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BLOOD BORNE PATHOGENS EXPOSURE CONTROL PLAN

 

School Name:               MSAD  #71  Kennebunk/Kennebunkport                                                                                                                        

Date of Preparation:      November 13, 2003                                                        

 

In accordance with the OSHA Blood borne Pathogens standard, 29 CFR 1910.103O, the following exposure control plan has been developed:

 

Exposure Determination

 

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 all employees may be expected to incur such occupational exposure, regardless of frequency. In MSAD #71 the following job classifications are in this category:

 

Job Classification                                                          Tasks/Procedures

Nurses                                                                         First Aid, Contact with body fluids

Athletic Trainer                                                            First Aid, Contact with body fluids       

Special Education Life Skills Staff                                 First Aid, Contact with body fluids

Technology Ed. Teachers P.E. Teachers                       First Aid, Contact with body fluids 

School Day Custodians                                                Contact with body fluids

 

In addition, OSHA requires a list 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 for 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                                                          Tasks/Procedures

Secretaries in elementary schools                                  First Aid, Contact with body fluids

Playground Aides                                                         First Aid, Contact with body fluids

Maintenance Staff                                                         Contact with body fluids

Bus Drivers                                                                  Contact with body fluids

         

Implementation Schedule and Methodology

 

OSHA also requires that this plan also 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 this school 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.

 

Work practice controls will be utilized to eliminate or minimize exposure to employees at all MSAD 71 facilities. Where occupational exposure remains after institution of these controls, personal protective equipment shall also be utilized. Sharps containers will be utilized. Used syringes and lancets for insulin injection will be deposited in sharps container located in the nurses office.

 

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

 

  1. Daily monitoring by school nurse.  The school nurse is the only care provider involved in blood glucose monitoring. 
  2. Periodic disposal of sharps container through local emergency medical services.
  3. The nurse is responsible for reviewing the effectiveness controls.

 

Hand washing facilities are also available to the employees who incur exposure to blood or other potentially infectious materials. All MSAD 71 hand washing facilities are located in all bathrooms, custodial work areas, and nurse’s office.

 

After removal of personal protective gloves, employees shall wash hands and any other potentially contaminated skin area immediately or as soon as feasible with anti-bacterial soap and water.  If employees incur exposure to their skin or mucous membranes then those areas shall be washed with antibacterial soap and water or flushed with water as appropriate as soon as feasible following contact.

 

Needles

 

Contaminated needles and other contaminated sharps will not be bent, recapped, removed, sheared or purposely broken.

 

Containers for Reusable Sharps

 

Contaminated sharps that are not reusable are to be placed immediately, or as soon as possible, after use into appropriate sharps containers. At this school the sharps containers are puncture resistant, labeled with a biohazard label, and are leak proof.  Sharps containers are located in the nurse’s office at each school.  Syringes used for insulin injection will be placed in sharps container located in the nurse’s office.

 

Personal Protective Equipment

 

All personal protective equipment used at this facility 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 only 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 which the protective equipment will be used.

 

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. Gloves will be available from main office, nurse’s office, and individual packs given to teachers.   Gloves will be used for the following procedures: any contact with body fluids and cleaning body fluid spills.                                                                                          

 

Disposable gloves used at this facility are not to be washed or decontaminated for re-use 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 re-use provided that the integrity of the glove is not compromised. Utility gloves will be discarded if they are cracked, peeling, torn, punctured, or exhibit 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. Situations at the school, which would require such protection, are as follows: cleaning bathroom facilities.

 

This school will be cleaned and decontaminated according to the following schedule:

 

  1. All school bathrooms will be cleaned and decontaminated nightly.
  2. Nurse’s office will be cleaned daily.

 

Decontamination will be accomplished by utilizing the following materials:

 

  1. bleach solutions
  2. EPA registered germicides

All contaminated work surfaces will be decontaminated after completion of 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 if the surface may have become contaminated since the last cleaning.  

All bins, pails, cans, and similar receptacles shall be inspected and decontaminated on a daily basis and on an as needed basis if they have been contaminated.  Liners will be changed daily. Contaminated materials will be double bagged for disposal.

 

Any broken glassware which may be contaminated will not be picked up directly with the hands. The following procedures will be used: Gloves will be worn. Regular housekeeping procedures and universal precautions will be followed.

 

Regulated Waste Disposal

 

All contaminated sharps shall be discarded as soon as feasible in sharps containers which are located in the school. Sharps containers are located in the school nurse’s office.

 

Hepatitis B Vaccine

 

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

 

Employees who decline the Hepatitis B vaccine will sign a waiver attached to this policy.

 

Employees who initially declined the vaccine but who later wish to have it may then have the vaccine provided at no cost. Requests should be submitted in writing to the superintendent.

 

Post-Exposure Evaluation and Follow-Up

 

Exposure incident means 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.

 

When the employee incurs an exposure incident, it should be reported to school nurse, building principal and/or immediate supervisor.                                                                                              

 

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:

 

  1. Documentation of the route of exposure and the circumstances related to the incident.
  2. 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.
  3. 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 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.
  4. The employee will be offered post exposure prophylaxis in accordance with the current recommendations of the U.S. Public Health Service.
  5. 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.
  6. The following person(s) has been designated to assure that the policy outlined here is effectively carried out as well as to maintain records related to this policy: Superintendent of schools.

 

Interaction with Health Care Professionals

 

A written opinion shall be obtained from the health care professional who evaluates employees of this school. Written opinions will be obtained in the following instances:

 

  1. When the employee is sent to obtain the Hepatitis B vaccine.
  2. 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:

 

  1. Whether the Hepatitis B vaccine is indicated and if the employee has received the  vaccine, or for evaluation following an incident.
  2. That the employee has been informed of the results of the evaluation, and
  3. That the employee has been told about any medical conditions resulting from exposure to blood or other potentially infectious materials.

 

Training

 

Training for all employees will be conducted prior to initial assignment to tasks where occupational exposure may occur. Training will be conducted in the following manner:

 

Training for employees will include the following with an explanation of:

 

  1. The OSHA standard for Blood borne Pathogens
  2. Modes of transmission of blood borne pathogens
  3. This Exposure Control Plan, i.e. points of the plan, lines of responsibility, and how the plan will be implemented.
  4. Procedures which might cause exposure to blood of other potentially infectious materials at this school.
  5. Control methods which will be used at the school to control exposure to blood or other potentially infectious materials.
  6. Personal protective equipment available at this school.
  7. Post Exposure evaluation and follow-up.
  8. Signs and labels used at the schools.
  9. Hepatitis B vaccine program at the school.

 

Record Keeping

 

The Superintendent of Schools will maintain all records required by the OSHA standard.

 

Dates

 

1.      All provisions required by the standard will be implemented by November 30, 2003.

2.      Training will be conducted by the school nurses or other health professional using videotapes, written materials, or slide shows.

3.      All employees will receive annual refresher training.

4.      The outline for the training materials is located in the main office of each building.