Blood Borne Pathogen Exposure Control Plan (ECP)

Transcription

1 Ryko Solutions, Inc. Blood Borne Pathogen Exposure Control Plan (ECP) Purpose: Ryko Solutions, Inc. is committed to providing a safe and healthful work environment for our entire staff. In pursuit of this endeavor, the following exposure control plan (ECP) is provided to eliminate or minimize occupational exposure to blood borne pathogens in accordance with OSHA standard 29 CFR , "Occupational Exposure to Blood borne Pathogens." The ECP is a key document to assist our firm in implementing and ensuring compliance with the standard, thereby protecting our employees. This ECP includes: * Determination of employee exposure; * Implementation of various methods of exposure control, including: * Universal precautions, * Engineering and work practice controls, * Personal protective equipment, and * Housekeeping * Hepatitis B vaccination; * Post-exposure evaluation and follow-up; * Communication of hazards to employees and training; * Recordkeeping; and * Procedures for evaluating circumstances surrounding an exposure incident. The methods of implementation of these elements of the standard are discussed in the subsequent pages of this ECP. Failure to follow this policy could lead to serious injury, disease, or death ENFORCEMENT NOTICE Failure to follow this policy can lead to disciplinary action up to and including termination. Administrative Duties The EHS Manager is responsible for the implementation of the ECP. EHS Manger will maintain, review, and update the ECP at least annually, and whenever necessary to include new or modified tasks and procedures. Those employees who are determined to have occupational exposure to blood or other potentially infectious materials (OPIM) must comply with the procedures and work practices outlined in this ECP. Ryko Solutions, Inc. ECP Page 1 of 6

2 The EHS Manager will maintain and provide all necessary personal protective equipment (PPE), engineering controls (e.g., sharps containers), labels, and red bags as required by the standard. The EHS Manager shall ensure that adequate supplies of the aforementioned equipment are available in the appropriate sizes The EHS Manager and Human Resources Administrator will be responsible for ensuring that all medical actions required are performed and that appropriate employee health and OSHA records are maintained. The EHS Manager will be responsible for training, documentation of training, and making the written ECP available to employees and inspecting agencies. Employee Exposure Determination The following is a list of all job classifications at our establishment in which all employees have occupational exposure: All full time employees Part-time, temporary, contract, and per diem employees are covered by the standard. How the provisions of the standard will be met for these employees is described in this ECP, if applicable. Methods of Implementation and Control Universal Precautions All employees will utilize universal precautions. Failure to utilize universal precautions can lead to serious injury, disease, or death. Exposure Control Plan Employees covered by the blood borne pathogens standard receive an explanation of this ECP during their initial training session. It will also be reviewed in their annual refresher training. All employees have an opportunity to review this plan at any time during their work shifts by contacting their supervisor or EHS Manager. The EHS Manager is responsible for reviewing and updating the ECP annually or more frequently if necessary to reflect any new or modified tasks and procedures that affect occupational exposure and to reflect new or revised employee positions with occupational exposure. The review and update of such plans must also: 1. Reflect changes in technology that eliminate or reduce exposure to blood borne pathogens 2. Document annually consideration and implementation of appropriate commercially available and effective safer medical devices designed to eliminate or minimize Ryko Solutions, Inc. ECP Page 2 of 6

3 occupational exposure. Engineering and Work Practice Controls Engineering and work practice controls will be used to prevent or minimize exposure to blood borne pathogens. The specific engineering controls and work practice controls used are listed below: 1. Universal Precautions 2. Annual Bloodborne Pathogen training Sharps disposal containers. Sharps containers are provided at Poet Biorefining-Jewell. This facility identifies the need for changes in engineering control and work practices through: 1. Safety Committee activities 2. OSHA records review We evaluate the need for new procedures or new products by: 1. Safety Committee evaluation 2. Management team evaluation The following staff are involved in this process: Safety committee members, to include hourly employees from maintenance, operations, field service and sales, and office staff as well as at least one manager from the same departments, and either the EHS Manager or the Vice President of Human Resources. Personal Protective Equipment (PPE) PPE is provided to all employees at no cost. Training is provided by the EHS Manager in the use of the appropriate PPE for the tasks or procedures employees will perform at initial training and annually thereafter. The types of PPE available to employees in the form of kits that contain: 1. Gloves 2. Eye protection 3. Face shields 4. Disposable suits. Emergency BBP kits are located at first aid cabinets in the plant/warehouse/service vehicle. Each first aid kit is also equipped with cleanup solution and wipes. Replacement of kits and materials shall be responsibility of the person assigned the kit. All employees using PPE must observe the following precautions: 1. Wash hands immediately or as soon as feasible after removal of gloves or other PPE 2. Remove PPE after it becomes contaminated, and before leaving the work area 3. Wear appropriate gloves when it can be reasonably anticipated that there may be hand Ryko Solutions, Inc. ECP Page 3 of 6

4 contact with blood or OPIM, and when handling or touching contaminated items or surfaces; replace gloves if torn, punctured, contaminated, or if their ability to function as a barrier is compromised. Never wash or decontaminate disposable gloves for reuse 4. 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 5. Remove immediately or as soon as feasible any garment contaminated by blood or OPIM, in such a way as to avoid contact with the outer surface Failure to follow the above precautions could lead to serious injury, disease, or death. The procedure for handling used PPE is as follows: 1. Dispose of into a bio hazard bag. 2. Notify the EHS Manager, Territory Manager, or appointed designee 3. The Manager or appointed designee will make arrangements for the contaminated items to be properly and safely disposed of through health care providers or waste collection providers. Housekeeping Regulated waste is placed in containers that are closable, constructed to contain all contents and prevent leakage, appropriately labeled or color-coded (see Labels section), and closed prior to removal to prevent spillage or protrusion of contents during handling. The procedure for handling other regulated waste is: 1. Towels, clothing, etc.: Dispose into a bio hazard bag 2. Broken glassware that may be contaminated is picked up using mechanical means, such as a brush and dust pan. The material will be put into a bio-hazard container 3. The technical Manager or his appointed designee will make arrangements for the contaminated items to be properly and safely disposed of through our health care providers Never hold a bio-hazard back from the bottom. Items in the bag may puncture through and expose you to the bio-hazard which could lead to serious injury, disease, or death. Labels The following labeling method(s) is used in this facility: 1. Red bags containing the universal bio-hazard symbol Post-exposure Evaluation and Follow-Up Should an exposure incident occur, the EHS Manager or Human Resources Administrator must be contacted immediately. In the event that the EHS Manager or Human Resources Administrator is unavailable, the department manager must be contacted. An immediately available confidential medical evaluation and follow-up will be conducted by a local medical clinic selected by Ryko or field service manager. Following the initial first aid (clean the wound, flush eyes or other mucous membranes, etc.), the following activities will be Ryko Solutions, Inc. ECP Page 4 of 6

5 performed: 1. Document the routes of exposure and how the exposure occurred 2. Identify and document the source individual (unless we can establish that identification is infeasible or prohibited by state or local law) 3. Provide the collected information to the health care provider Administration of Post-Exposure Evaluation and Follow-up The EHS Manager or designated appointee ensures that health care professional(s) responsible for employee's post-exposure evaluation and follow-up are given a copy of OSHA's bloodborne pathogens standard. The EHS Manager ensures that the health care professional evaluating an employee after an exposure incident receives the following: 1. A copy of 29 CFR A description of the employee's job duties relevant to the exposure incident 3. Route(s) of exposure 4. Circumstances of exposure 5. If possible, results of the source individual's blood test 6. Relevant employee medical records Procedures for Evaluating the Circumstances Surrounding an Exposure Incident The EHS Manager, Human Resources Administrator, and department manager will review the circumstances of all exposure incidents to determine: 1. If engineering controls in use at the time 2. Work practices followed 3. A description of the device being used 4. Protective equipment or clothing that was used at the time of the exposure incident (gloves, eye shields, etc.) 5. Location of the incident (Grains, distillation, etc) 6. Procedure being performed when the incident occurred 7. Employee's training If it is determined that revisions need to be made, the EHS Manager or designated appointee will ensure that appropriate changes are made to this ECP. Employee Training All employees will receive training upon initial employment and annually thereafter conducted by the EHS Manager or appointed trainer(s). All employees who have occupational exposure to bloodborne pathogens receive training on the epidemiology, symptoms, and transmission of bloodborne pathogen diseases. In addition, the training program covers, at a minimum, the following elements: 1. A copy and explanation of the standard 2. An explanation of our ECP and how to obtain a copy 3. An explanation of methods to recognize tasks and other activities that may involve exposure to blood and OPIM, including what constitutes an exposure incident 4. An explanation of the use and limitations of methods that will prevent or reduce Ryko Solutions, Inc. ECP Page 5 of 6

6 exposure including appropriate engineering controls, work practices, and personal protective equipment 5. An explanation of the types, uses, location, removal, handling, decontamination, and disposal of PPE 6. An explanation of the basis for PPE selection 7. Information on the hepatitis B, hepatitis C, and HIV 8. Information on the appropriate actions to take and persons to contact in an emergency involving blood or OPIM 9. An explanation of the procedure to follow if an exposure incident occurs, including the method of reporting the incident and the medical follow-up that will be made available 10. An explanation of the signs and labels and/or color coding required by the standard and used at this facility 11. An opportunity for interactive questions and answers with the person conducting the training session. Training materials for this facility are available at Ryko Solutions, Inc. Grimes and available online through Ryko s internal file access systems. Recordkeeping Training Records Training records are completed for each employee upon completion of training. These documents will be kept for at least three years at the Administrative Office. The training records include: 1. The dates of the training sessions 2. The contents or a summary of the training sessions 3. The names of the persons conducting the training 4. The names and job titles of all persons attending the training sessions Employee training records are provided upon request to the employee or the employee's authorized representative within 15 working days. Such requests should be addressed to the EHS Manager or Human Resources Administrator. Medical Records Employee medical records are provided upon request of the employee or to anyone having written consent of the employee within 15 working days. Such requests should be sent to the EHS Manager or Human Resources Administrator. OSHA Recordkeeping An exposure incident is evaluated to determine if the case meets OSHA's Recordkeeping Requirements (29 CFR 1904). This determination and the recording activities are done by EHS Manager or his designated appointee. Ryko Solutions, Inc. ECP Page 6 of 6