Occupational Exposure to Bloodborne Pathogens Exposure Control Plan Employer: Nevada State Health Division Effective Date: May 5, 1992 Compliance Statement: In accordance with OSHA Bloodborne Pathogens standard, 29 CFR 1910.1030, the following exposure control plan has been developed. It is designed to eliminate or minimize employee occupational exposure to blood or other potentially infectious materials. I. Program Management: The Communicable Disease Committee (CD) will have the overall responsibility for the management, support and implementation of the Health Division s Bloodborne Pathogens Compliance Program. The CD Committee will develop any additional policies and practices needed to support the effective implementation of this plan, as well as review, revise or update this plan, as needed. Bureau Chiefs and Supervisors are responsible for exposure control in their areas and are responsible for ensuring that proper exposure control procedures are followed. Bureau Chiefs, Supervisor or designees, are responsible for providing information and training to all employees who have the potential for exposure to bloodborne pathogens. The exposure control plan will be reviewed annually, on or before May 5 th of each year, and updated when necessary. II. Exposure Determination: An exposure determination has been performed to determine which Health Division employees may incur occupational exposure to bloodborne pathogens. This determination has been made without regard to the use of personal protective equipment and regardless of the frequency of occupational exposure. The following job classifications have been determined to incur occupational exposure. Bureau of Disease Control & Intervention Services Communicable Disease Specialists Public Health Advisors Property Inventory Clerk Bureau of Family Health Services Community Nutrition Aides Registered Nurse (RN) Genetics Counselor Bureau of Laboratory Services Microbiologists Chemists Lab Assistants Bureau of Health Protection Services Bureau of Licensure & Certification Nevada WIC Program-Appendix Page 1 of 7
Bureau of Health Planning Bureau of Health Information and Data Management Bureau of Administrative Services In addition to the above job classifications, each Bureau will furnish a list of job classifications and tasks performed in which employees may have potential exposure to bloodborne pathogens. III. Methods of Compliance Universal Precautions Health Division employees who have potential exposure to bloodborne pathogens will observe universal precautions. All blood or other potentially infectious materials will be considered infectious regardless of the perceived status of the source patient. Universal Precautions: guidelines were first published by CDC in 1987 and they were revised in 1988 in Update: Universal Precautions for Prevention of Transmission of HIV, HBV, and Other Bloodborne Pathogens in Health Care Settings, MMWR, Vol. 37 No. 24:378-88 June 24, 1988. IV. Engineering controls Engineering and work practice controls will be utilized to eliminate or minimize exposure to employees. Where occupational exposure remains after institution of these controls, personal protective equipment shall also be utilized. Health Division programs utilize the following engineering controls: 1. Sharps containers are in use and available at every Health Division clinic and laboratory worksite. 2. Hand washing facilities (or antiseptic hand cleaners and towels or antiseptic towelettes) are available and accessible to all employees who have the potential for exposure. 3. Leak-proof, color-coded or labeled with a biohazard label, puncture-resistant (if necessary) specimen containers, are used by all Health Division facilities. Programs with unique or other engineering controls will specify these controls on the Engineering Control worksheet or reference procedure manuals where they can be found. The above controls will be examined and maintained on a regular schedule. The schedule for reviewing the effectiveness of the controls is outlined in the Engineering Control worksheet, Appendix B. V. Work Practice Controls: The following work practice controls have been in use and have been adopted as part of the OSHA Bloodborne Pathogen Compliance Program: Employees wash their hands immediately, or as soon as possible, after removal of gloves or other personal protective equipment. Following any contact of body areas with blood or any other infectious materials, employees wash their hands and any other exposed skin with soap and water as soon as possible. They also flush exposed mucous membranes (i.e., eyes, mouth) with water. Contaminated needles and other contaminated sharps are not bent, recapped or removed unless: there is no feasible alternative Nevada WIC Program-Appendix Page 2 of 7
the action is required by specific medical procedure the above recapping or needle removal is accomplished through the use of a medical device or a one-handed technique Contaminated reusable sharps (where applicable) are placed in appropriate containers immediately, or as soon as possible, after use. Eating, drinking, smoking, applying cosmetics or lip balm and handling contact lenses is prohibited in works areas where there is potential exposure to bloodborne pathogens. Food and drink is not kept in refrigerators, freezers, on countertops or in other storage areas where blood or other potentially infectious materials are present. Mouth pipetting/suctioning of blood or other infectious materials is prohibited. All procedures involving blood or other infectious materials minimize splashing, spraying or other actions generating droplets of these materials. Specimens of blood or other infectious materials are placed in designated leak proof containers, appropriately labeled, for handling and storage. If outside contamination of a primary specimen container occurs, the primary container shall be placed within an appropriately labeled secondary container which prevents leakage during the handling, processing, storage, transport or shipping of the specimen. Equipment which has become contaminated with blood or other potentially infectious materials shall be examined prior to servicing or shipping and shall be decontaminated as necessary unless the decontamination of the equipment is not feasible. Personal Protective Equipment All personal protective equipment (PPE) used by Health Division employees will be provided without cost to the employee. Personal protective equipment will be chosen based on the anticipated exposure to blood or other potentially infectious materials. The protective equipment will be considered appropriate only if it does not permit blood or other potentially infectious materials to pass through or reach the employees clothing, skin, eyes, mouth or other mucous membranes under normal conditions or use and for the duration of time which the protective equipment will be used. The following PPE includes, but is not limited to: Gloves Gowns Laboratory coats Face shields/masks Safety glasses Goggles Mouthpieces Resuscitation bags Pocket masks Examination gloves Other PPE (list) Hypoallergenic gloves are available to employees who are allergic to the gloves the Health Division normally supplies. Nevada WIC Program-Appendix Page 3 of 7
Each Bureau will reference how personal protective equipment will be provided, what procedures require protection and what type of protection, and who has the responsibility for PPE distribution. See Exposure Determination worksheet, Appendix A. All personal protective equipment will be cleaned, laundered and disposed of by the employer at no cost to the employee. The employer, at no cost, will make all repairs and replacements to employees. All garments, which are penetrated by blood, shall be removed immediately or as soon as possible. All personal protective equipment will be removed prior to leaving the work area. Each Bureau will reference where employees are expected to place the PPE upon leaving the work area and other protocols, etc. Gloves shall be worn where it is reasonably anticipated that employees will have hand contact with blood or other potentially infectious materials or when handling or touching contaminated items or surfaces. Disposable gloves are not to be washed or decontaminated for re-use and are to be replaced as soon as practical when they become contaminated, torn, punctured or otherwise lose their ability to function as an exposure barrier. Utility gloves are decontaminated for re-use unless they are cracked, peeling torn or exhibit other signs of deterioration, or when their ability to function as a barrier is compromised, at which time they are disposed of. Masks and eye protection (such as goggles, face shields, etc.,) are used whenever splashes or sprays may generate droplets of infectious materials. Housekeeping In general, all contaminated work surfaces will be decontaminated after completion of procedures and immediately or as soon as possible after any spill of blood or other potentially infectious materials, as well as the end of the work shift if the surface may have become contaminated since the past cleaning. Protective coverings, such as plastic wrap, aluminum foil or absorbent paper are removed and replaced as soon as possible when overtly contaminated or at the end of the work shift if they have been contaminated during the shift. All bins, pails, cans and similar receptacles shall be inspected and decontaminated on a regular basis. See Cleaning Schedule, Appendix C. Any broken glassware, which may be contaminated, will not be picked up directly with the hands, but by mechanical means such as dustpan and brush, tongs, forceps, etc. Each Bureau will reference the cleaning and decontamination schedule using the Cleaning Schedule worksheet, Appendix C. This schedule provides the following information: The area to be cleaned/decontaminated. Day and time of scheduled work. Cleaners and disinfectants to be used. Any special instructions that are appropriate. Nevada WIC Program-Appendix Page 4 of 7
Regulated Waste Disposal All contaminated sharps shall be discarded as soon as possible in sharp containers, which are located in each clinic/laboratory location where medical/laboratory procedures using sharps are used. Regulated waste other than sharps shall be placed in appropriate containers. They are discarded or bagged in containers that are closeable, puncture-resistant (when applicable), leak-proof if the potential for fluid spill or leakage exists, and red in color or labeled with the appropriate biohazard-warning label. Containers for this regulated waste are located throughout clinic/laboratory areas within easy access to employees and as close as possible to the sources of the waste. Waste containers are maintained upright, routinely replaced and not allowed to overfill. Contaminated laundry (where applicable) is handled as little as possible and is not sorted or rinsed where it is used. Whenever employees move regulated waste containers from one area to another the containers are immediately closed and placed inside appropriate secondary containers if leakage is possible. Programs with unique or other methods for handling regulated waste will outline or reference these procedures. VI. Hepatitis A & B Vaccination Program: All employees who have been identified as having exposure to blood or other potentially infectious materials will be offered the Hepatitis B vaccine (HBV), at no cost to the employee. The vaccine will be offered within 10 working days of their initial assignment to work involving the potential for occupational exposure to bloodborne pathogens, unless the employee has previously had HBV or wishes to submit to antibody testing which shows the employee to have sufficient immunity (anti-hbs positive or anti-hbc positive). Employees who decline the Hepatitis B vaccine will sign a waiver, which used the wording in Appendix A of the OSHA standard. See Hepatitis B Vaccination Declination Form, Appendix D. Employees who initially decline the vaccine but who later wish to have it may then have the vaccine provided at no cost. The employee s supervisor has the responsibility for assuring the vaccine is offered, that declination waivers are signed, and what health-care professional to refer the employee to for vaccination. This will be determined by each Bureau Chief. VII. Post-Exposure Evaluation and Follow-Up: When the employee incurs an exposure incident, it should be reported to his/her immediate supervisor or designee who has the responsibility to maintain records of exposure incidents. This person will be designated by each Bureau Chief. All employees who incur an exposure incident will be offered post-exposure evaluation and follow-up will include the following: Documentation of the route of exposure and circumstances related to the incident. See Post-Exposure Screening/Follow-up worksheet, Appendix E. If possible, the identification of the source individual and, if possible, the status of the source individual. The blood of the source individual will be tested (after consent is obtained) for HIV and hepatitis B infectivity (HbsAG positive). Nevada WIC Program-Appendix Page 5 of 7
Results of testing of the source individual will be made available to the exposed employee with the exposed employee informed about the applicable laws and regulations concerning disclosure of the identity an infectivity of the source individual. The employee will be offered the option of having their blood collected for testing of the employee s HIV/HBV serological status. The blood sample will be preserved for up to 90 days to allow the employee to decide if the blood should be tested for HIV serological status. However, if the employee decides prior to that time that testing will or will not be conducted, then the appropriate action can be taken and the blood sample discarded. The employee will be offered post-exposure prophylaxis in accordance with the current recommendations which are currently outlined in the CDC supplement: Guidelines For Prevention of Transmission of HIV & HBV to Health-Care & Public Safety Workers, USPHS, Feb. 1989. The employee will be given appropriate counseling concerning precautions to take during the period after the exposure incident. The employee will also be given information on what potential illnesses to be alert for and to report any related experiences to appropriate personnel. Each Bureau Chief will designate an individual to assure that the policy outlined here is effectively carried out as well as to maintain records related to this policy. The Bureau of Disease Control & Intervention Services (687-4800) has been designated to offer consultation for post exposure evaluation and follow-up for Health Division employees. Guidelines for post exposure evaluation and follow-up and information on the management of occupational exposures have been distributed to Health Division employees and is included in the appendices (Appendix G). Interaction with Health Care Professionals A written opinion shall be obtained from the health care professional who evaluates employees for the Health Division. Written opinions will be obtained in the following instances: When the employee is sent to obtain the Hepatitis B vaccine. Whenever the employee is sent to a Health care professional following an exposure incident. Health care professionals shall be instructed to limit their opinions to: Whether the Hepatitis B vaccine is indicated and if the employee has received the vaccine and/or for evaluation following an exposure incident. That the employee has been informed of the results of the evaluation That the employee has been told about any medical conditions resulting from exposure to blood or other potentially infectious materials. The written opinion to the employer is not to reference any personal medical information. VIII. Training: Training for all Health Division employees will be conducted prior to initial assignment to tasks where occupational exposure may occur. Training for employees will be provided at no cost to the employee and will include explanations of: Nevada WIC Program-Appendix Page 6 of 7
The OSHA Standard for Bloodborne Pathogens. Epidemiology and symptomatology of bloodborne diseases. Modes of transmission of bloodborne pathogens. (included in epidemiology of bloodborne diseases). This Exposure Control Plan (i.e., points of the plan, lines of responsibility, how the plan will be implemented, etc.). Procedures which might cause exposure to bloodborne pathogens. Control methods which will be used to control exposure to bloodborne pathogens. Personal protective equipment available and who should be contacted concerning availability. Post-exposure evaluation and follow-up. Biohazard signs and labels used. Hepatitis B vaccination program offered. Question and answer session. All employees will receive at least annual refresher training, conducted within one year of the employee s previous training. A variety of training methods may be used including videotapes, written materials, lectures, etc. Each Bureau Chief will designate an individual who will maintain a library of training materials and perform the required documentation. See Recordkeeping worksheet, Appendix F. IX. Recordkeeping: All records required by the OSHA standard will be maintained by each Bureau s personnel file. Annually, this file will be updated and a copy sent to the Health Division s personnel department to be included in the employee s permanent personnel file. Optimally, this could coincide with the employee s annual performance evaluation. See Recordkeeping worksheet, Appendix F. Medical records of exposure incidents must be maintained for 30 years from the exposure. Training records must be maintained for at least three years. Federal hepatitis B vaccination records must be kept at least 10 years. X. Dates: The OSHA Bloodborne Pathogen standard went into effect March 6, 1992. All provisions of the OSHA standard became effective July 6, 1992. Nevada WIC Program-Appendix Page 7 of 7