Safety Manual. Blood Borne Pathogens Program (For General Employees)
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1 Page 1 of 7 Sect: 1.0 Purpose 2.0 Scope Ardent s HSE Manual contains two Blood Borne Pathogen programs; one for general employees and one for trained first aid providers. The purpose of this Blood Borne Pathogen Program for General Employees is to develop awareness of the risks associated with Blood Borne pathogens in employees who are not exposed to blood and other infectious substances during the performance of their normal work duties. This Blood Borne Pathogen Program for General Employees is intended for use by all employees except those with occupational exposure risks. See Ardent s supplement to this program titled, - Exposure Control Plan for employees with occupational exposure. Section.A, Ardent document, A. It should be noted that OSHA Directive CPL states that the blood Borne pathogen standard does not apply to the construction industry and; the company is not required to offer the hepatitis B vaccine, prior to exposure, to any person who renders first aid only as a collateral duty. This collateral duty definition applies to Ardent employees trained in the administration of first aid but would not apply to employees hired specifically to staff a first aid facility. 3.0 Regulatory References The Blood Borne Pathogen Program for General Employees is intended to satisfy elements of the following regulatory requirements: o 29 CFR Policy It is Ardent s policy that: o All employees are provided training in blood borne pathogen awareness. o Ardent will offer the hepatitis B vaccine to any employee of the company who has been potentially exposed to blood borne pathogens when the exposure is witnessed by an Ardent supervisor or when an employee reports a potential exposure to an Ardent supervisor or manager. The choice for HBV vaccination is not mandatory. If an affected Employee chooses not to have the vaccination at the initial offering, they will have the
2 Page 2 of 7 Sect: 5.0 Responsibilities opportunity to be vaccinated when they are ready. The Company will document the offer, acceptance or declination with the Hepatitis B Vaccination Consent-Declination Form (Ardent document no: O-SS-FRM-0081). 5.1 Management shall be responsible for the following: Ardent s Corporate HSE Director or designated representative will ensure that the Blood Borne Pathogen Program for General Employees is communicated to all employees. Management will ensure proper implementation of the program through training, jobsite and facility safety audits and record keeping. Business Unit Managers are responsible for communication of the program to all employees assigned to their respective business units. Review this Blood Borne Pathogen Program annually and update as necessary. Ensure that a copy of Blood Borne Pathogen Program is available and accessible to employees and any OSHA representative upon request. Provide or make available the hepatitis B vaccine and vaccination series to all employees who have been potentially exposed to blood borne pathogens in the workplace. 5.2 Supervision shall be responsible for the following: Understand and enforce the Blood Borne Pathogen Program. Provide guidance to employees on recognition and control of infection hazards. Implement site controls isolating employees from infection hazards. Immediately inform management of any infection hazard exposures and near miss events. Provide immediate on-the-spot training for all employees on the jobsite regarding Ardent s Blood Borne Pathogen Program when necessary. Enforce PPE requirements and enforce discipline as necessary for PPE or any hazard control violation. 5.3 Employees shall be responsible for the following: Participate in and understand training. Follow the rules and procedures regarding infectious hazard protection. Participate in JSA and hazard recognition activities. Inform your supervisor of concerns regarding infectious hazards in the workplace. Stop the work and immediately inform your supervisor if you believe an operation is unsafe or presents hazards that have not been identified and/or controlled.
3 Page 3 of 7 Sect: Wear appropriate PPE. 6.0 Definitions Biological Hazard. The term biological hazard or biohazard is taken to mean any viable infectious agent that presents a risk, or a potential risk, to the well being of humans. Medical Wastes/Infectious Wastes. All waste emanating from human or animal tissues, blood or blood products or fluids. This includes used first aid bandages, syringes, needles, sharps, material used in spill cleanup and contaminated PPE or clothing. Universal Precautions. Refers to a system of infectious disease control that assumes that every direct contact with body fluids is infectious and requires every employee exposed to be protected as though such body fluids were infected with blood-borne pathogens. All infectious/medical material must be handled according to Universal Precautions (OSHA Instruction CPL A) 7.0 Hazards Unprotected exposure to body fluids presents the possible risk of infection from a number of blood borne pathogens, notably Hepatitis and HIV. 7.1 Hazard Control o Provide employee awareness training to prevent untrained employees from handling potentially infectious substances. o Provide necessary PPE at all jobsites to reduce the risk of contamination from body fluids. o Provide Blood Borne Pathogen Program training to all employees trained in the administration of first aid. 8.0 General Procedures All body fluids will be considered infected with blood borne pathogens. Thus all employees exposed to body fluids must be protected from potential contamination. A placard communicating the Universal Precautions and General Safety Rules can be found in Appendix B, Ardent document no: O-SS-PLC Universal Precautions Gloves - Gloves must be worn when providing assistance to an injured person when the injuries have resulted in the release of blood or other bodily fluids. Gloves must be made of appropriate disposable material, usually intact latex or vinyl Eye Protection - Eye protection should be worn to protect against splashes and sprays. Safety glasses do not provide sufficient protection and should be replaced or supplemented by the use of goggles and/or face shields.
4 Page 4 of 7 Sect: Hand Washing - Employees must wash their hands immediately, or as soon as possible, after removal of gloves or other personal protective equipment and after hand contact with blood or other potentially infectious materials Contaminated PPE - All personal protective equipment must be removed immediately upon leaving the work area, and if this equipment is overtly contaminated, it must be placed in an appropriate area or container for storage, washing, decontamination, or disposal Segregating Contaminate Waste/Equip. - All PPE, first aid supplies, and cleaning materials exposed to blood must be segregated from other waste at the point of origin. Contact the local safety coordinator for handling and removal of infectious waste. Personal clothing contaminated with infectious waste must be removed immediately and treated in the same manner as other infectious waste Cleanup of Bodily Fluids - Cleanup of body fluid spills (e.g. blood) will be performed by employees trained in the Blood Borne Pathogen Program for First Aid providers. Any spills of body fluid will be presoaked (sprayed on the affected area) with antibacterial/viral solution for 10 minutes before being removed. (Note: Gloves and eye protection should be worn when handling spills of body fluids) All items used to clean body fluid spills will be handled in accordance with the preceding paragraph Reporting - Any suspected exposure to HIV/HAV/HBV through human body fluid contact shall be reported to your supervisor immediately. 8.2 Hepatitis-B Virus (HBV) Vaccinations - Any employee suspecting that he or she has been exposed to blood must immediately report the suspected exposure to his or her immediate supervisor. The supervisor will relay the incident to the HSE Director and the employee will be offered Hepatitis-B Virus (HBV) Vaccinations at Ardent expense. Additionally, Ardent will provide for the employee to be tested for HIV/HAV/HBV at Ardent Expense. Following the initial blood test at time of exposure, seronegative Employees will be retested at 6 weeks, 12 weeks and 6 months to determine if transmission has occurred. 8.3 Hepatitis B Vaccine Form - Ardent will offer the hepatitis B vaccine to any employee of the company that has been potentially exposed to blood borne pathogens when the exposure is witnessed by an Ardent supervisor or when an employee reports a potential exposure to an Ardent supervisor or manager. The Company will document the offer, acceptance or declination with the Hepatitis B Vaccination Consent-Declination Form (Ardent document no: O-SS-FRM-0081).
5 Page 5 of 7 Sect: 8.4 Confidentiality - During all phases of Post Exposure, the confidentiality of the affected Employee and exposure source will be maintained on a "need to know basis". The Blood-Borne Pathogens Exposure and Treatment Form, (Ardent document no: O- SS-FRM-0080), is used to document the exposure and offer of medical assistance to the affected Employee and use the Medical Consent Form for Blood Borne Pathogens Testing (Ardent document no: O-SS-FRM-0082), for the exposure source. The results of any HIV/HAV/HBV tests conducted will be provided to the exposed and source Employees within 5 business days of receipt. 9.0 Training A copy of the forms mentioned in this section can be found in Appendix A of the Ardent HSE Manual. All employees will receive Blood Borne Pathogen awareness training. 9.1 Training Content - All new and current affected Employees will be trained initially and annually thereafter. The content of the training program will include: Company Policy Types and transmission of Blood Borne Pathogens Hazard Recognition, Signs & Labels Universal Precautions & General Safety Rules Use and selection of Personal Protective Equipment Post Exposure Treatment and Procedures HBV Vaccinations 9.2 Personnel Training All Ardent employees will receive Blood Borne Pathogen Awareness training. 9.3 Training Frequency Blood Borne Pathogen Awareness training and re-training shall be provided as following: 1) Initially upon hire as part of the New Employee Safety Orientation. 2) Annually - All employees will receive annual Blood Borne Pathogen Awareness training through the Toolbox Safety meetings, weekly safety meetings or quarterly safety meetings. 3) Upon changes in the for General Employees Reporting & Recordkeeping All exposure incidents shall be reported. All exposure events resulting in injury, illness of an employee shall be recorded as Incidents on an Ardent Incident Report. Failures in containment, control methods, isolation, etc., not resulting in employee injury, illness or exposure, shall be recorded as near miss events on an Ardent Near Miss Report.
6 Page 6 of 7 Sect: All injuries from contaminated sharps shall be logged in the Sharps Injury Log. The log shall contain the following minimum information: 1) Type and brand of device involved 2) Area or department where the incident occurred 3) Explanation of the incident Confidentiality of the injured employee shall be maintained. OSHA 300 Log The following will be recorded on the OSHA 300 Log of Occupational Injuries and Illnesses: o o Occupationally contracted HBV or HIV will be recorded on the OSHA 300 Log of Occupational Illnesses Exposures to blood borne pathogens from contact with sharps shall be recorded on the OSHA 300 Log of Occupational Injuries and Illnesses if treatment such as gamma globulin, hepatitis B immune globulin or hepatitis B vaccine is prescribed by a Physician. Control & Retention Records associated with this program shall be handled in the following manner: o Custodian Ardent s Director of HS&E shall be the custodian of employee exposure and medical records and accountable for compliance with 29 CFR o Incident - shall be handled per the Incident Reporting and Record Keeping Program. o Training records - shall be maintained for a minimum of 3 years. o All other medical records - shall be handled per the Access to Medical Records Program, HSE Manual Section, E.1, Ardent document O-SS-SPP o Availability - All recordkeeping required by this program will be available upon request by the employee, to anyone having consent of the employee, and the required Health Officials. In the event the company no longer exists, Ardent will contact the designated Health Officials for their disposition 3 months prior to disposal of the records. o Retention - Training Certificates, HBV Vaccinations Consent Forms, and exposure reports will be maintained for 30 years Attachments 11.1 Appendix A, Blood-Borne Pathogens Exposure and Treatment Form, Ardent document no: O-SS- FRM-0080.
7 Page 7 of 7 Sect: 11.2 Appendix A, Hepatitis B Vaccination Consent-Declination Form, Ardent document no: O-SS-FRM Appendix A, Medical Consent Form for Blood Borne Pathogens Testing, Ardent document no: O-SS- FRM Appendix B, Universal Precautions and General Safety Rules placard, Ardent document no: O-SS- PLC-0077.
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