4119.42, 4219.42, 4319.42 - Exposure Control Bloodborne Pathogens

PURPOSE OF THE PLAN

A major goal of the Federal Occupational Safety and Health Administration (OSHA) and its California State Equivalent, CAL-OSHA, is to promote safe work practices in order to minimize illness and injury experienced by employees. As another step toward achieving this goal, OSHA has enacted a Federal Bloodborne Pathogens Standard. It is identified in the Code of Federal Regulations (CFR) as 29 CFR 1910.1030, and the CAL-OSHA state standard is covered under Title 8, Section 5193. The purpose of these regulatory standards is to reduce occupational exposure to Hepatitis B Virus (HBV), Human Immunodeficiency virus (HIV) and other bloodborne pathogens that employees may encounter in the work place.

The San Bernardino County Superintendent Of Schools believes that a number of general principles should be followed when working with the possibility of contacting bloodborne pathogens:

• Minimize all employee exposure.
• Never underestimate the risk associated with exposure.
• Our facilities should institute every practical work practice and engineering control to eliminate employee exposure to bloodborne pathogens.

The San Bernardino County Superintendent of Schools has implemented this Exposure Control Plan to meet the CAL-OSHA Bloodborne Pathogens Standard. The plan is designed to:

• Protect employees from the health hazards that accompany exposure to bloodborne pathogens
• Provide appropriate treatment and counseling should employee exposure occur

EXPOSURE DETERMINATION

CAL-OSHA 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 personal protective equipment). This exposure determination is required to list all job classifications in which employees may be expected to incur such occupational exposure, regardless of frequency.

The following San Bernardino County Superintendent of Schools job classifications or staff categories that interact with students include:

• Teachers of alternative education and special needs students
• Educational Assistants
• School Nurses
• ROP Teachers
• Foster Youth Services Managers

In addition, CAL-OSHA requires a listing of job classifications in which some employees may have occupational exposure. Since not all the employees in these categories 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 also required to be listed in order to clearly understand which employees in these categories are considered to have occupational exposure. The job classifications and associated tasks for these categories are as follows:

Job Classification
Classroom Teacher and Classroom Attendant as identified above.

Tasks/Procedures
Both provide classroom instruction, supervision, and immediate first aid/CPR in the event of an emergency.

CAL-OSHA also requires that this plan include a schedule and method of implementation for the various requirements of the standard. The following complies with this requirement:

Compliance Methods

Universal precautions will be observed at all of our facility locations in order to prevent contact with blood or other potentially infectious materials. All blood or other potentially infectious material will be considered infectious regardless of the perceived status of the source individual.

Engineering and work practice controls will be utilized to eliminate or minimize exposure to employees at all of our facilities. Where occupational exposure remains after institution of these controls, personal protective equipment shall also be utilized. In the San Bernardino County Superintendent of Schools the following engineering controls will be utilized:

• Sharps containers/instructions for use provided at applicable sites
• Hand washing facilities, including soap, readily available
• Signs denoting/encouraging use of hand washing facilities
• Bag-lined wastebaskets in high-risk areas

The above controls will be examined and maintained on a regular schedule. The schedule for reviewing the effectiveness of the controls is as follows:

• Each site administrator or designee shall monitor and ensure that the above controls are enforced.
• The site administrator or designee shall inspect equipment and procedures based on the above controls not less than once per month.

Hand washing facilities are also available to the employees who incur exposure to blood or other potentially infectious materials. CAL-OSHA requires that these facilities be readily accessible after incurring exposure. At our sites where hand-washing facilities are not readily available, antiseptic cleanser and paper towels will be provided.

After removal of personal protective gloves, employees shall wash hands and any other potentially contaminated skin area immediately, or as soon as feasible, with soap and water.

If employees incur exposure to their skin or mucous membranes, then those areas shall be washed or flushed with water as soon as feasible following contact.

Needles

Contaminated needles and other contaminated sharps will not be bent, recapped, removed, sheared or purposely broken. CAL-OSHA allows an exception to this if the procedure would require that the contaminated needle be recapped or removed and no alternative is feasible and the action is required by the medical procedure. If such action is required then the recapping or removal of the needle must be done by the use of a mechanical device or a one-handed technique.

Containers for Reusable Sharps

Contaminated sharps that are reusable are to be placed immediately, or as soon as possible after use, into appropriate sharps containers. Within the San Bernardino County Superintendent of Schools, the sharps containers are puncture resistant, labeled with a biohazard label, and are leak proof. Sharps containers are either provided by parents or may be ordered from medical supply companies.

Work Area Restrictions

In classroom areas where there is a reasonable likelihood of exposure to blood or other potentially infectious materials, employees are not to eat, drink, apply cosmetics or lip balm, smoke, or handle contact lenses. Food and beverages are not to be kept in refrigerators, freezers, shelves, cabinets, or on counter tops or bench tops where blood or other potentially infectious materials are present.

All cleanup procedures will be conducted in a manner that will minimize splashing, spraying, splattering, and generation of droplets of blood or other potentially infectious materials.

Personal Protective Equipment

All personal protective equipment used in the San Bernardino County Superintendent of Schools will be provided without cost to employees. 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 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 of use and for the duration of time that the protective equipment will be used.

For purposes of this Plan, Personal Care (PC), Clean-up (CU), and Specialized Healthcare Plan (SHCP) procedures require protective clothing and equipment and will be provided to employees in the following manner:

Personal Protective Equipment / Tasks
Aprons / PC
Gloves / PC, CU, SHCP
Protective eyewear / PC, CU, SHCP
Masks / SHCP

All personal protective equipment will be cleaned, laundered, and disposed of by the employer at no cost to employees. All repairs and replacements will be made by the employer at no cost to employees.

All garments that are penetrated by blood shall be removed immediately or as soon as feasible, then bagged and stored or disposed of as directed by the site administrator.

Gloves shall be worn where it is reasonably anticipated that employees will have hand contact with blood, other potentially infectious materials, non-intact skin, and mucous membranes. Classroom staff will use a new pair of gloves for each student. Gloves are provided by San Bernardino County Superintendent of Schools. They are also available in all San Bernardino County Superintendent of Schools first aid kits.

Disposable gloves used in the San Bernardino County Superintendent of Schools are not to be washed or decontaminated for reuse and are to be replaced as soon as practical when they become contaminated or as soon as feasible if they are torn, punctured, or when their ability to function as a barrier is compromised. Utility gloves may be decontaminated for reuse provided that the integrity of the glove is not compromised. Utility gloves will be discarded if they are cracked, peeling, torn, punctured, or exhibits other signs of deterioration or when their ability to function as a barrier is compromised.

Masks, in combination with eye protection devices, such as goggles or glasses with solid side shield, or chin length face shields, are required to be worn whenever splashes, spray, splatter, or droplets of blood or other potentially infectious materials may be generated and eye, nose, or mouth contamination can reasonably be anticipated.

The CAL-OSHA standard also requires appropriate protective clothing to be used, such as lab coats, gowns, aprons, clinic jackets, or similar outer garments. Masks, protective eyewear, aprons, or coveralls shall be worn where body fluids may be splashed on the employee.

All San Bernardino County Superintendent of Schools facilities will be cleaned and decontaminated according to a predetermined schedule.

Decontamination and cleaning will be accomplished by utilizing the following San Bernardino County Superintendent of Schools supplied cleaning material and procedures:

• Disinfectant/germicide cleaning solution.
• All contaminated work surfaces will be decontaminated after completion procedures and immediately or as soon as feasible after any spill of blood or other potentially infectious materials, as well as the end of the work shift where the surface may have become contaminated since the last cleaning.
• All bins, pails, cans, and similar receptacles shall be bag-lined by the site custodian.
• Broken glassware that may be contaminated will not be picked up directly with the hands. The following procedures will be used: The broken glass shall be swept up with a broom and a dustpan. Residue will then be removed with a vacuum cleaner.

Regulated Waste Disposal

All contaminated sharps shall be discarded as soon as feasible in sharps containers that are located in the facility when appropriate. The container will be collected by the parent or taken to the nearest fire station.

Laundry Procedures

Laundry contaminated with blood or other potentially infectious materials will be handled as little as possible. Such laundry will be placed in appropriately marked bags at the location where it was used. Such laundry will not be sorted or rinsed in the area of use.

All employees who handle contaminated laundry will utilize personal protective equipment to prevent contact with blood or other potentially infectious materials.

In the event of contaminated laundry, the laundry will be sent off-site. The laundry service accepting the laundry is to be notified, in accordance with the CAL-OSHA standard.

Hepatitis Vaccine

All employees who have been identified as having possible exposure to blood, human body fluids, or potentially infectious materials will be offered the Hepatitis B vaccine, at no cost. The vaccine will be offered within 10 working days of their initial assignment to work involving the potential for occupational exposure to blood, human body fluids, or other potentially infectious materials unless the employee has previously had the vaccine or wishes to submit to antibody testing which may show the employee to have sufficient immunity.

Employees who decline the Hepatitis B vaccine will sign a waiver that uses the specialized CAL-OSHA wording (see Exhibits B-1 and B-2).

The employees who initially decline the vaccine but who later wish to have it may then have the vaccine provided at no cost.

The Personnel Services Department has the responsibility for assuring that the vaccine is offered and that acceptance forms or waivers are signed. The vaccine will be administered by a San Bernardino County Superintendent of Schools selected clinic.

Post-Exposure Evaluation and Follow-Up

When an employee is involved in an exposure incident, it should be reported immediately to the immediate supervisor and the Workers’ Compensation office.

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 the following:

• Documentation of the route of exposure and the circumstances related to the incident.
• 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/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 confidentiality (disclosure of the identity and 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/HBV 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 of the U.S. Public Health Service. These recommendations are currently three injections of HBV vaccine.
• 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 Workers' Compensation office has been designated to assure that the policy outlined here is effectively carried out as well as to maintain records related to this policy.

Interaction with Health Care Professionals

A written opinion shall be obtained from the health care professional who evaluates San Bernardino County Superintendent of Schools employees. 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, or for evaluation following an incident.
  • Confirmation that the employee has been informed of the results of the evaluation, and
  • That the employee has been told about any medical conditions resulting from exposure to blood or other potentially infectious materials. (Note that the written opinion to the employer is not to reference any personal medical information).

Training

Training for all employees will be conducted prior to initial assignment to tasks where occupational exposure may occur. Initial training will be the responsibility of the Personnel Services Department.

Annual in-service training will be made mandatory for all employees expected to incur occupational exposure. It may include videotapes and instructional material. A trained health professional will be available to answer questions.

Training for employees will include an explanation of the following:

• The CAL-OSHA standard for Bloodborne Pathogens
• Epidemiology and symptomatology of bloodborne diseases
• Modes of transmission of bloodborne pathogens
• This Exposure Control Plan (i.e. points of the plan, lines of responsibility, and how the plan will be implemented)
• Procedures which might cause exposure to blood or other potentially infectious materials
• Control methods that will be used in the San Bernardino County Superintendent of Schools to control exposure to potentially infectious materials
• Personal protective equipment available and who to contact to get the equipment.
• Post exposure evaluation and follow-up
• Signs and labels used
• Hepatitis B vaccine program

Recordkeeping

All initial training records required by the CAL-OSHA standard will be maintained by the San Bernardino County Superintendent of Schools Personnel Services Department. Annual refresher training records will be kept by the administrate head of the assigned employees.

Dates of Implementation and Renewal

All provisions required by the standard were implemented in July, 1994 and revised annually.

All designated employees will receive annual refresher training.

The information and references in this plan will be updated as required and the plan will be reviewed in its entirety on an annual basis.

Approved: September 15, 1994
Revised: March 21, 2006