HomeMy WebLinkAboutExposure Control Plan - Bloodborne Pathogens FINAL 01-2017
p City of Atascadero
Exposure Control Plan for Bloodborne Pathogens
Revised January 15, 2017
Exposure Control Plan for Bloodborne Pathogens
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Table of Contents
Policy and Elements .......................................................................................................................2
Exposure Determinations ..............................................................................................................3
Schedules and Methods of Implementation .................................................................................4
a. Method of Communication ............................................................................................4
b. Hepatitis B Vaccination ......................................................................................................... 5
c. Communication of Hazards to Employees .......................................................................... 6
d. Record Keeping ...................................................................................................................... 6
Hazard Communication Plan .......................................................................................................7
1. City Policy ............................................................................................................................... 7
2. Container Labeling ................................................................................................................. 7
3. SDSs ......................................................................................................................................... 7
4. Employee Training and Information .................................................................................... 8
5. Hazardous Non-routine Tasks ............................................................................................... 8
6. List of Hazardous Chemicals ................................................................................................ 9
7. Program Availability .............................................................................................................. 9
Provisions for the Initial Reporting of Exposure Incidents .....................................................10
Hepatitis B Vaccination Series Declination ...............................................................................11
Post Exposure Evaluation ...........................................................................................................12
Actively Involving Employees in the Review and Update of the Exposure Control Plan .....13
Accident Incident Report Form ..................................................................................................14
Hepatitis B Vaccination Series Declination ...............................................................................16
Attachments A and B
Exposure Control Plan for Bloodborne Pathogens
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Policy and Elements of the Plan
The City of Atascadero is committed to providing a safe and healthy work environment for all
staff. The organization’s policy is to establish, implement, and maintain an effective exposure
control plan as required by the bloodborne pathogens regulation in California Code of
Regulations, Title 8 (8 CCR), Section 5193. This written plan is designed to prevent or minimize
employees’ occupational exposure to blood and other potentially infectious materials (OPIM).
The plan is consistent with the requirements of the Cal/OSHA Injury and Illness Prevention
Program (8 CCR 3203). The City’s exposure control plan is made available upon request, for
examination and copying, to the employees, the Chief of Cal/OSHA, and NIOSH (or their
respective designees) in accord with 8 CCR 3204, “Access to Employee Exposure and Medical
Records.” The City’s written exposure control plan contains at least the following elements:
Exposure determinations
Schedule and method of implementation for each of the applicable subsections of the
bloodborne pathogens regulation (8 CCR5193), which include:
o Methods of compliance
o Hepatitis B vaccination and post exposure evaluation and follow-up
o Communication of hazards to employees
o Recordkeeping
Provisions for the initial reporting of exposure incidents
Hepatitis B vaccination series for unvaccinated employees
Effective procedures for:
o Evaluating the circumstances surrounding exposure incidents
o Work practice controls–exception to prohibited practices
o Gathering sharps injury log information
o Making periodic determinations of the frequency of use and the types and the brands of
sharps involved in exposure incidents
o Identifying and selecting appropriate and currently available engineering control devices
o Actively involving employees in the review and update of the exposure control plan for the
procedures they perform
The information-gathering and documentation procedures serve as a basis for making decisions about the
use of needleless systems and sharps with engineered sharps injury protection.
Exposure Control Plan for Bloodborne Pathogens
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Exposure Determinations
Employees in specifically identified job classifications in the organization have occupational
exposure to bloodborne pathogens. Occupational exposure means reasonably anticipated skin,
eye, mucous membrane, or parenteral contact with blood or other potentially infectious material
(OPIM) that may result from the performance of an employee’s duties. Parenteral contact
means piercing mucous membranes or the skin barrier through such events as needle-sticks,
human bites, cuts, and abrasions. OPIM includes various contaminated human body fluids,
unfixed human tissues or organs (other than skin), and other materials known or reasonably
likely to be infected with human immunodeficiency virus (HIV), hepatitis B virus (HBV), or
hepatitis C virus (HCV) through cells, tissues, blood, organs, culture mediums, or solutions.
The City’s policy is to conduct exposure determinations throughout the facility without regard to
the use of personal protective equipment (PPE). There are lead person(s), or other individuals
who conduct, evaluate, and periodically review exposure determinations. This process involves
identifying all job classifications, tasks, or procedures in which the City’s employees may have
occupational exposure to blood or OPIM. The City’s approach is to consider all the job
classifications at once.
NOTE: The City of Atascadero Fire and Police Departments each have their own Exposure
Control Plans for Bloodborne Pathogens which are independent of this document.
Job classification determinations are based upon OSHA examples.
Job Classifications in Which All Employees Have Occupational Exposure
All individuals in each job classification listed below have occupational exposure.
Job Classification: 1. Lifeguards
Task/Procedure in These Jobs That Have Occupational Exposure:
Lifeguards have occupational exposure when performing first aid.
Job Classifications in Which Some Employees Have Occupational Exposure
All individuals in each job classification listed below have some occupational exposure.
Job Classification: 1.Wastewater Treatment Plant Staff 2.Maintenance Staff 3.Zoo Staff
4. Colony Park Community Center Staff
Task/Procedure in These Jobs That Have Occupational Exposure:
Wastewater Operators have some exposure while performing pump maintenance, collecting lab samples,
and operating wastewater systems. Maintenance staff and Colony Park Community Center staff are
exposed while performing janitorial work and waste disposal duties. Zoo staff is exposed while
performing animal care duties. All of the above mentioned job classifications have some occupational
exposure when working on equipment contaminated with blood, OPIM, or contaminated used sharps.
Exposure Control Plan for Bloodborne Pathogens
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Schedules and Methods
Of Implementation
The City has developed a schedule and methods of implementation for the applicable subsections (d)
through (h) of 8 CCR 5193. The City has determined which subsections are applicable and has
documented pertinent information as follows:
(a) METHODS OF COMMUNICATION
Universal Precautions
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, per regulation 1910.1030(b).
All employees will utilize the following universal precautions:
Exposure Control Plan (ECP)
Employees covered by the bloodborne pathogens standard receive an explanation of this Exposure
Control Plan (ECP) during their initial training session. It will also be reviewed in their refresher training.
All employees can review this plan at any time during their work shifts by contacting their immediate
supervisor. If requested, the City will provide an employee with a copy of the Exposure Control Plan.
The Exposure Control Plan will be reviewed and updated on an as needed basis, to reflect any new or
modified tasks and procedures that affect occupational exposure and to reflect new or revised employee
positions with occupational exposure.
Engineering Controls and Work Practices
Engineering controls and work practice controls will be used to prevent or minimize exposure to
bloodborne pathogens. The City identifies the need for changes in engineering controls and work
practices through review of OSHA records, employee interviews, committee activities, etc.
Both front-line workers and management officials are involved in this process. The Risk Manager, or
designee is responsible for ensuring that these recommendations are implemented.
Personal Protective Equipment (PPE)
PPE is provided to City employees at no cost to them. Training in the use of the appropriate PPE for
specific tasks or procedures is provided by the employee’s immediate supervisor.
The types of PPE available to employees are as follows, but not limited to:
Eye protection
Face shield
Gloves
Rubber boots
Exposure Control Plan for Bloodborne Pathogens
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Rain gear
Uniform/Coveralls
PPE may be obtained through the employee’s immediate supervisor. All employees using PPE shall
observe the following precautions:
Wash hands immediately or as soon as feasible after removing gloves or other PPE.
Remove PPE after it becomes contaminated and before leaving the work area.
Used PPE shall be disposed of in appropriate containers for storage, laundering, decontamination,
or disposal.
Wear appropriate gloves when it is reasonably anticipated that there may be hand contact with
blood or OPIM, and when handling or touching contaminated items or surfaces; replace gloves if
torn, punctured or contaminated, or if their ability to function as a barrier is compromised.
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.
Never wash or decontaminate disposable gloves for reuse.
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.
Housekeeping
Regulated waste is placed in containers which are closable, constructed to contain all contents and prevent
leakage, appropriately labeled or color-coded and closed prior to removal to prevent spillage or protrusion
of contents during handling.
(b) HEPATITIS B VACCINATION
The City will provide training to those employees that have been identified in the job classifications as
being at risk for occupational exposure on hepatitis B vaccinations; addressing safety, benefits, efficacy,
methods of administration, and availability.
The hepatitis B vaccination series is available at no cost after initial employee training and within 10 days
of initial assignment to all employees identified in the job classifications of the Exposure Determination
section of this plan (page 3). Vaccination is encouraged unless: 1) documentation exists that the employee
has previously received the series; 2) antibody testing reveals that the employee is immune; or 3) medical
evaluation shows that vaccination is contraindicated.
However, if an employee declines the vaccination, the employee must sign a declination form. 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 employee’s personnel file.
Vaccination will be provided by a medical facility designated by the City, and documentation of
completion of the vaccination series will be provided to the City.
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(c) COMMUNICATION OF HAZARDS TO EMPLOYEES
Please refer to the City of Atascadero’s Hazard Communication Plan (pgs. 7-9 of this
document) for information concerning communication of hazards to employees.
(d) RECORD KEEPING
Record keeping of incidents should comply with OSHA’s Recordkeeping Requirements (29 CFR 1904).
Training Records
Records are maintained for each employee upon completion of training. These documents will be kept for
at least three years within the departments training records file. The training records include:
the dates of the training sessions
the contents or a summary of the training sessions
the names and qualifications of persons conducting the training
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 employee’s immediate
supervisor.
Medical Records
Medical records are maintained for each employee with occupational exposure in accordance with 29
CFR 1910.1020, “Access to Employee Exposure and Medical Records.”
The City Manager’s Office is responsible for maintenance of the required medical records. These
confidential records are kept in the employee’s personnel file for at least the duration of employment plus
30 years.
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 City Manager’s
Office.
Accident/Incident Report
In addition to the 29 CFR 1904 Recordkeeping Requirements, all percutaneous injuries from
contaminated sharps are also recorded in an Accident/Incident Report (Attachment A). All
incidences must include the following:
Date of injury
Department or work area where the incident occurred
Explanation of how the incident occurred
The employee may complete a Worker’s Comp packet and seek medical evaluation from the
City-designated Worker’s Comp approved facility/provider.
Exposure Control Plan for Bloodborne Pathogens
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Hazard Communication Plan
The following Hazard Communication Program is based on the requirements of the OSHA Hazard
Communications Standard, 29 CFR 1910.1200.
Hazard Communication Program
1. City Policy
To ensure that information about the dangers of all hazardous chemicals used by the City is
known by all affected employees, the following hazardous information program has been
established. Under this program, you will be informed of the contents of the OSHA Hazard
Communications standard, the hazardous properties of chemicals with which you work, safe
handling procedures and measures to take to protect yourself from these chemicals.
This program applies to all work operations in the organization in which employees may be
exposed to hazardous chemicals under normal working conditions or during an emergency
situation. All work units of the City will participate in the Hazard Communication Program.
Copies of the Hazard Communication Program are available on the City’s electronic network
and hard copies are made available in each department.
The Risk Manager, or designee has overall responsibility for the program, including reviewing
and updating this plan as necessary.
2. Container Labeling
Employees will verify that all containers received for use will be clearly labeled as to the
contents, note the appropriate hazard warning, and list the manufacturer’s name and address. The
immediate supervisor in each department will ensure that all secondary containers are labeled
with either an extra copy of the original manufacturer’s label or with labels marked with the
identity and the appropriate hazard warning. For help with labeling, staff should consult
his/her/your immediate supervisor.
3. Safety Data Sheets (SDSs)
The Risk Manager or designee is responsible for establishing and monitoring the City’s SDS
program. He/she will ensure that procedures are developed to obtain the necessary SDSs and will
review incoming SDSs for new or significant health and safety information. He/she will see that
any new information is communicated to affected employees.
Copies of SDSs for all hazardous chemicals to which employees are exposed or are potentially
exposed are made available to all employees and are stored in a location determined by each
department.
Exposure Control Plan for Bloodborne Pathogens
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SDSs will be readily available to all employees during each work shift. If an SDS is not
available, employees should contact his/her/your immediate supervisor.
4. Employee Training and Information
The Risk Manager or their designee is responsible for the Hazard Communication Program and
will ensure that all program elements are carried out.
Employees in positions at risk for exposure to hazardous chemicals will receive initial training
on the hazard communication plan. Each new employee assigned to such a position will attend
an orientation that includes the following information and training:
An overview of the OSHA hazard communication standard
The hazardous chemicals present at his/her work area
The physical and health risks of the hazardous chemicals
Symptoms of overexposure
How to determine the presence or release of hazardous chemicals in the work area
How to reduce or prevent exposure to hazardous chemicals through use of control
procedures, work practices and personal protective equipment
Steps the City has taken to reduce or prevent exposure to hazardous chemicals
Procedures to follow if employees are overexposed to hazardous chemicals
How to read labels and SDSs to obtain hazard information
Location of the SDS file and written Hazard Communication program
Prior to introducing a new chemical hazard into any section of the City, each employee in that
department will be given information and training as outlined above for the new chemical
hazard.
5. Hazardous Non-Routine Tasks
Periodically, employees are required to perform non-routine tasks that are hazardous, such as
confined space entry.
Prior to starting work on non-routine tasks, each affected employee will be given information by
the employee’s immediate supervisor about the hazardous chemicals he or she may encounter
during such activity. This information will include specific chemical hazards, protective and
safety measures the employee should use, and steps the City is taking to reduce the hazards,
including ventilation, respirators, the presence of another employee (buddy systems), and
emergency procedures.
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6. List of Hazardous Chemicals
A list of all known hazardous chemicals used by City employees may be obtained from the
MSDSs, located within each department.
When new chemicals are received, this list is updated (including date the chemicals were
introduced) within 30 days.
The hazardous chemical inventory is compiled and maintained by the Risk Manager, or
designee.
7. Program Availability
A hard copy of this program is to be made available on the City’s electronic network and in
every department for employee access.
Exposure Control Plan for Bloodborne Pathogens
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Provisions for the Initial Reporting of
Exposure Accident/Incidents
The City documents and reports all exposure incidents as soon as possible regardless of
whether first aid was rendered. An exposure incident means 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. Parenteral means piercing mucous membranes or the skin
barrier through such events as needle sticks, human bites, cuts, and abrasions. All employees
(excluding designated first aid providers who provide first aid regularly and those who render
first aid only as a collateral duty) receive training about the City’s policy.
The Risk Manager, or designee is designated by the City to receive Accident/Incident Reports.
The exposure Accident/Incident Report includes at least the following:
The name of the employee involved in the exposure incident.
A description of the exposure or first-aid incident, including:
The time and date.
A determination of whether an exposure incident occurred. This determination is
necessary to ensure that the proper post-exposure evaluation is conducted and
prophylaxis and follow-up are made available immediately if an exposure incident has
occurred.
Exposure Control Plan for Bloodborne Pathogens
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Hepatitis B Vaccination Series Declination
The City strongly encourages hepatitis B vaccination and makes the vaccination series
available to all employees who have occupational exposure to blood or OPIM. However, if an
employee does not wish to participate in the hepatitis B vaccination, he/she must sign the
HEPATITIS B VACCINE DECLINATION form (Attachment B). This document will be
filed within the employee’s personnel file.
Exposure Control Plan for Bloodborne Pathogens
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Post-Exposure Evaluation
And Follow-up
The City has made prearrangements for appropriate post-exposure evaluation and follow-up for
all employees involved in an exposure incident. An exposure incident means specific eye,
mouth, other mucous membrane, non-intact skin, or parenteral contact with blood or other
potentially infectious material (OPIM) that result from the performance of an employee’s duties.
After an exposure incident is reported, the City will make immediately available to the exposed
employee a confidential medical evaluation and follow-up. Follow-up may include post-
exposure prophylaxis (when medically indicated), counseling, and evaluation of a reported
illness, if appropriate. For each exposure incident, the City documents the route(s) of exposure
and the circumstances under which the exposure incident occurred.
Exposure Control Plan for Bloodborne Pathogens
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Actively Involving Employees in the Review
and Update of the Exposure Control Plan
The City’s exposure control plan is reviewed and updated as needed (and whenever necessary)
to include:
New or modified tasks or procedures that affect occupational exposure
Progress in implementing the use of needleless systems and sharps with engineered
sharps injury protection
New or revised job position(s) that involve occupational exposure
Reviews and evaluations of exposure incidents that have occurred since the previous
update
Reviews and responses to information indicating that the existing exposure control plan is
deficient in any area
All employees are encouraged to provide suggestions on improving the procedures they perform
in their departments or divisions. Employees contribute to the review and update of the exposure
control plan by:
Participating as members of committees (e.g., safety and health, labor-management,
infection control, product evaluation and selection, purchasing of equipment)
Attending meetings to discuss safety and health issues and improvements
Reporting issues or potential problems to supervisors
Providing ideas, recommendations, or suggestions
Filling out reports, questionnaires, or other documents
Exposure Control Plan for Bloodborne Pathogens
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Accident Incident Report Form
Form A
Exposure Control Plan for Bloodborne Pathogens
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Exposure Control Plan for Bloodborne Pathogens
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Hepatitis B Vaccination Series Declination
Form B