Osha Blood Borne Pathogen Occupational Exposure Policy

Section A. Occupational Exposure Policy

1. The purpose of this policy is to prevent the occupational exposures of the staff to the following potentially infections materials: blood, semen, vaginal secretions, cerebrospinal fluid, synovial fluid, plural fluid, amniotic fluid, pericardial fluid, peritoneal fluid, saliva in dental procedures, and human tissue.

2. Occupational exposure means contact with skin, eyes, mucus membrane, or parenteral exposure by the potentially infectious materials.

3. Information and training: all employees involved in work that would involve occupational exposure must participate in a training program which must be provided at no cost to the employee, during working hours. The training shall be provided at the initial time of assignment and at least annually thereafter. Any new standards of or techniques shall be taught at the time of their inclusion into the program. The training program shall include:

  • a general explanation of the epidemiology and symptoms of blood borne diseases and their modes of transmission;
  • an explanation of the employer’s control plan and a copy of the control plan;
  • and explanation of which activities involve exposure to potentially infectious materials and the methods which will prevent or reduce exposure to them;
  • the proper handling and disposal of potentially infectious materials and protective equipment;
  • all necessary information on the hepatitis vaccination
  • information on what action is to be taken in case an emergency occurs, or an exposure incident occurs; and
  • information on post-exposure follow-up.

4. Training session records shall include: the date of the session; a summary of the session; the names and titles of all persons attending the session. These records shall be kept for at least three years from the time of the session and shall be made available to the appropriate person(s) if requested. These records shall be available for transfer as required by the Director (the Director, Department of Labor, Occupational Safety and Health Administration). If the business ceases and there is no one to transfer the records to them the Director shall be notified and he shall receive the records; if he so desires.

5. The employer shall establish and maintain an accurate record for each employee with occupational exposure which shall include:

  • the name and social security number of the employee;
  • a copy of their hepatitis B vaccination status; a copy of all results of medical exams and testing;
  • a copy of the health care professional’s written opinion of the situation; and
  • a copy of information provided to the health care professional.

The employee’s medical record shall be kept confidential and not divulged except with the written consent of the employee. These records shall be kept for the duration of the employee’s employment plus 30 years.

6. Definitions of contamination and decontamination: If something is contaminated it has the presence of a potentially infectious material on it. Examples of potentially contaminated items include laundry and sharpes (sharpes are any objects that can penetrate the skin). To decontaminate something means by the use of physical or chemical means to inactivate or to destroy infectious materials on the item to the point where they can’t transmit disease.

7. Personal protection equipment (which shall be impermeable to all potentially infectious materials) will be worn when there is a risk of occupational exposure to potentially infectious materials. This equipment included the following: gloves, gowns protective equipment shall be available at the work site whenever there is risk of occupational exposure. When the employee leaves the work area, the equipment shall be removed and stored, cleaned, or disposed of by the employer. If a protective garment is penetrated by a potentially infectious material it shall be removed as soon as feasible. If gloves are penetrated they shall be replaced as soon as feasible. Disposable gloves shall not be reused. If an employee declines to use protective equipment this event has to be documented and a wavier has to be signed by the employee. Masks and goggles shall be used whenever there is danger of contamination of the face or eyes by potentially infections materials.

8. Handwashing facilities shall be available in every work site. If these are not readily available an appropriate antiseptic hand cleaner in conjunction with appropriate clean clothe or paper towels shall be available. Employees shall wash their hands as soon as feasible after removing protective equipment. If they come in contact with potentially infectious material they shall wash their skin with soap and water and flush mucous membranes with water. The work site shall be maintained in a clean and sanitary condition. All equipment and working surfaces shall be cleaned and decontaminated after contact with potentially infectious materials as soon as feasible. Such equipment includes bins and pails. Broken glassware which may be contaminated shall not be directly picked up with you hands. Housekeepers need to use gloves and other appropriate equipment when cleaning a work site. Use appropriate antiseptics. Bleach at 1:10 or metri spray-cetylcide or autoclave for instruments.

9. Eating, drinking, and applying cosmetics are prohibited in work areas where contamination is possible. Food and drinks shall not be kept in these hazardous areas. All procedures involving potentially infectious materials shall be done as carefully as possible to minimize splashing, spraying, spattering, and droplets of these materials. Mouth pipetting is prohibited.

10. Contaminated needles shall not be recapped but carefully placed in the appropriate container. These containers shall be OSHA approved. All potentially infectious materials shall be disposed of in the appropriate OSHA approved containers. The containers shall be closed prior to removal from the work area and prior to shipment to the appropriate facility for disposal. Disposal containers shall be available in each work area. Contaminated laundry shall be transported in the appropriate bags which can be closed and are leak proof for all potentially infectious materials. The bags shall then be transported to the appropriate facility for disposer. Protective gloves shall be worn when handling such materials if there is risk to the face.

11. Hepatitis B vaccination shall be offered to all employees who are at risk of exposure. This shall be offered to them within ten working days of employment. The schedule for vaccinations is as given by the state health department recommendations for Hepatitis B.

12. Post-exposure evaluation and follow-up: following a report of an exposure incident, the employer shall make available to the employee a confidential medical evaluation and follow-up including the following documents:

  • documentation of the route of exposure and the circumstances under which the incident occurred; and
  • identification and documentation of the source individual if feasible.

The source individual’s blood shall be tested as soon as feasible for HBV and HIV infectivity if consent is obtained (unless consent is not needed) from the individual. Results of the source individual’s testing shall be made available to the exposed employee. If consent is obtained the exposed employee’s blood shall be tested as soon as feasible. All of the above are to be documented (as well as results of medical exams and blood testing) Within fifteen days of the completion of the evaluation the employee shall be given a written opinion of the evaluation.

13. Dates: this plan is currently effective in all aspects for all office locations.

14. Hepatitis B vaccination schedule: per current health department recommendations. Post-exposure management policy is included in the training also.

15. Gowns- at least 12, masks- at least 12, goggles- at least 4 per office.

Section B. Application Of The Occupational Exposure Policy

1. A Staff Exposure Assessment List will be kept on the premises and will include:

  • A list of all staff and those who are at risk
  • Indication of those who have reviewed the occupational exposure policy and discussed it
  • Indication of those who have been offered the Hepatitis B vaccine
  • Indication of those who were given the opportunity to sign any necessary waivers concerning vaccinations and protective equipment
  • Indication of those who have had occupational exposure incidents

2. Regular inspection and replacement of any defective equipment shall be on a monthly basis and more often as needed.

3. Sharpes containers shall be replaced when full and picked up by a licensed disposal company. They shall be sealed while waiting to be picked up. Needles can be removed from syringes and deposited in sharpes containers and the syringes disposed of in the regular garbage if no blood was drawn into syringe. If blood was drawn into the syringe the syringe and the needle are to be disposed of in a sharpes container. The needle is to be removed from the syringe with a hemostat or other appropriate device. Do not bend, shear or break contaminated needle. Needles are never to be recapped. Broken glass is to be cleaned up with a dust pan and brush. Capillary tubes need to be put into sharpes containers.

4. Any containers that may be contaminated or leak must be placed in a second container: containers must be maintained in an upright position during transport..

5. The work areas that are contaminated will be cleaned as soon as feasible after a procedure and then daily by the cleaning crew. Appropriate antiseptic will be used.

6. Contaminated laundry is to be bagged in labeled containers using gloves (and gowns if necessary). It is then to be transported to the laundry facility where it is again handled with gloves. It is then washed and brought back to the office where it is autoclaved before additional surgical use.

7. The following categories associate tasks with the required protective equipment.

Job Category Nature Of Task Personal Protective Equipment
Available Worn
I Direct contact with blood or other body fluids to which universal precautions apply Yes Yes
II Activity performed without blood exposure but exposure may occur in emergency Yes No
III Task/activity does not entail predictable or unpredictable exposure to blood No No

8. Urine slide covers will be disposed of in sharpes containers, and slides will be cleaned and soaked in antiseptic and reused. Cotton swabs and tongue depressors will be disposed of in the regular garbage. Used gloves, masks, and gowns will be disposed of in the regular garbage.

9. Throat cultures and urine cultures will be disposed of in red bags marked as hazardous waste.

10. Documentation for the following will be maintained:

  • Vaccination forms
  • Training forms
  • Incident forms and follow-up
  • Inspection (monthly) forms
  • Annual training forms

Section C. Hepatitis B Vaccination Policy

1. Hepatitis B vaccination will be made available to all employees who are at risk for occupational exposure to bloodborne pathogens. The vaccine will be offered in accordance with existing employee health protocols:

  • within 10 working days of initial assignment to all employees who have occupational exposure unless the employee has previously received the complete Hepatitis B vaccine series, antibody testing has revealed that the employee is immune, or the vaccine is contraindicated for medical reasons.
    • A prescreening program is not a prerequisite for receiving the Hepatitis B vaccination.
    • If the employee initially declines Hepatitis B vaccination but at a later date decides to accept the vaccination while still employed and still at risk for occupational exposure to bloodborne pathogens, the Hepatitis B vaccination will still be available.
    • The employees who decline to accept Hepatitis B vaccination offering will sign a statement of refusal.
    • Routine booster doses of Hepatitis B vaccine which are recommended by the US Public Health Service at some later date will be made available to employees free of charge.
  • and after the employee has received the required training, including information on Hepatitis B vaccine safety, efficacy, method of administration, vaccine benefits, and its provision to the employee free of charge.

2. Hepatitis B vaccine will be administered in accordance with existing employee health protocols for administration of the vaccine..

3. Our office has administrative responsibility for overall compliance with this protocol.

4. Hepatitis B Vaccine. Please read the following carefully. Employees will have the opportunity to ask questions and have them answered to their satisfaction before making a decision about receiving the Hepatitis B vaccine.

  • Hepatitis B is an inflammation of the liver caused by the Hepatitis B virus. You may not be very ill with the virus or you may have severe symptoms that require hospitalization.
  • The symptoms of Hepatitis B include loss of appetite, fatigue abdominal discomfort or pain, an enlarged liver, jaundice (yellow skin tone) and abnormal liver function tests (blood tests).
  • People who have Hepatitis B can develop long term consequences that include chronic active Hepatitis, cirrhosis, and liver cancer.
  • Health care workers are 20 times more likely to contract the virus than the general public.
  • Everyone who has contact with blood or body fluids is a risk. Your job description signifies whether you are at risk.
  • The Hepatitis B virus can survive for seven days in dried blood. Every contact with the Hepatitis B virus is capable of causing infection.
  • You have as high as a 30% chance of contracting Hepatitis B from a single contaminated needlestick.
  • Shot-term consequences of Hepatitis B include an average of seven weeks lost from work, and the risk of permanent liver damage.
  • Long-term consequences include chronic active hepatitis and cirrhosis of the liver, as well as a 12-300 times greater risk of developing liver cancer.
  • Every week 4 to 5 health care workers die of Hepatitis B or its complications.
  • The vaccine, Engerex-B, is a noninfectious synthetic vaccine, containing no blood or blood products.
  • Three doses of the vaccine administered appropriately (IM in the deltoid_ over a six month period will provide protection to over 90% of recipients. Immunity is thought to be for life.
  • Local reactions may include soreness, redness, and swelling at the injection site.
  • Contraindications to receiving the vaccine include; sensitivity to yeast, sensitivity to thimerosal (vaccine prior to the middle of 2000), pregnancy, breastfeeding, cortisone therapy.
  • The vaccine will only protect you from Hepatitis B.
  • You may donate blood if you receive the vaccine.
  • The Hepatitis B vaccine is offered free of charge to all employee who are at risk for occupational exposure to blood and/or body fluids.

Section D. Bloodborne Pathogens Exposure & Post-exposure Policy

1. Exposure Incident will be defined as a specific eye, mouth, other mucous membrane, non-intact skin, or parenteral contact with blood or other potentially infectious materials that results from the performance of an employee’s duties.

  • Blood will be defined as human blood, human blood components, and products made from human blood.
  • Bloodborne pathogens will be defined as pathogens microorganisms that are present in human blood an can cause disease in humans. These pathogens include, but are not limited to, Hepatitis B Virus (HBV) and Human Immunodeficiency Virus (HIV).
  • Potentially infectious materials will be defined as the following human body fluids:
    • semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva in dental procedures, any body fluid that is visibly contaminated with blood, and all body fluids in situations where it is difficult or impossible to differentiate between body fluids;
    • any unfixed tissue or organ (other than intact skin) from a human (living or dead);
    • HIV-containing cell or tissue cultures, organ cultures, and HIV or HIV-containing culture medium or other solutions.

2. Medical evaluation, procedures, and follow-up will be:

  • Made available at no cost to the employee through the practice
  • Made available to the employee at a reasonable time and place.
  • Performed by or under the supervision of a licensed physician or by or under the supervision of another licensed healthcare professional.
  • Provided according to recommendations of the US public health service current at the time these evaluations and procedures take place. The doctor will review and update post-exposure management guidelines as new directives are issued, but at least annually.
  • All lab tests will be conducted by an accredited laboratory at no cost to the employee.

3. Post-exposure evaluation and follow-up will include at least the following elements:

  • Documentation of the route(s) or exposure, and the circumstances under which the exposure incident occurred
  • Identification and documentation of the source individual, unless identification is infeasible
    • The source individual’s blood will be tested as soon as feasible for HBV; and as soon as consent is obtained, for HIV infectivity. Individuals who will not consent can be tested in accordance with policy.
    • When the source individual is already know to be infected with HBV or HIV, tested for the source individual’s known HBV or HIV status need not be repeated.
    • Results of the source individual’s blood, if available, will be made available to the exposed employee, and the employee will be informed of applicable laws and regulations concerning disclosure of the identity and infectious status of the source individual.
  • Collection and testing of blood or HBV and HIV serological status of the employee:
    • The exposed employee’s blood will be collected as soon as feasible and tested after consent is obtained.
    • If the employee consents to baseline blood collection, but does not give consent at that time for HIV serologic testing, the sample shall be preserved for at least 90 days. If, within 90 days of exposure incident, the employee elects to have the baseline sample tested, such testing shall be done as soon as feasible.
  • Post-exposure prophylaxis, when medically indicated, will be as recommended by the US public health services, to include counseling and evaluation of reported illnesses.

4. Information provided to the healthcare professional responsible for the employees Hepatitis B vaccination and/or the employees evaluation after an exposure incident will include at least the following:

  • A copy of the OSHA regulation 29cfr part 11910.1030 Occupational Exposure To Bloodborne Pathogens; Final Rule
  • A description of the exposed employee’s duties as they relate to the exposure incident
  • Documentation of the route(s) of exposure and circumstances under which exposure occurred
  • Results of the source individual’s blood testing, if available
  • All medical records relevant to the appropriate treatment of the employee including vaccination status

5. The healthcare professional’s written opinion will be obtained and provided to the employee within 15 days of the completion of the evaluation.

  • The healthcare professional’s written opinion for post-exposure evaluation and follow-up will be limited to the following information:
    • Whether Hepatitis B vaccination is indicated for the employee has received such vaccination
    • That the employee has been informed of the results of the evaluation
    • That the 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 diagnoses will remain confidential and will not be included in the written report.

6. Medical recordkeeping: the office of Ron Smith MD will establish and maintain an accurate record for each employee with occupational exposure to include:

  • The name and social security number of the employee
  • A copy of he employee’s Hepatitis B vaccination status including the dates of all the Hepatitis B vaccinations and any medical records relative to the employee’s ability to receive vaccination
  • A copy of all results of examinations, medical testing, and follow-up procedures
  • The employer’s copy of the healthcare professionals’ written opinion
  • A copy of the information provided to the healthcare professional
  • All medical records will be kept confidential and will not be disclosed or reported without the employee’s express written consent to any person within or outside the workplace expect as required be law, and will be maintained for at least the duration of employment plus 30 years.

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