Office of Environmental Health & Safety - Exposure Control Plan

Exposure Control Plan Bloodborne Pathogens May 2014 In accordance with the requirements of OSHA 29 CFR 1910.1030 and the Westfield State University Facilities and Operations Health & Safety Policy, the following guidelines have been established to reduce the risk of exposure to bloodborne pathogens for our faculty, staff, and students. Westfield State University has developed this plan to mitigate the hazards of blood, body fluids, sewage, and other similar materials that may pose a risk to employees at occupational risk and to the campus community. Through engineering controls, safe practices, personal protective equipment, housekeeping, immunizations, and training, Westfield State University is committed to take necessary steps to protect employees and the campus community from the risk of exposure. Definitions: • Bloodborne Pathogens – microorganisms that are present in human blood that can cause disease • Hepatitis B Virus (HBV) – bloodborne pathogen that causes inflammation of the liver • Hepatitis A Virus (HAV) – highly contagious, known to spread through the breakdown of sanitary conditions such as floods or other natural disasters, person-to-person contamination, poor hygiene habits (not washing hands thoroughly after using the bathroom), Infected food handlers, contaminated food or water. • Human Immunodeficiency Virus (HIV) – bloodborne pathogen that attacks the body’s immune system, causing the disease known as AIDS. • Personal Protective Equipment – Equipment that is required to protect employees from exposure to blood and body fluids or other hazards. It may include but is not limited to: - Aprons, gowns and lab coats - face shields and/or goggles - gloves - masks for protection • Potentially Infectious Human Body Fluids – fluids in which bloodborne pathogens may be present. - blood - semen - vaginal secretions - cerebral spinal fluid - any other body fluid contaminated with blood • Potentially Infectious Materials – tissue and organs (other than intact skin) from dead or living humans, cell or tissue cultures that contain HIV or HBV and any contaminated sharp object that can penetrate the skin 1

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Sharps Container(s) – Red, labeled leak-proof, puncture resistant closeable containers used to discard (contaminated, presumed contaminated or non-contaminated) sharps. Universal Precautions – guidelines that require faculty and staff to treat all blood, body fluids, sewage and similar materials as infected with HBV, HIV or other bloodborne diseases.

Affected Employees: Westfield State University employees that have been identified as those for whom the risk of exposure is a possibility must not only acquire the appropriate training, but are encouraged to seek (through their supervisor) immunizations for Hepatitis B and Hepatitis A . The vaccine is available at no cost to all Westfield State University employees in the positions identified below: Those employees for whom a risk assessment has been done, include; 1. Westfield State University, Department of Public Safety Police Officers/ISO First Aid / CPR Crime scene analysis Exposure to animal and human bites 2. Facilities and Operations Staff Environmental Services Staff First Aid / CPR Certified Employees Housekeeping/maintenance of restrooms and common areas Grounds and Trades employees Landscapers Plumbers sewage, sink and toilet maintenance other trades staff based on risk assessment 3. Departments of Athletics and Movement Science Faculty, Coaches, Trainers,Staff Administering First Aid/CPR 4. Department of Residential Life Residence Directors First Aid/CPR 4. Department of Health Services 5. Department of Biology , Faculty and Staff If the employee does not wish to take advantage of the free immunization provided for by the university, they will be required to sign a waiver that indicates they were made aware of such a vaccination but chose not to participate. In the instance where those employees who had previously declined the inoculation now opt to take advantage of the program for the free shot(s) at a later date, Westfield State University will make it available to the employee at no cost provided they contact the Office of Environmental Health and 2

Safety in advance. Vaccinations are available as a new hire , during employment and immediately after exposure

Workplace Transmission: Bloodborne pathogens are transmitted in the workplace the same ways, HBV, HIV and other pathogens are transmitted elsewhere, through blood, body fluids, unfixed tissues or organs other than intact skin. The primary routes of disease transmission into the body are; 1. Accidentally cutting yourself with a sharp object or glass that is contaminated with infected blood and body fluids 2. Getting infected blood or body fluids on your skin, especially if your skin has open sores, nicks, acne, dermatitis, broken cuticles and/or cuts 3. Getting infected blood or body fluids in the mucous membranes of your eyes, nose and mouth 4. Sharing or otherwise coming in contact with infected needles 5. Sexual contact with an infected partner Universal Precautions: All blood, body fluids and sources of potentially infectious human body fluids including sewage shall be considered infectious until proven otherwise. Since Westfield State University staff cannot identify a person(s) who may be infected, they shall not take unnecessary chances. It can take just one exposure to become infected. Therefore, any employee who has been assigned the responsibility of providing First Aid / CPR care, clean up or other tasks dealing with blood, body fluids, needles, and sewage should take the following protective action; First Aid • if not trained in first aid / CPR - call the Department of Public Safety at 5262 • if trained, provide care and/or call the Department of Public Safety at 5262 assess the scene… - is it safe to enter ? - if no personal protective equipment available (gloves, face shields masks), then… - give the patient the first aid supplies so that they may treat (if possible) their own wound - if personal protective equipment is available, then… b. provide care utilize… - gloves (non latex if possible) - face mask or shields - resuscitation mask or shield c. clean-up handwashing is required regardless of whether or not gloves and other personal protective equipment was utilized. - wash affected areas for a minimum of 30 seconds, use… - antibacterial / antiseptic soap and water, or - disposable antibacterial / antiseptic waterless cleaner if no soap and water Personal Protective Equipment (PPE) 3

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Eye and face shields, gloves, masks, disposable shoe covers and other similar items must be located within all department, shop and vehicle first aid and biohazard kits. PPE may also include (when applicable) aprons, gowns, laboratory coats and mouthpieces Gloves should be durable and doubled up when necessary to prevent exposures through rips and tears. In addition, it is recommended that the gloves be non-latex for staff who might be latex sensitive. The appropriate type of Personal Protective Equipment depends on the type of work and degree of exposure anticipated. Its purpose is to protect the workers and their clothes from possible exposure and the spread of contamination. blood soaked clothing should not be brought home for laundering. - contaminated clothing should be disposed of or laundered by an outside firm - disposable clothing should be discarded into a red biohazard bag for proper disposal the red bag for disposal must be brought to the Hazardous Storage building by authorized personnel. Contact your supervisor or call the Office of Environmental Health and Safety at 5209. Red bags are readily available in Central Receiving, however, Environmental Services staff should keep a supply ready in an area that is immediately available(in their respective work areas) in the event of an emergency

Gloves • are required to be durable and double layered (if necessary). • they should fit properly and should not be so tight as to become easily ripped. • if damaged, ripped or torn, discard gloves/ the eye and face protection, and replace them with an appropriate PPE that is free from deficiency - Contaminated gloves must not come in contact with equipment, items or surfaces that were not contaminated or infected. Often gloves used to treat a patient remain in use until the patient has been relocated out of the building. Hence, door handles, refrigerators and lights that were previously not a problem have become so. Gloves are inexpensive. Personnel should not feel as though the gloves should be reused. Dispose of them whenever blood and body fluid is a potential or known concern. - Gloves should be removed one at a time. - as you remove your hand from the glove, turn it inside out. - take the other hand out of the 2nd glove, turning it inside out and place them into the 1st glove for disposal. Those gloves must be red-bagged for correct disposal. Blood and Body Fluid Clean-Up: As soon as a blood and body fluid spill has occurred, the first issue is to deal with the victim and any necessary first aid that is required. Once the victim has been attended, the clean-up must begin. • In accordance with prudent practice, products like 3-M quat disinfectant / phenolic should be used to disinfect any blood /body fluids that may have been released. Pre-treatment with 3-M brand heavy- duty ready-to-use Multi-Surface cleaner may be required as needed. Environmental Services staff has been trained with regard to established cleanup procedures. • If a complete clean-up of the spilled blood and body fluid(s) will be delayed, then the Westfield State University Department of Public Safety or other initial response staff should begin the initial decontamination process. Application of a recognized disinfecting solution or spray can be applied until Environmental Services staff can completely mitigate the hazard After a blood and body fluid incident, and before the arrival of either Environmental Services staff, it may become necessary for the Westfield State University Department of Public Safety to start the decontamination process by applying a disinfectant or granular solidifier. This recommendation shall not imply or require that it is their responsibility to completely clean-up the area. Simply, the responding officers are protecting other unsuspecting persons from exposure by covering 4

the blood and/or body fluids with the needed means of disinfectant. Sewage and Sewer Back-up The Center for Disease Control (CDC) has warned of the hazards associated with the inadequate cleaning of business, home, and other properties as a result of a sewer malfunction. This can also occur during local flooding. Our first goal is to protect the staff whose responsibility it is to clean up the spill. Sewer backups may be building specific or a back up from the street that has come from one or more homes and businesses. Since we are unable to tell the difference, we must assume the worst, this is sewage and the potential for blood and body fluid exposure is significant. Boots that can be properly disinfected and washed should be utilized only in the room or hall of origin. These boots like the gloves should not move from place to place because this may spread the contamination. Other types of PPE should be used during the cleanup process (such as the disposable boot covers available in the cleanup kits). Therefore, all pervious and semi-pervious materials that have been contaminated will most likely have to be discarded. Shoes, leather, furniture, sheet-rock, wood and similar pieces will retain water and trace amounts of waste from the sewage which will make them impossible to adequately clean. Impervious materials such as the concrete floor, block walls and the like can be disinfected using the 3-M products described earlier in this document. Safe Housekeeping: • •

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Gloves are required. - Westfield State University recommends at least two pairs Use an apron/ Tyvek coveralls when necessary - these items can be obtained from the office of Environmental Health & Safety or through the area supervisors Restrict access to the area - WSU Department of Public Safety Police Officers should protect a hazardous area until… - A trained Environmental Services staff member arrives - They have applied the necessary disinfectant to prevent any potential exposure Do not pick up broken pieces of glass or sharps with gloved or bare hands. - use tongs, shovels, scoops or brush and dust pan Needles and syringes (if discovered) should be reported to the WSU Department of Public Safety. - do not pick up the needles or attempt to re-cap - The needles and syringes will be removed by the WSU Department of Public Safety Police Officers or the Office Environmental Health & Safety. Use disposable towels and rags to soak up most of the blood and body fluids Place all contaminated material into a red “labeled” biohazard bag for proper relocation and disposal. Westfield State University has a Hazardous Waste Storage building with a segregated bay for this purpose. Do not overfill the containers Clean all work areas at the end of each shift. Use the appropriate disinfectant. Discard as red-bag all bio-hazard waste - all mops and any other used cleaning items. Red bag waste will be kept at the Hazardous Waste Storage building until time of transport.

Laundry: When dealing with or handling bags of laundry that could contain blood 5

or body fluids, it is recommended that… a. always lift the bag (double bag for bio-hazard waste) from the top this will minimize your risk of exposure, since most hazards such as the needles and other sharps will drop to the bottom of the bag Needles and Syringes Needle sticks could pose a significant health risk for the recipient of any contaminated or potentially contaminated needle. Precautions must be taken to minimize the hazard. Regardless of who you are and what you do… a. do not bend, recap, shear or otherwise break a needle used for any purpose b. always dispose of any needle into a puncture resistant, leak-proof “Biohazard” labeled container, as soon as possible. Sharps containers are present in the Office of Health Services c. Report any full or damaged containers to your supervisor for repair or replacement General Practices • • • • • • •

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Do not eat, drink, smoke or apply cosmetics or lip balms or handle contact lenses where personnel may be exposed to blood and body fluids Avoid all petroleum-based lubricants that may dissolve or breakdown the latex gloves Always wash your hands thoroughly (at least 30 seconds) before applying hand cream Do not keep food and drinks in refrigerators, freezers or cabinets, or on shelves, countertops or bench-tops where blood or other potentially hazardous material may be kept Avoid splashing, splattering or spraying of blood - when necessary use the aprons, eye and face protection, gowns and other PPE Never mouth-pipette or suction blood or other potentially hazardous materials All containers used for the disposal of bio-hazardous materials must be red in color and shall be labeled “Biohazard” as required. Access to the Hazardous Waste Storage building can be coordinated through the Office of Environmental Health and Safety or the Department of Facilities and Operations. Remember to inform your supervisor that a response kit has been used and needs immediate replenishment

Biohazard / Infection Control Kits: •

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Biohazard and Infection Control kits, in addition to First Aid Kits should be located in each Westfield State University Police Car, the applicable Biology Department Laboratories, Dining Services, Health Services, and the Departments of Athletics and Movement Science. Bodily Fluid Disposal Kit(s) should be located in at least (1) main custodial closet in each building that is staffed by Facilities and Operations (Environmental Services) personnel

As a minimum the Infection Control and Bodily Fluid Disposal kits shall have; • Disinfectant cleaner • Gloves (adequate in size and number) • Handwash (waterless antibacterial / antiseptic) • Red “Biohazard” labeled bags • Paper or other type towels • Labels • Masks 6

It shall be the responsibility of each departmental supervisor to make certain the kits are inspected and refilled as necessary to ensure adequate means of handling a bio-hazardous incident. Environmental Services personnel must notify the area supervisor when they have used a spill response kit to ensure a replacement kit is always and immediately available. Additional kits will be purchased as necessary through the Office of Environmental Health and Safety. Training: Training shall be provided to all WSU employees at occupational risk on an annual basis. Additional training will be given if changes to the rules, regulations or policies have changed. Employees who may not deal with this type of situation on a routine basis may (if needed) request additional or follow-up training from the office of Environmental Health and Safety. Training will incorporate the following; 1. The OSHA Standard and General Duty Clause 2. Epidemiology, signs and symptoms and transmission of bloodborne pathogens 3. The Exposure Control Plan 4. Procedures that may cause occupational exposure to blood, body fluids and infectious diseases 5. Methods used to control exposures to blood and infectious diseases 6. Personal Protective Equipment available 7. Hepatitis B Vaccine Program/waiver form 8. Procedures to be followed when an exposure to blood and body fluids occurs, and 9. Explanation of required labels and signs Recordkeeping Requirements Confidential Medical Records will be maintained on all Westfield State University employees with an occupational exposure. These records will include the following information; 1. Employee’s Name and Social Security Number 2. Hepatitis B Vaccine status or waiver form 3. Copy of Health Care Professional(s) written opinion following an exposure, and 4. Any information provided by the employer to the health care professional following an exposure incident. Medical Records shall be kept for the duration of the worker’s employment plus 30 years. These records mill be kept in confidential files located in the Department of Human Resources. They will not be disclosed without written permission from the employee. Training Records shall include the following; 1. Date of training session 2. Contents or summary of training session 3. Names and qualifications of trainers 4. Names and job titles of all persons attending the training Training Records shall be maintained for three (3) years from the date of training and will be kept in Office of Environmental Health and Safety. These records shall be available to employees, employees’ representatives, and all other agencies charged with employee safety at the state or federal level. Incident Exposure Reporting: 7

Incident Exposure Report An Accident Investigation Report shall be completed within 24 hours of an exposure incident. The employee’s supervisor, the Facilities and Opertations Safety Officer and/or Human Resources shall conduct a detailed investigation of the exposure incident and complete all sections of the investigation report. The department head will then review the incident and sign the investigation report in order to prevent a recurrence. Post-Exposure Evaluation Following a report of an exposure incident, Westfield State University will make immediately available to the exposed employee a confidential medical evaluation and follow-up. Either the employee’s personal physician or a university appointed physician may conduct the medical evaluation. Documentation of an exposure incident will include the following: 1. Circumstances of the exposure 2. Route of exposure 3. Identification of source individual, if feasible 4. Result of source individual’s blood testing, if feasible; and 5. Result of medical records relevant to appropriate treatment of employee, including vaccination status. Follow-Up Follow up will include post exposure prophylaxis as recommended by the United States Public Health Service, testing of blood for HBV and HIV status, counseling, and evaluation of reported illness Health Care Professional – Provided Information: The following information will be provided to the healthcare professional performing the medical evaluation: 1. 2. 3. 4. 5.

Copy of OSHA standard Description of exposed employee’s duties as they relate to the exposure incident Documentation of the route of exposure Results of source individual’s blood testing; and Medical records relevant to appropriate treatment of employee, including vaccination status.

Healthcare Professionals – Written Opinion: Within 15 days of the completion of the medical evaluation, a written opinion from the healthcare professional shall be given to the employee. The opinion will provide the following information: 1. Whether HBV vaccination is indicated and if the employee received the vaccination 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 the exposure that require further evaluation and treatment All other information is confidential and shall not be in the written report.

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