Page 1 of 7 Introduction Since one cannot tell who may be carrying HIV, hepatitis B, or any bloodborne pathogen, all workers who may contact human blood or body fluids are at risk. For this reason, the Occupational Safety and Health Administration recently passed the Bloodborne Pathogens Standard (OSHA 1910.1030). All school personnel are covered by OSHA's Bloodborne Pathogens Standard because they may need to respond in an emergency and administer first aid to a student and/or staff member and that person may be carrying a fatal disease and not even know it. OSHA's Bloodborne Pathogens Standard requires all school districts to create and make available to every employee an Exposure Control Plan (ECP). This Plan will: Identify the personnel covered by the Standard. Analyze the potential hazard of various jobs. Determine what measures will be taken to reduce the risk of exposure. The keys to preventing infection are: Understanding the dangers you face. Knowing how to protect yourself. We are concerned with the health and welfare of all employees and students in Community Unit district 185 and will work toward providing necessary services to assure both are safeguarded. Overview EXPOSURE CONTROL PLAN This plan is written to meet the Occupational Safety and Health Administration's (OSHA) compliance standards on Occupational Exposure to Bloodborne Pathogens. The purpose of the law is to eliminate or reduce occupational exposure to Hepatitis B Virus (HBV), Human Immunodeficiency Virus (HIV), and other bloodborne pathogens. The following includes the contents of the exposure control plan which will be reviewed and revised annually by the Superintendent or his designee: A. Exposure determination B. Compliance schedule and methodology C. System to provide the Hepatitis B Vaccine D. Post-exposure evaluation and follow-up E. Interaction with health care professionals F. Employee training G. Record keeping The primary goal of the plan is to prevent staff and students from being exposed to bloodborne disease-causing pathogens. Elimination or reduction of occupational exposure to bloodborne pathogens must be based on the four methods of compliance to include: (a) universal precautions; (b) the development and implementation of work practice controls to remove the hazards and improve the manner of performing an exposure prone task; (c) the availability of personal protective equipment; and (d) housekeeping procedures to ensure that employee safeguards are provided.
Page 2 of 7 DEFINITIONS related to this Exposure Control Plan as defined by OSHA: 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). Contaminated means the presence or the reasonably anticipated presence of blood or other potentially infectious materials or may contain sharps. 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, self-sheathing needles) that isolate or remove the bloodborne pathogens hazard from the workplace. Exposure Incident means a specific eye, mouth, other mucous membrane, non-intact skin, or parenteral contact with blood or other potentially infectious materials that results from the performance of an employee's duties. Handwashing Facilities means a facility providing an adequate supply of running potable water, soap and single use towels or hot air drying machines. HBV means hepatitis B virus. HIV means human immunodeficiency virus. 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 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. Parenteral means piercing mucous membranes or the skin barrier through such events as needlesticks, 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. 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.
Page 3 of 7 Sharps means any object that can penetrate the skin including, but not limited to, needles, scalpels, broken glass, and exposed ends of dental wires. 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. An example would include, but not be limited to, trauma victims/ students. 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 Area is that space where a person has been treated. Work Practice Controls means controls that reduce the likelihood of exposure by altering the manner in which a task is performed (e.g., sweeping up broken glass rather than picking it up). A. EXPOSURE DETERMINATION OHSA requires employers to perform an exposure determination concerning which employees may incur occupational exposure to blood or other potentially infectious materials. The exposure determination is made without regard to the use of personal protective equipment (i.e., employees are considered to be exposed even if they wear gloves). Group 1: This includes all job classifications in which all employees may be expected to incur such occupational exposure, regardless of frequency. Group 2: This includes all job classifications in which some employees may have occupational exposure. Not all employees in these classifications would be expected to incur exposure to blood or other potentially infectious materials. Tasks or procedures that would cause these employees to have occupational exposure are listed to clearly understand which employees in this group are considered to have occupational exposure. Group 1 job classifications are: Principal/Assistant Principal Elementary School Secretary District Nurse Junior/Senior High School Infirmary Staff Junior/Senior High School Hall Monitor TMH and BD Teacher Program Assistant in TMH and BD classrooms Preschool Teacher Physical Education Teacher Coach Athletic Trainer Janitor Recess Supervisor Group 2 job classifications and associated tasks are: Classroom Teacher: to provide immediate health care in absence of the school nurse and to intervene during altercations between students. B. COMPLIANCE SCHEDULE AND METHODOLOGY A written plan shall be developed for initiation by March 30, 1993. The written plan shall provide for initial employee training by April 29, 1993, with annual refresher training, thereafter. Additional provision shall be made to train new hires. An immunization schedule shall be implemented by May 29, 1993.
Page 4 of 7 Compliance Methods: Engineering and work practice controls will be utilized to eliminate or minimize exposure to employees in all buildings. At each facility the following engineering controls will be utilized: - Sharps containers will be located in the main office of each elementary school building. - A sharps container will be located in the infirmary at the Junior/Senior High School. - Anti-viral wipettes are included in the first aid kit at each building located in the main office at each grade school and in the infirmary at the Junior/Senior High School. - Disposable gloves will be located in the main office of each building. - A CPR microshield shall be located in each building's first aid kit. The above controls will be examined and maintained on a regular schedule. The District Nurse will be responsible for reviewing the effectiveness of the individual controls once per week and will replace the equipment as needed. Universal precautions will be observed in all buildings of the School District to minimize the risk of exposure to blood and/or body fluids of all persons, regardless of health status or diagnosis. Universal precautions include, but are not limited to, the following: 1. Hands should always be washed after contact with body fluids. Examples of this in the school environment include, but are not limited to: a. use of the bathroom b. caring for a runny nose c. cleaning up body secretions (i.e. urine, feces, or vomit) d. treating an open wound If hands come in contact with potentially infectious materials, they should be immediately washed with soap and warm water for 2-3 minutes. Germicidal soap is available in each attendance center. Hand-washing facilities are located in the work area and/or adjacent to the work area in each building. 2. All personal protective equipment used at each facility will be provided without cost to employees and disposed of by the employer at no cost to employees after being used. Each principal will make staff aware of the location of the personal protective equipment in the building. a. Gloves must be worn where there is contact with or where it is reasonably anticipated that employees will have hand contact with blood, or other potentially infectious materials, non-intact skin, and mucous membranes. Gloves are available in the work area of each school building. It is recommended that each staff member keep a pair close at hand. The following general guidelines apply to glove usage: (1) Use gloves for assisting with cuts, scratches, or other breaks in the skin. (2) Use gloves when cleaning up blood or body fluids containing blood. (3) Gloves should be used one time and then thrown away. Replace torn or punctured gloves immediately. Hands should be washed after the gloves have been discarded. b. A CPR microshield should be worn during mouth-to-mouth resuscitation to minimize the spread of infection. These are located in each building's first aid kit.
Page 5 of 7 3. All contaminated work surfaces will be decontaminated immediately after any contact with blood or other potentially infectious materials with a 1-10 dilution of household bleach. 4. Staff or students with open lesions or weeping dermatitis must refrain from direct contact and from handling blood or body fluids containing blood. 5. Cleaning up after a potentially infectious materials incident (vomit, urine, stool, blood, et cetera) will follow this procedure: a. Assess the amount and type of potentially infectious materials. b. Use personal protective equipment as needed. Latex gloves are essential for cleaning up all potentially infectious spills. c. Use a decontaminant agent (i.e. Isolyser) to congeal and disinfect the potentially infectious fluids. d. Sweep up the potentially infectious material and put into the hazardous waste container located in designated areas in each building. e. Disinfect the contaminated area with the bleach solution (1 part bleach with 10 parts water) or germicide of choice. f. Disinfect clean-up equipment (brooms, mops, dust pans, etc.) with bleach solution. g. Cloth rags must be machine washed with detergent and machine dried (if contaminated must label for laundry). h. Dispose of PPE in a hazardous waste container and wash hands with an antibacterial soap. 6. Routine cleaning of areas daily contaminated with body fluids such as rest rooms, nurse's offices, and shower facilities will follow this procedure: a. Schedule these areas to be cleaned daily (all areas must have a schedule). b. Gather cleaning and disinfecting equipment. c. Put on latex gloves. d. Dispose of hazardous waste in designated container. Place other waste in regular waste disposal container. e. Clean surface areas (sinks, toilets, and floors) in this order using approved disinfectant or germicide. f. Clean and disinfect equipment. g. Cloth rags must be machine washed with detergent and machine dried. h. Dispose of gloves in a hazardous container and wash hands with an antibacterial soap. 7. Regulated waste will be disposed of in the following manner: Everything that can be flushed will be. Solids will be placed in a metal can with a biohazard sign (Appendix D) on it. These containers will be maintained by the custodial staff of each school building. 8. Laundry Procedures Laundry contaminated with blood or other potentially infectious materials will be handled as little as possible. The laundry will be decontaminated and the staff member will be given a reasonable length of leave time to change clothes.
Page 6 of 7 C. SYSTEM TO PROVIDE THE HEPATITIS B VACCINE All employees who have been identified as having exposure to blood or other potentially infectious materials will be offered the Hepatitis B vaccine 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 blood or other potentially infectious materials. All employees receiving the vaccine must attend the Bloodborne Standards Training prior to the immunization. The School District is purchasing vaccine through a Federal Purchasing Contract, and the McDonough County Health Department will be responsible for administering the vaccine. Employees who decline the Hepatitis B vaccine will sign a waiver (Appendix A). Employees who initially decline the vaccine, but who later wish to have it, may have the vaccine provided at no cost. The District Nurse will be responsible for assuring that the vaccine is offered and the waivers signed. The McDonough County Health Department will administer the vaccine. D. POST-EXPOSURE EVALUATION AND FOLLOW-UP When an employee incurs an exposure incident, it should be reported to the building principal who will report to the District Nurse. Records (Appendix C) will be kept in the individual buildings. All employees who incur an exposure incident will be offered post-exposure evaluation and follow-up in accordance with the OSHA standard. This follow-up will include: - Documentation of the route of exposure and the circumstances related to the incident. - If possible, the identification of the source individual. The blood of the source individual will be tested (after consent is obtained) for HIV/HBV infectivity. - 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 and infectivity of the source individual. - The employee will be offered the option of having his/her blood collected for testing of the employee's HIV/HBV serological status. However, if the employee decides prior to that time that testing will 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 of the U.S. Public Health Service. - 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. - The District Nurse, in cooperation with the building principals, has been designated to assure that the policy outlined here is effectively carried out as well as to maintain records related to this policy.
Page 7 of 7 E. INTERACTION WITH HEALTH CARE PROFESSIONALS A written opinion shall be obtained from the health care professional who evaluates employees of the School District. Written opinions will be obtained in the following instances: 1. When the employee is sent to obtain the Hepatitis B. vaccine. 2. 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: 1. Whether the Hepatitis B Vaccine is indicated and if the employee has received the vaccine, or for the evaluation following an incident: 2. That the employee has been informed of the results of the evaluation; and 3. 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 make reference to any personal medical information. F. EMPLOYEE TRAINING Training for all employees will be the responsibility of the District Nurse. Training will be conducted using videotapes, written materials, and question/answer sessions. Training will be conducted at each school building during the first nine weeks of the school year. All employees will receive annual refresher training within one year of the previous training. The outline for the training materials is located in the Board Office. Training for employees will include an explanation of the following: 1. An accessible copy of the regulatory text of this standard; 2. Epidemiology and symptomatology of bloodborne diseases; 3. Modes of transmission of bloodborne pathogens; 4. The District's Exposure Control Plan (i.e., points of the plan, lines of responsibility, how the plan will be implemented, etc.); 5. Procedures/situations which might cause exposure to blood or other potentially infectious materials in the District; 6. Control methods which will be used to control exposure to blood or other potentially infectious materials; 7. Personal protective equipment availability and who should be contacted; 8. Post-exposure evaluation and follow-up; 9. Signs/label/color coding required by OSHA; 10. The District's Hepatitis B vaccination program. G. RECORD KEEPING All records required by the OSHA standard will be maintained by the District Nurse. Adopted 9-16-97