: Angela Berry Availability and transfer of all records must be in compliance with the requirements set forth in 29 CFR 1910.1020 (h). 7.12.4 Team member training records must be kept for a period of three (3) years. Please send all training records to the Manager of Environmental Hazards in the Corporate Safety Department. 8 Budget / Approval Process 8.1 It is the responsibility of each jobsite to procure a properly equipped first aid kit and the PPE required by this policy. 9 Related Documents 9.1 See attachments Policy: 025 Bloodborne Pathogens Rev. 03/02/10 Page 8

9.1 Appendix A Exposure Incident Report EXPOSURE INCIDENT REPORT PLEASE PRINT Date Report Completed: Exposed Team Member s Name: Team Member #: Home Phone: Jobsite Name: D.O.B.: Job Title: Exposed Team member s Hepatitis Vaccination Status: Date of Exposure: Time of Exposure: AM PM Location of Incident (home, jobsite, clinic, street, etc.) Be Specific Describe what task(s) were being performed when the exposure occurred - Be Specific Was the exposed individual wearing Personal Protective Equipment (PPE)? Yes No If yes, list: Did the PPE fail? Yes No If yes, explain how: Which body fluids did the exposed individual contact (blood, vomit, etc.) Be Specific What parts of the body were exposed or came in contact with the blood or potentially infectious materials? Be Specific Estimate the percent (%) of body surface that was exposed: How long was it exposed? Did a foreign body (needle, auto part, machine part, wires, etc.) penetrate the skin? Yes No If yes, what was the object(s)? Policy: 025 Bloodborne Pathogens Rev. 03/02/10 Page 9

Where did it penetrate? Was any fluid injected under or into the skin? Yes No Unknown If yes, what fluid? How much? What first aid activities were implemented after exposure? Source individual identified? Yes No Name of source individual: Source Hepatitis B vaccination status: Did source individual agree verbally to be tested? Corporate Safety Notified? Yes No Yes No Name of Corporate Safety Person Medical Evaluation on individual(s) performed? Yes No If yes, what is the name of the facility? Signatures: Exposed Team Member Foreman/Supervisor Project Manager Area Manager cc: Corporate Safety Department SD1024 Policy: 025 Bloodborne Pathogens Rev. 03/02/10 Page 10

9.2 Appendix B Hepatitis B Vaccination Decline Form HEPATITIS B VACCINATION DECLINE FORM I understand that due to my occupational exposure to blood or other potentially infectious materials I may be at risk of acquiring hepatitis B virus (HBV) infection. I have been given the opportunity to be vaccinated with hepatitis B vaccine, at no charge to myself. However, I decline hepatitis B vaccination at this time. I 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 charge to me. Team Member s Signature Date Witness Signature Date SD1023 Policy: 025 Bloodborne Pathogens Rev. 03/02/10 Page 11