Bloodborne Pathogens

Transcription

1 Bloodborne Pathogens Exposure Control Plan West Stones Crossing Road Greenwood, IN (317) Revision Date 6/9/14 1

2 BLOODBORNE PATHOGENS EXPOSURE CONTROL PLAN Center Grove School Community School Corporation is committed to providing a safe and healthy 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 bloodborne pathogens in accordance with OSHA standard 29 CFR The ECP is a key document to assist our Corporation 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, Hand washing and Housekeeping Hepatitis B vaccination Post-exposure evaluation and follow-up Communication of hazards to employees and training Recordkeeping Procedures for evaluating circumstances surrounding an exposure incident; The methods of implementations of these elements of the standard are discussed in the subsequent pages of this ECP Program Administration The Human Resources Department with the help of the Health Services Department will ensure effective implementation of the ECP. The Health Services Coordinator (HSC) will maintain, review, and update the ECP at least annually, and whenever necessary to include new or modified tasks and procedures. All employees covered receive an explanation of this ECP during their hiring training session. It will also be reviewed in their annual refresher training. All employees have the opportunity to review this plan at any time during their work shifts by contacting their building principal, nurse or clinic assistant, Department Director or the Health Services Coordinator. Each building Nurse or Clinic Assistant, Head Custodian or Director 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. Maintenance and Health Services will ensure that adequate supplies of the aforementioned equipment are available in the appropriate sizes. Building contacts and phone numbers: Human Resources Director Sally Hacker Human Resources - Certified Lynae Froman Human Resources Support Lynn Williams Health Services Coordinator Carla Slauter, RN Maintenance Director Chris Painter Transportation Director Rick Pederson Center Grove Elementary Nurse Custodian Maple Grove Elementary Nurse Custodian North Grove Elementary Clinic Assistant Custodian Pleasant Grove Elementary Clinic Assistant

3 Custodian Sugar Grove Elementary Nurse Custodian Middle School Central Nurse Custodian Middle School North Nurse Custodian High School Nurse Custodian The Health Services Coordinator will be responsible for ensuring that all medical actions required are performed and that appropriate employee health and OSHA records are maintained. The Health Services Coordinator will be responsible for training, documentation of training, and making the written ECP available to employees, and OSHA representatives. Employee Exposure Determination Occupational Exposure is defined as: Reasonably anticipated skin, eye, mucous membrane, or parenteral contact with potentially infectious materials that may result from the performance of an employee s duties. Parenteral contact involves piercing mucous membranes or the skin barrier through such events as needle sticks, human bites, cuts and abrasions. The following is a list of job classifications in which all employees have occupational exposure: Job Title Nurse/Clinic Assistant Special Education Teacher & Assistant Custodian School Resource Officer Athletic Trainer Department/Location All School Buildings All School Buildings All School Buildings CG Police Department HS The following is a list of job classifications in which some employees have occupational exposure. Included is a list of tasks and procedures, or groups of closely related tasks and procedures, in which occupational exposure may occur for these individuals: Job Title Department/Location Task/Procedure Principal All School Buildings Care of injured student Assistant Principal All School Buildings Care of injured student Dean All School Buildings Care of injured student Secretary/Office Assistant All School Buildings If assigned clinic coverage Head Coach (Contact Sports) Middle School & High School Care of injured student Special Education Bus Driver Transportation Care of injured/ill student Special Education Bus Monitor Transportation Care of injured/ill student Industrial Technology Teachers Middle School & High School Care of injured student Methods of Implementation and Control Universal Precautions Universal Precautions refers to the practice of handling blood and other potentially infectious materials as if they are 3

4 infectious. All employees will utilize universal precautions. Engineering Controls and Work Practices Engineering controls and work practice controls are designed to eliminate or minimize employee exposure. This facility identifies the need for changes in engineering control and work practices through employee interviews and/or recommendations and the review of accident/incident reports as well as tracking exposure incident reports. We evaluate the need for new procedures or new products by discussing recommendations with principals, Department Directors, Health Services Coordinator, Director of Human Resources and/or Student Services and the Superintendent or his designee. Any staff member may be involved in this process if desired, or, as recommended, and may suggest change, offer improvement and assist in the implementation of new work practices and/or engineering controls. The Human Resources Department with the help of the Health Services Department will ensure effective implementation of these recommendations. Hand washing o This district provides hand washing facilities which are readily accessible to employees. When a provision for hand washing facilities is not feasible, this district shall provide either an appropriate antiseptic hand cleanser and paper towels or antiseptic towelettes. o Employees shall wash hands or any other skin with soap and water or flush mucous membranes with water immediately, or as soon as possible, following contact of such body areas with blood or other potentially infectious materials (OPIM). o Employees shall wash their hands immediately, or as soon as possible, after removal of gloves or other personal protective equipment. When antiseptic hand cleaners or towelettes are used, hands shall be washed with soap and running water as soon as possible. Do not reuse disposable gloves. Housekeeping and Waste Procedures o Items such as paper towels, gauze squares, or clothing used in the treatment of blood or OPIM spills that are blood-soaked or caked with blood shall be bagged, tied, and designated as a biohazard. Bags designated as biohazard (containing blood or OPIM contaminated materials) shall be red in color and/or affixed with a biohazard label. Building custodians will provide the red bags as needed. o Used red biohazard bags should be stored in a locked custodian closet until they can be taken to the CG Wellness Clinic for proper disposal. o Custodian shall respond immediately to any major blood or OPIM incident so that it can be cleaned, decontaminated, and/or removed. o Contaminated sharps, broken glass, plastic, or other sharp objects shall be discarded into appropriate sharps containers. Sharps containers provided are closable, puncture-resistant, leak-proof on sides and bottoms, and labeled or color-coded appropriately. Sharps disposal containers are available in each building clinic. o Sharps containers maintained in school clinics are inspected at least weekly and maintained or, replaced by the nurse or clinic assistant every year or, whenever necessary to prevent overfilling. o When a sharps container is ¾ full, the container top shall be closed in the locked position and the container will be delivered by a health services employee to the CG Wellness Clinic for proper disposal. o Bins and pails, cans, similar containers, and surfaces are cleaned and decontaminated as soon as possible after visible contamination. o Broken glassware which may be contaminated is picked up using mechanical means, such as a brush and dust pan or with tweezers or forceps and discarded into appropriate sharps container. o Contaminated clothing articles are not laundered by this School Corporation. Personal Protective Equipment (PPE) o Where occupational exposure remains after institution of engineering and work practice controls, 4

5 o o o o o o o personal protective equipment shall be used. PPE is provided to our employees at no cost. Training in the use of the appropriate PPE for specific tasks or procedures is provided by Department Directors, Nurse or Clinic Assistant, or Health Services Coordinator. PPE is intended to function as a protection against contamination with blood or other potentially infectious material. The types of PPE available to employees are as follows: non-latex gloves, eye protection, masks, band aids, antiseptic wipes and CPR face shields. Most PPE are located in custodian s closet, clinic, school bus, and distributed to each teacher for their classroom. Additional PPE can be obtained through the clinic by requesting it. Eye protection and mouth barriers are not distributed to all employees, but can be provided if necessary. Remove PPE after it becomes contaminated and before leaving the work area. Wear appropriate gloves when it can be reasonably anticipated that there may be hand contact with blood or other potentially infectious material (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. 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. 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. Used PPE may be disposed of in regular trash if not soaked with blood or OPIM. Utility gloves may be decontaminated for reuse if their integrity is not compromised; discard utility gloves if they show signs of cracking, peeling, tearing, puncturing, or deterioration. Equipment to be Labeled and Label Type The following labeling methods are used: Red plastic bags; universal biohazard symbol (label shall be fluorescent orange or red-orange) The Maintenance Director will ensure that custodians are provided with and using affixed warning labels and those red bags are used as required if regulated waste or contaminated equipment is brought into the facility. Sharps disposal containers are ordered and maintained by the nurse or clinic assistant in each building. Employees are to notify the Maintenance Director, building principal, or building custodian if they discover regulated waste containers, refrigerators containing blood or OPIM, contaminated equipment, etc. without proper labels. Hepatitis B Vaccination The Health Services Coordinator will make the hepatitis B vaccination series available to all employees who have occupational exposure after the employee(s) have been given information on the hepatitis B vaccine, including information on its efficacy, safety, and method of administration as well as the benefits of being vaccinated. The Hepatitis B vaccination series is available at no cost to the employee after training and within 10 days of initial assignment to employees identified in the exposure determination section of this plan. Vaccination is encouraged unless: 1) documentation exists that the employee has previously received the series, 2) 5

6 antibody testing reveals that the employee is immune, or 3) medical evaluation shows that vaccination is contraindicated. However, if an employee chooses to decline the vaccination, the employee must sign a declination form (Appendix A). Employees who decline may request and obtain the vaccination at a later date at no cost. Documentation of refusal of the vaccination is kept in the Health Services Coordinator s office. Vaccination will be provided by the Occupational Health Facility. Post-Exposure Evaluation and Follow-Up What is an Exposure Incident? An exposure incident means a specific eye, mouth, other mucous membrane, non-intact skin, or parenteral contact with blood or OPIM that result from the performance of an employee s duties. A physician ultimately must determine and clarify in writing that a significant exposure has occurred. Splashes or sprays to intact skin are not considered exposure incidents for OSHA purposes. All exposure incidents shall be reported, investigated, and documented by the end of the workday on which the incident occurred. Should an exposure incident occur, contact your building nurse or clinic assistant, Health Services Coordinator, or Human Resources Director. Following the initial first aid (clean the wound, flush eyes, or other mucous membrane, etc.), the following activities will be performed: Completion of Exposure Incident Report Form (Appendix C) In the event of a needle-stick or sharps injury, the Sharps Injury Log (Appendix B) is completed by the Health Services Coordinator. Exposure Incident Follow Up Following a report of an exposure incident, this district shall make immediately available to the exposed employee a confidential medical examination from a health-care provider knowledgeable about the current management of postexposure prophylaxis in the first 24 hours following exposure. Minimal follow-up shall include the following: Document the routes of exposure and how the exposure occurred. Identify and document the source individual (unless the school corporation can establish that identification is unfeasible or prohibited by state or local law). Obtain consent and make arrangements to have the source individual tested as soon as possible to determine HIV, HCV, and HBV infectivity; document that the source individual s test results were conveyed to the employee s health care provider. If the source individual is already known to be HIV, HCV and/or HBV positive, new testing need not be performed. Assure that the exposed employee is provided with the source individual s test results and with information about applicable disclosure laws and regulations concerning the identity and infectious status of the source individual (e.g., laws protecting confidentiality). After obtaining consent, collect exposed employee s blood as soon as feasible after exposure incident, and test blood for HBV and HIV serological status. If the employee does not give consent for HIV serological testing during collection of blood for baseline testing, preservation of the baseline blood sample for at least 90 days is the responsibility of the Occupational Health Facility; if the exposed employee elects to have the baseline sample tested during this waiting period, testing is understood to occur as soon as feasible. 6

7 Medical Follow-up The Health Services Coordinator ensures that health care professional(s) responsible for employee s hepatitis B vaccination and post-exposure evaluation and follow-up are given a copy of OSHA s bloodborne pathogens standard. The health care professional evaluating an employee after an exposure incident will receive the following: a description of the employee s job duties relevant to the exposure incident route(s) of exposure circumstances of exposure if possible, results of the source individual s blood test relevant employee medical records, including vaccination status The Occupational Health Facility provides the employee with a copy of the evaluating health care professional s written opinion within 15 days after completion of the evaluation. The healthcare professional s written opinion for post exposure follow-up shall be limited to the following information: the affected employee has been informed of the results of the evaluation; and the affected employee has been told about any medical conditions resulting from exposure to blood or other potentially infectious materials which require further evaluation or treatment. All other findings or diagnosis shall remain confidential and shall not be included in the written report. Procedures for Evaluating the Circumstances Surrounding an Exposure Incident The building principal, Department Director and the Health Services Coordinator will review the circumstances of all exposure incidents to determine: Engineering controls in use at the time Work practices followed A description of the device being used (including type and brand) Protective equipment or clothing that was used at the time of exposure incident (gloves, eye shields, etc.) Location of the incident (classroom, school bus, playground, etc.) Activity or procedure being performed when the incident occurred Employee s training If revisions to this ECP are necessary, the building principal, Department Director(s) and/or the Health Services Coordinator will ensure that appropriate changes are made. (Changes may include an evaluation of safer devices, adding employees to the exposure determination list, etc.). Employee Training All employees receive bloodborne pathogens training upon hire and annually thereafter as conducted by the Health Services Coordinator. The training program covers, at a minimum, the following elements: A copy and explanation of the OSHA bloodborne pathogen standard The epidemiology and symptoms of bloodborne diseases An explanation of the modes of transmission of bloodborne pathogens An explanation of our ECP and how to obtain a copy An explanation of methods to recognize tasks and other activities that may involve exposure to blood and OPIM, including what constitutes an exposure incident 7

8 An explanation of the use and limitations of engineering controls, work practices, and PPE An explanation of the types, uses, location, removal, handling, decontamination, and disposal of PPE An explanation of the basis for PPE selection Information on the hepatitis B vaccine, including information on its efficacy, safety, method of administration, the benefits of being vaccinated, and that the vaccine will be offered free of charge Information on the appropriate actions to take and persons to contact in an emergency involving blood or OPIM 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 Information on the post-exposure evaluation and follow-up that the employer is required to provide for the employee following an exposure incident An explanation of the signs and labels and/or color coding required by the standard that are used An opportunity for interactive questions and answers with the person conducting the training session Training materials for the corporation are available in Skyward Employee Access, from the Health Services Coordinator, in the clinics of all school buildings and in the offices of the Superintendent, Maintenance, and Transportation. Recordkeeping Training Records Training records are completed for each employee upon completion of training. These documents will be kept for at least three years in the office of the Health Services Coordinator. The training records include: Dates of the training sessions Contents or a summary of the training sessions Names and qualifications of persons conducting the training 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 Health Services Coordinator. Medical Records Medical records are maintained for each employee with occupational exposure in accordance with 29 CFR , Access to Employee Exposure and Medical Records. The Human Resources Director is responsible for maintenance of the required medical records. These confidential records are not disclosed or reported without the employee s expressed written consent to any person within or outside the district, except as required by law. The records will be kept for at least the duration of employment plus 30 years in a separate file from personnel records. The records shall include the following: The name and social security number of the employee A copy of the employee s HBV vaccination status, including dates of vaccination, declination form, and any additional medical records relative to hepatitis B If an exposure incident (s) has occurred, a copy of all results of examinations, medical testing, and follow-up procedures If an exposure incident (s) has occurred, the district s copy of the healthcare professional s written opinion If an exposure incident(s) has occurred, the district s copy of information provided to the healthcare professional, exposure incident report form, the results of the source individual s blood testing, if available, 8

9 and the consent obtained for release. 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 Director of Human Resources at 4800 West Stones Crossing Road, Greenwood, IN OSHA Recordkeeping An exposure incident is evaluated to determine if the case meets OSHA s Recordkeeping Requirements (29 CFR 1904). OSHA reportable exposure incidents, including splashes to mucous membranes, eyes, or non-intact skin, shall be entered as injuries on the OSHA Form 300. This determination is done by the Health Services Coordinator and forwarded to the CG Benefits Specialist to be included on the annual report. Sharps Injury Log (Appendix B) In addition to the 1904 Recordkeeping Requirements, all percutaneous injuries from contaminated sharps are also recorded in a Sharps Injury Log. All incidences must include at least: Date of the injury Type and brand of the device involved (syringe, lancet) Department or work area where the incident occurred Explanation of how the incident occurred This log is reviewed as part of the annual program evaluation and maintained for at least five years following the end of the calendar year covered. If a copy is requested by anyone, it must have any personal identifiers removed from the report. 9

10 Hepatitis B Vaccine Declination (Mandatory) Employee s Name: Social Security Number: Position/Title: I received Hepatitis B education and training on and (approximate date) I understand that due to my occupational exposure to blood or other potentially infectious materials I may be at risk of acquiring the 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 this vaccine at this time and understand that by doing so 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 the hepatitis B vaccine, I can receive the vaccination series at no charge to me. I understand I will need post-exposure treatment if I have direct contact with blood or other body fluids at work whether or not I receive the Hepatitis B vaccine. I have read and I understand the above information and do not wish to receive the hepatitis B vaccine series (three doses) at this time. Signature: Date: Health Services Coordinator Signature: Date: Appendix A 10

11 Center Grove Community Schools Sharps Injury Log Date of Injury Type of Device (e.g. syringe, lancet) Brand Name of Device Work Area (where injury occurred) Brief description of how the incident occurred (i.e. procedure being done, action being performed: disposal, injection, etc.) Appendix B 11

12 Center Grove Community Schools Exposure Incident Report Form Employee s Name: Date of Report: Address: City, State: Zip: Telephone Number: Job Title: EXPOSURE INCIDENT INFORMATION Date of Exposure: Time of Exposure: a.m./p.m. Location where exposure incident occurred: Name of supervisor exposure incident reported to: Address: City, State, Zip: Describe in detail the exposure incident: Name of witnesses to the exposure incident: What post-exposure first-aid was administered? By Whom? Was the employee working within the capacity of his/her job description? Please explain in further detail. Yes No Were Universal Precautions being used? Please explain in further detail? Yes No What personal protective equipment was being used? Has the employee received occupational exposure and Hepatitis B training? Yes Date No 12

13 EVALUATION AND FOLLOW-UP OF THE EXPOSURE INCIDENT A follow-up evaluation is to be made within 10 days of the exposure incident to determine if the above recommendations or actions were taken to prevent another similar incident. Recommendations or actions to be taken to prevent another such similar incident: Follow-Up Date: / / Person Making Follow-up: Findings of the evaluation: Additional Comments: Report prepared by: Date: Principal or Designee s Signature: Superintendent or Designee s Signature: Appendix C 13

14 Center Grove Community Schools Employee Medical Record Checklist Employee Name Please Print Social Security Number Building Job Classification Copy of employee's hepatitis B vaccination record or declination form (Appendix A). Attach any additional medical records relative to hepatitis B If an exposure incident(s) has occurred: Brief description of exposure incident: Log and attach this district s copy of information provided to the healthcare professional. Exposure Incident Report Form (Appendix C). Results of the source individual s blood testing, if available and if consent for release has been obtained. Log and attach this district s copy of the healthcare professional's written opinion. Appendix D 14