EXPOSURE CONTROL PLAN [29 CFR 1910.1030]
OPHTHALMOLOGY
UCH – Ophthalmology, Cordova Office 8001 Centerview Parkway, Suite 101 Cordova, Tennessee 38018-4260
EMERGENCY TELEPHONE NUMBERS UCH – Ophthalmology, Cordova Office Implemented 10/1/2014 (Reviewed and Revised as needed July 13, 2016)
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MEMPHIS FIRE DEPARTMENT
9 - 911
MEMPHIS POLICE DEPARTMENT
9 - 911
___________________________________________________ TOSHA
543 - 7259 543 - 7586
TOSHA
1(800) 249-8510
Notify within 8 hours of fatality or within 24 hours for any hospitalization, amputation, or enucleation. ____________________________________________________ OSHA (Regional Office - Atlanta)
(404) 347 - 3573
____________________________________________________ SOUTHERN POISON CENTER
528 - 6048
____________________________________________________ REPORT TOXIC CHEMICAL AND OIL SPILLS
UCH – Ophthalmology, Cordova Office Implemented 10/1/2014 (Reviewed and Revised as needed July 13, 2016)
1 (800) 424 - 8802
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EMPLOYEE RIGHTS AND RESPONSIBILITIES The Occupational Safety and Health Act of 1970 (OSHA) states that "each employer shall furnish to each of his employees employment and a place of employment which is free from recognized hazards that are causing or likely to cause death or physical harm to his employee." [Section 5(a)(1) - generally known as the General Duty Clause] To that end this plan was developed and implemented by our office on 9/1/2014 as a means to eliminate or minimize employee exposure to blood and other potentially infectious materials. It is necessary and essential that ALL EMPLOYEES in this office whose duties involve any reasonably anticipated contact with or exposure to blood or any other potentially infectious material do the following: A. Read, understand and FOLLOW the Exposure Control Plan devised by our office. B. Ask the OSHA Deputy Coordinator, as designated by the employer, any questions you might have regarding the Exposure Control Plan. C. Sign an agreement provided to you by the OSHA Coordinator stating that you have thoroughly read and understand the Exposure Control Plan and will abide by the provisions of our Exposure Control Plan.
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EXPOSURE CONTROL PLAN FOR UCH OPHTHALMOLOGY, CORDOVA OFFICE A. General [29 CFR 1910.1030(c)(1)] This plan is being implemented and observed as a means of minimizing or eliminating bloodborne pathogen exposure to employees of this office. This plan shall contain information concerning the policies, procedures and records of this office with regard to: Exposure Determination Labeling/Hazard Communication HBV Vaccination Engineering Controls Personal Protective Equipment Housekeeping Record-keeping [29 CFR 1910.1030(c)(1)(ii)(A)] B. Exposure Control Manager As an employee of this office, this Exposure Control Plan is available to you upon request during normal business hours in the Procedure Room at 8001 Centerview Parkway, Cordova, TN 38018-4260. [29 CFR 1910.1030(c)(1)(iii)] You may also access this and other plans at: http://uthsc.edu/eye/osha/. William R. Morris, M.D. has been designated by this office as the individual responsible for the completion, implementation and maintenance of this Exposure Control Plan. The OSHA Deputy Coordinators for the Cordova Office are Kathleen Cruzen and Steve Crowe.
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EXPOSURE DETERMINATION A. General [29 CFR 1910.1030(c)(2)(i)] The OSHA Standard describes how to determine which health care employees have occupational exposure to bloodborne pathogens. OSHA defines occupational exposure as reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee's duties. Other potentially infectious materials include: Semen Vaginal Secretions Cerebrospinal Fluid Synovial Fluid Pleural Fluid Pericardial Fluid Amniotic Fluid Saliva in Dental Procedures Any body fluids visibly contaminated with blood All body fluids where it is difficult or impossible to differentiate between body fluids An unfixed tissue or organ from a human (living or dead) B. Job Classification ALL EMPLOYEES with the following Job Classifications are considered to have occupational exposure:[29 CFR 1910.1030(c)(2)(i)(A)] 1. Physician (Ophthalmologist) 2. Optometrist 3. Ophthalmic Technician 4. Ophthalmic Photographer NO Job Classifications exist in which only some of the employees have occupational exposure. [29 CFR 1910.1030(c)(2)(i)(B)] NO EMPLOYEES with the following Job Classification are considered to have occupational exposure: 1. Clerical (Transcriptionist) 2. Receptionist (Medical Office Assistant)
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C. Task and Procedure Description [29 CFR 1910.1030(c)(2)(i)(C)] The following is a list of tasks or procedures that may be associated with occupational exposure: 1. Cleaning examining rooms 2. Assisting physician (Ophthalmologist) in examining patients 3. Assisting physician at minor surgery 4. Changing (removal and replacement) of dressings 5. Cleaning instruments 6. Handling contaminated sharp instruments 7. Handling contaminated laundry 8. Examination of patients with bleeding wounds 9. Performance of minor surgery
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TABLE 1 Task/Protective Equipment Usage Task/Procedure
Employee Classification Ophthalmic Technician
PPE/Precautions
2. Assisting physician (Ophthalmologist) in examining patients 3. Assisting physician at minor surgery 4. Changing (removal and replacement) of dressings 5. Cleaning instruments
Ophthalmic Technician
Gloves, Lab Coat if exposed to blood
Ophthalmic Technician
Gloves, Lab Coat
Ophthalmic Technician Physician Ophthalmic Technician
Gloves, Lab Coat
6. Handling contaminated sharp instruments 7. Handling contaminated laundry
Ophthalmic Technician Physician Ophthalmic Technician
8. Examination of patients with bleeding wounds 9. Performance of minor surgery
Physician
10. Fluorescein Angiography
Photographer Ophthalmic Technician Physician
1. Cleaning examining rooms
Physician
UCH – Ophthalmology, Cordova Office Implemented 10/1/2014 (Reviewed and Revised as needed July 13, 2016)
Gloves
Gloves Safety Eyewear Gloves Hemostats for glass Gloves Gloves, Lab Coat or Gown Gloves, Lab Coat or Gown Gloves, Lab Coat or Gown
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D. Exposure Determination Forms The following forms are to be used to classify employees into three (3) groups depending on their occupational exposure to blood or other potentially infectious materials. These forms will be filled out by all employees and kept in the Exposure Control Plan book. Class I - Job Classifications in which employees DO HAVE occupational exposure Class II - Job Classifications in which employees NORMALLY DO NOT have occupational exposure, but in some situations duties might be assigned them that cause an occupational exposure Class III - Job Classifications in which employees DO NOT have occupational exposure Exposure Determination shall be made WITHOUT regard to use of Personal Protective Equipment.
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EMPLOYEE CATEGORY I Employee Name SS# Date of employment Job Title Job Description
Exposure Potential Tasks
Personal Protective Equipment to be worn
CATEGORY I DEFINITION: Tasks involving exposure to blood, body fluids or tissues. "All procedures or other job-related tasks that involve an inherent potential for mucous membrane or skin contact with blood, body fluids or tissues, or a potential for spills or splashes of them, are Category I tasks. Use of appropriate protective measures should be required for every employee engaged in Category I tasks." Such employees may included, but not be limited to, physicians, nurses, physician assistants, dentists, hygienists, chairside assistants and laboratory technicians fall into this category.
EMPLOYEE ACKNOWLEDGEMENT
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DATE
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EMPLOYEE CATEGORY II Employee Name SS# Date of employment Job Title Job Description
Exposure Potential Tasks
Personal Protective Equipment to be worn
CATEGORY II DEFINITION: Tasks involving no exposure to blood, body fluids or tissues, but employment may require performing unplanned Category I tasks. "The normal work routine involves no exposure to blood, certain body fluids or tissues, but exposure or potential exposure may be required as a condition of employment." For example, business staff who may, as part of their duties, help clean up, set up, handle instruments or impressions, or send out lab work are generally Category II employees.
EMPLOYEE ACKNOWLEDGEMENT
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DATE
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EMPLOYEE CATEGORY III Employee Name SS# Date of employment Job Title Job Description
Exposure Potential Tasks
Personal Protective Equipment to be worn
CATEGORY III DEFINITION: Tasks that involve no exposure to blood, body fluids or tissues. "The normal work routine involves no exposure to blood, body fluids or tissues. Persons who perform these duties are not called upon as part of their employment to perform or assist in emergency medical care or first aid or to be potentially exposed in any other way".
EMPLOYEE ACKNOWLEDGEMENT
UCH – Ophthalmology, Cordova Office Implemented 10/1/2014 (Reviewed and Revised as needed July 13, 2016)
DATE
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LIST OF CLASS I EMPLOYEES July 13, 2016
James C. Fleming, MD Natalie C. Kerr, MD Shiva Bohn, MD Brian Fowler, MD Jesse Wesberry, MD Aaron Waite, MD Cassandra Johnson Charlotte Pepin Yolinda Thompson Maria Wolfe Pam Rice Lori Rikard Lisa Cowans Kathleen Cruzen Steve Moser Steve Crowe Chantel Devould Ursula Walls Sue Wilson Mindy Hughes Sonya Rutledge
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LIST OF CLASS II EMPLOYEES July 13, 2016 None
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LIST OF CLASS III EMPLOYEES July 13, 2016 Kelley Hill Annette Killebrew
METHODS OF COMPLIANCE The following procedures and concepts required by OSHA have been adopted by this UCH – Ophthalmology, Cordova Office Implemented 10/1/2014 (Reviewed and Revised as needed July 13, 2016)
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office for the health, safety and well being of our employees. A. UNIVERSAL PRECAUTIONS [29 CFR 1910.1030(d)(1)] ALL EMPLOYEES WILL UTILIZE "UNIVERSAL PRECAUTIONS" AT ALL TIMES "Universal Precautions" is OSHA's preferred method of control to protect employees from exposure to all human blood, certain human body fluids and Other Potentially Infectious Material (OPIM). The term "Universal Precautions" refers to a concept of bloodborne diseases control which requires that all human blood and OPIM be treated as if known to be infectious for HBV, HIV, or other bloodborne pathogens regardless of the perceived "low risk" of a patient. B. ENGINEERING AND WORK PRACTICE CONTROLS [29 CFR 1910.1030(d)(2)] Employers are required by OSHA to develop and implement engineering and work practice controls as the primary means of eliminating or reducing employee exposure. In the event that a risk of occupational exposure still exists after implementation of engineering and work practice controls the employer will provide and ensure that employees utilize personal protective equipment as additional protection. 1. Hand washing Employees will wash their hands and any exposed skin areas with liquid soap and water immediately or as soon as feasible upon contact with blood, certain body fluids, or OPIM and on the following occasions: - upon reporting for work; - before gloving; - after gloves are removed; - after each patient, or during prolonged contact with one patient; - before handling medications; - before and after eating or smoking; - after using the toilet, blowing or wiping the nose, or similar incidents; - after your hands have touched a surface which may be contaminated; - when soiled; - before leaving the medical office. Employee's mucous membranes that become exposed will be flushed for 15 minutes with water or equivalent substitute immediately or as soon as feasible. Eye Wash Fountains are located in the Clean Room between the Photography Room and the Procedure Room. Upon removal of gloves or other Personal Protective Equipment, employees will use soap and water to wash their hands immediately or as soon as feasible. Should handwashing facilities be unavailable, the employee will use either an UCH – Ophthalmology, Cordova Office Implemented 10/1/2014 (Reviewed and Revised as needed July 13, 2016)
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antiseptic cleanser or towelette; however, when antiseptic cleansers or towelettes are used, hands will be washed with soap and water as soon as possible. Prior to invasive procedures use antimicrobial soaps, such as Hibiclens, as suggested by the CDC. In this office hand washing facilities are located in: [29 CFR 1910.1030(d)(2)(iii)] Each examination room Employee's rest room Employee's lounge Procedure Room
Photography Room Clean Storage Room Clean up Room
Soap used in all hand washing stations is Soft Soap Liquid. Employees MUST wash hands after each patient contact. [29 CFR 1910.1030(d)(2)(v)] Employees MUST wash hands after any glove removal. [29 CFR 1910.1030(d)(2)(v)] 2. Handling of sharps Employees will not bend, recap or remove contaminated needles or other contaminated sharps except as indicated below: [29 CFR 1910.1030(d)(2)(vii)] Syringes and needles used in botulinum toxin injection will not be recapped but will be placed in a covered metal pan bearing the BIOHAZARD LABEL and autoclaved until the toxin is inactivated. The syringe and needle will then be removed as a unit with a hemostat and placed in the proper sharps container. During surgical procedures in which multiple injections are required at varying time intervals, the needle may be recapped between injections utilizing the one-hand "scoop" technique. At the completion of the procedure, the uncapped needle and syringe should be placed in the sharps container.
Employees will place contaminated sharps in the appropriately designated containers located in each examination room, the Procedure Room, the Photography Room, or Clean-up Room. [29 CFR 1910.1030(d)(2)(viii)] Filled sharps containers are closed before overfilled and disposed of in the Stericycle container.
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POLICY ON “SAFE NEEDLES” Due to implementation of new legislation by the State of Tennessee, this office evaluated the availability of “safe needles” for use in the workplace. Information was obtained from several companies regarding the ability to supply suitable products for use in our workplace. No companies at the present time supply products in the needle and/or syringe size used for procedures in our office. The availability of new products will be checked from time to time, and, if they become available on the market, this office will evaluate them and place them in service if they can be used in our practice. In one office procedure (needling of a filtering bleb), the presence of a guard interferes with visualization and the safe and efficient performance of this procedure by the physician. Thus a “safe needle” is not suitable for this use during this procedure. Policy Date: May 29, 2000 WRMorris, MD July 13, 2016 Evaluation of the availability of proper sized needles, particularly 30 G, revealed no manufacturer could supply the needed sizes commonly used in our office. Larger needles are used primarily for drawing up other medication and not for injection into patients. WRMorris, MD Addendum: (May 16, 2001) During the Annual OSHA Training Seminar, employees are asked for their input on new, safer medical devices. [29 CFR 1910.1030(c)(1)(v)] A form is distributed, filled out by the employee, signed, and dated. Copies of this form are filed with the training reports. A blank form is found on the following page. DHHS (NIOSH) Publication 2000-135 “ How to Protect Yourself From Needlestick Injuries” will be distributed during the Annual OSHA Training Seminar to all employees who work in Exposure Determination Class III jobs. Blunt needles do not perform in a satisfactory manner to be used in ophthalmic surgery. Therefore, we do not employ their use in this office. (June 2012)(WRM)
Employee Input Form UCH – Ophthalmology, Cordova Office Implemented 10/1/2014 (Reviewed and Revised as needed July 13, 2016)
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[29 CFR 1910.1030(c)(1)(v)]
Needlestick Safety and Prevention Act of 2000 In order to promote a safe and healthy workplace, UCH –Cordova and UCH – Hamilton Eye Institute solicit input from its employees on the identification, evaluation, and selection of appropriate workplace devices used in the collection of blood, administration of injections, certain laboratory procedures, and some surgical procedures. The regulations for these offices regarding sharps (needles, blades, and suture needles) are contained in the Exposure Control Plan. Specific policies on recapping needles, locating and disposing of sharps containers, and handling of other materials that might injure the employee by percutaneous exposure to blood, blood products, or OPIM are outlined in that document. It is the employee's responsibility to know and follow these requirements. If you have suggestions regarding the use of new, safer devices that might protect you from percutaneous exposure to blood, blood products, or OPIM during the performance of your duties, please place your suggestions in the area below. ______________________________________________________________________ ______________________________________________________________________ ______________________________________________________________________ ______________________________________________________________________ ________________________________ If in the future you become aware of situations that you feel are hazardous in this area, please communicate with you supervisor, the OSHA Deputy in your office, or the OSHA Coordinator. If you have no suggestions at this time please check the BOX below, sign and date this form. I have no suggestions concerning new medical devices as of this date. ___________________________________ Office Name
UCH – Ophthalmology, Cordova Office Implemented 10/1/2014 (Reviewed and Revised as needed July 13, 2016)
Date: ________________
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METHODS OF COMPLIANCE (continued) 3. Personal hygiene Employees will not eat, drink, smoke, apply cosmetics or lip balm, or handle their own contact lenses in work environments where risk of exposure occurs. [29 CFR 1910.1030(d)(2)(ix)] Eating and drinking are allowed in the Break Room area only. Smoking is not allowed at any location in the office. Smoking is allowed outside the building only. Storage of food or drink is allowed ONLY in the refrigerator in the Break Room. No blood products or OPIM are to be stored in this refrigerator. Blood products and OPIM are to be stored ONLY in the refrigerator in the Procedure Room. [29 CFR 1910.1030(d)(2)(x)] Ice trays should be removed from refrigerators in the the Procedure Room. 4. Exposure Minimization Employees will perform all procedures involving blood, body fluids, or OPIM in such a manner as to minimize splashing, spraying, spattering, and generation of droplets by these substances. No brushes will be used during the cleaning of surgical instruments. [29 CFR 1910.1030(d)(2)(xi)] 5.
Specimens of blood, body fluids, or OPIM will be placed in a designated container that prevents leakage during collection, handling, processing, storage, transport, or shipping. This container will be labeled with the Biohazard Symbol and closed prior to storage, transportation or shipping. [29 CFR 1910.1030(d)(2)(xiii)]
6. In this office we do not have equipment that becomes contaminated with blood, body fluids, or OPIM that is shipped or serviced periodically. Surgical instruments sent out for repair shall be autoclaved before shipping and left in the sterile package. [29 CFR 1910.1030(d)(2)(xiv)] PERSONAL PROTECTIVE EQUIPMENT (PPE) [29 CFR 1910.1030(d)(3)(i)] SEE ALSO PERSONAL PRETECTIVE EQUIPMENT PLAN (PPEP) [29 CFR 1910.132] A. PERSONAL PROTECTIVE EQUIPMENT, or PPE can be essentially defined as ancillary body coverings designed to minimize or eliminate exposure to blood or other potentially infectious materials. B. PROVISION: When the chance of occupational exposure exists, the employer has provided, at no cost to the employee, the appropriate PPE in assorted sizes for proper fit.
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Examples: Gloves, gowns, laboratory coats, face shields or masks, eye protection, mouthpieces, resuscitation bags, pocket masks, or other ventilation devices. C. APPROPRIATE PPE [29 CFR 1910.1030(d)(3)(i)] PPE will be considered "appropriate" only if it does not permit blood or other potentially infectious materials to pass through to or reach the employee's work clothes, street clothes, undergarments, skin, mouth, or other mucous membranes under normal conditions of use and for the duration of time which the protective equipment will be used. D. ACCESSIBILITY OF EQUIPMENT [29 CFR 1910.1030(d)(3)(iii)] The employer has ensured that appropriate PPE in a variety of sizes shall be readily accessible, at no cost, to employees including: hypoallergenic gloves, glove liners, powderless gloves, or other similar alternatives for those employees who are allergic to the gloves normally provided. If the employee is allergic to latex, non-latex gloves will be provided for the employee’s use. These are located in the Procedure Room. Employees should be familiar with the NIOSOH Publication 98-113 Latex Allergy – A Prevention Guide. You may access by clicking on the link above or from the Workplace Safety and Health Resources website. E. USE OF PPE [29 CFR 1910.1030(d)(3)(ii)] The employer should ensure that the employee uses appropriate PPE unless the employer can show that the employee temporarily and briefly declined to use PPE when, under rare and extraordinary circumstances, it was the employee's professional judgement that in the specific instance use would have prevented the delivery of health care or public safety services or would have posed an increased hazard to the safety of the worker or co-worker. When the employee makes this judgement, the circumstances shall be investigated and documented in order to determine whether changes can be instituted to prevent such occurrences in the future. F. CLEANING, LAUNDERING, AND DISPOSAL OF PPE [29 CFR 1910.1030(d)(3)(iv)] PPE required by OSHA Standard shall be cleaned, laundered, and disposed of at no cost to the employee(s). PPE must NOT be laundered at home by employee(s). G. REPAIR, REPLACEMENT, REMOVALS [29 CFR 1910.1030(d)(3)(v)] PPE shall be repaired and/or replaced as needed, at no cost to the employee. If a garment is penetrated by blood or other potentially infectious material, the garment shall be removed immediately or as soon as feasible. [29 CFR UCH – Ophthalmology, Cordova Office Implemented 10/1/2014 (Reviewed and Revised as needed July 13, 2016)
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1910.1030(d)(3)(vi)] All PPE MUST be removed and properly disposed of prior to leaving the work area and before entering the employee lounge or other clerical areas of the office. [29 CFR 1910.1030(d)(3)(vii)] When PPE is removed it shall be placed in an appropriately designated area or container for storage, washing, decontamination, or disposal. [29 CFR 1910.1030(d)(3)(viii)] Designated areas or containers should be labeled with the BIOHAZARD SYMBOL, red in color or utilizing RED BAGS. H. GLOVES [29 CFR 1910.1030(d)(3)(ix)] Gloves shall be worn: - WHEN IT CAN BE REASONABLY ANTICIPATED THAT THE EMPLOYEE MAY HAVE HAND CONTACT WITH BLOOD OR OTHER POTENTIALLY INFECTIOUS MATERIALS, MUCOUS MEMBRANES, AND NON-INTACT SKIN. - When performing vascular access procedures. - WHEN HANDLING OR TOUCHING CONTAMINATED ITEMS OR SURFACES. - When handling hazardous medications Disposable (single use, exam) gloves, such as surgical examination gloves, shall be replaced as soon as practical when contaminated or as soon as feasible if they are torn, punctured, or when their ability to function as a barrier is compromised. [29 CFR 1910.1030(d)(3)(ix)(A)] Disposable (single use, exam) gloves shall NOT be washed or decontaminated for re-use. [29 CFR 1910.1030(d)(3)(ix)(B)]
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Utility gloves shall be discarded if cracked, peeling, torn, punctured, or otherwise exhibit signs of deterioration, or when their ability to function as a barrier is compromised. [29 CFR 1910.1030(d)(3)(ix)(C)] I. MASKS, EYE PROTECTION, AND FACE SHIELDS [29 CFR 1910.1030(d)(3)(x)] Masks shall be worn alone or in combination with eye protection devices such as goggles or glasses, side shields, face shields, etc. whenever splashes, sprays, splatter or droplets of blood or other potentially infectious material may be generated and eye, nose, or mouth contamination can be reasonably anticipated. Conditions that generate sprays or droplets will require the use of MASKS AND GOGGLES, GLASSES WITH SIDE SHIELDS, OR FACE SHIELDS IN COMBINATION. Under usual circumstances the procedures performed by the ophthalmologist in the office are NOT ANTICIPATED to generate splashes, sprays, splatters or droplets of blood or OPIM into the air. J. GOWNS AND OTHER PROTECTIVE CLOTHING [29 CFR 1910.1030(d)(3)(xi)] Appropriate protective clothing such as, but not limited to, long-sleeved gowns, aprons, long-sleeved lab coats, long-sleeved clinical jackets, or similar outer garments shall be worn in occupational exposure situations. The type and characteristics of such protective clothing must be appropriate to the task and degree of exposure anticipated. Each office must designate the appropriate PPE that every employee should wear during specific treatments or tasks depending on the degree of exposure anticipated. In the event that an employee’s personal clothing becomes soaked with blood or OPIM, the employer will furnish the employee with a scrub suit for use until the employer can clean/disinfect or have cleaned/disinfected the employee’s clothing. These are located in the Procedure Room.
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K. IN THIS OFFICE THE PPE UTILIZED, ITS AVAILABILITY/LOCATION AND DISPOSABILITY IS AS FOLLOWS: PPE ITEM
LOCATION
DISPOSE/ REUSE
Examination gloves
All exam rooms; Procedure Room
Dispose
Clean Room Gowns
Procedure Room
Dispose
Clean Room Masks
Procedure Room
Dispose
Goggles
Procedure Room
Reuse
Clean Room Eye protection (glasses with side shields)
Procedure Room
Reuse
Clean Room
L. IN THIS OFFICE THAT PPE THAT DECONTAMINATED AS FOLLOWS:
IS
"REUSED"
IS
CLEANED
PPE ITEM
METHOD TO CLEAN OR DECONTAMINATE
Laboratory coats
Send to Commercial Laundry
Goggles
Decontaminate with FRESH 1:10 Clorox, Rinse
Eye protection (glasses with side shields)
Decontaminate with FRESH 1:10 Clorox, Rinse
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OR
M. IN THIS OFFICE THAT PPE WHICH IS "DISPOSED" OF IS CONTAINED AS FOLLOWS: PPE ITEM
RECEPTACLE TYPE
FINAL RECEPTACLE
Gloves
Exam room receptacle Procedure Room receptacle
Bio-Waste Medical Box
Masks
Exam room receptacle Procedure Room receptacle
Bio-Waste Medical Box
Gowns
Exam room receptacle Procedure Room receptacle
Bio-Waste Medical Box
N. IN THIS OFFICE THERE ARE NO EXPOSURE SITUATIONS WHERE PPE MAY BE REQUIRED, BUT NOT UTILIZED.
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WORK SURFACE/WASTE CONTAINER CLEANING AND DISINFECTING [29 CFR 1910.1030(d)(4)(i)] A. Employers shall ensure work-sites shall be maintained in a clean and sanitary condition. B. The employer shall determine and implement an appropriate written schedule for cleaning and method of decontamination based on the location and the facility, type of surface to be cleaned, type of contaminant present, and tasks and procedures being performed in the area. C. All equipment, environmental and working surfaces, shall be cleaned and decontaminated after contact with blood or other potentially infectious materials. [29 CFR 1910.1030(d)(4)(ii)] D.
Contaminated work surfaces shall be decontaminated with an appropriate disinfectant after completion of procedures: [29 CFR 1910.1030(d)(4)(ii)(A)] IMMEDIATELY, or as soon as feasible, when surface are overtly contaminated; After any spill of blood or other potentially infectious materials; or At the end of each work shift if the surface may have become contaminated since the last cleaning. Documentation of Worksurface cleaning will be accomplished by completion of the Cleaning/Disinfection Documentation Chart (Page 28 of the Exposure Control Plan) on a daily basis. These charts are to be located in each examining room or other areas that require regular or periodic cleaning. At the end of each month the completed charts are placed in the loose-leaf binder provided. At the end of the third year, the oldest charts may be removed. This binder is kept with the other OSHA manuals in the Photography Room.
E. Protective coverings such as plastic wrap, aluminum foil or imperviously backed absorbent paper used to cover equipment and environmental surfaces shall be removed and replaced as soon as feasible when they become overtly contaminated or at the end of a work shift or if they may have become contaminated during the shift. [29 CFR 1910.1030(d)(4)(ii)(B)] F. All bins, cans, and similar receptacles intended for reuse which have a reasonable likelihood of becoming contaminated with blood or other potentially infectious materials shall be inspected and decontaminated on a regularly scheduled basis and decontaminated immediately or as soon as feasible upon visible contamination. [29 CFR 1910.1030(d)(4)(ii)(C)]
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G. In the event of breakage of a glass container which contains contaminated material or where the contents are unknown, the employee will NOT pick up the glass directly with his/her hands but utilize some mechanical device such as a hemostat to accomplish the clean up. The glass fragments must be placed directly into a redlabeled sharps container, and the instrument decontaminated at the completion of the clean up. [29 CFR 1910.1030(d)(4)(ii)(D)] H.
In developing a scheduled program for cleaning and disinfecting the work surfaces and waste containers the office should consider certain factors, some of which include: Potential for surface or container contamination may reasonably occur; Insuring that employees utilize PPE when cleaning and disinfecting; Any disinfectant should have a notation on the bottle or can that it is an EPAapproved tuberculocidal.
I. THE CLEANING AND DISINFECTING PROGRAM FOR THIS OFFICE IS: ROOM
CONTAINER OR SURFACE TYPE
FREQUENCY USED
DISINFECTANT /PPE
Exam rooms
Counter tops
1. 2.
End of day Immediately if contaminated
Lysol Spray Sani-Wipe/ Gloves
1. 2.
Daily if used Immediately if contaminated Weekly
Lysol Spray/
Daily if used Immediately if contaminated Weekly
Lysol Spray Sani-Wipes/ Gloves
Chairs Exam rooms
Infectious waste container
3. Photography Room
Counter tops Instrument stand surfaces
1. 2. 3.
Gloves
Procedure Room
Counter tops
1. 2.
Daily if used Immediately if contaminated
Lysol Spray Sani-Wipe/ Gloves
Procedure Room
Infectious waste
1. 2.
Daily if used Immediately if contaminated Weekly
Lysol Spray/
container
3.
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Gloves
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The following are to be used as a disinfectant according to label instructions. Lysol Spray EPA# 777-53-675 777-1L-1, NJ-2,11525-1L-01 1L1-2224-1 Sani-Cloth EPA# 1130-6-9480 9480-IN-1 J. THE PERSON(S) RESPONSIBLE FOR PERFORMING THE CLEANING AND DISINFECTING IS (ARE): Ophthalmic Assistants
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CLEANING/DISINFECTION DOCUMENTATION CHART
Cordova Office
Room ____________ Month/Year ______________ Disinfectant Utilized __________________ Day
Clean/Disinfect
Initials
Sharps Container
Initials
PPE
Initials
1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31
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REGULATED WASTE/REGULATED MEDICAL WASTE [29 CFR 1910.1030(d)(4)(iii)] A. OSHA DEFINES REGULATED WASTE OR REGULATED MEDICAL WASTE AS: Liquid or semi-liquid blood or other potentially infectious materials; Contaminated items that would release blood or other potentially infectious materials in a liquid or semi-liquid state if compressed; Items that are caked with dried blood or other potentially infectious materials and are capable of releasing these materials during handling; Contaminated sharps including exposed ends of dental wires; Pathological and microbiological wastes containing blood or other potentially infectious materials, including extracted teeth. B. CONTAMINATED SHARPS 1910.1030(d)(4)(iii)(A)]
DISPOSAL
AND
CONTAINMENT
[29
CFR
Contaminated sharps shall be discarded IMMEDIATELY or as soon as feasible after use in containers that are: -
Always upright; Replaced before being overfilled; Closable; Puncture resistant; Leak proof on the sides and bottom; Appropriately labeled or color-coded; Disposable; Easily accessible to employees in immediate areas of use or anticipated use.
Broken glassware may be contaminated and should not be picked up directly with the hands. It shall be cleaned up by using mechanical means only and placed in a sharps container. Reusable sharps contaminated with blood or other potentially infectious material shall not be stored or processed in a manner that requires employees to reach by hand into a container where these sharps have been placed. - Reusable containers shall not be opened, emptied or cleaned manually, in a manner that would expose employees to the risk of percutaneous injury.
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-When moving containers of contaminated sharps from the area of use the container shall be: - Closed immediately prior to removal or replacement to prevent spillage or protrusion of contents during handling, storage, transport, or shipping. - If leakage or protrusion occurs it should be placed in another secondary container that is closable, puncture resistant, leak-proof, and appropriately labeled or colorcoded. C. REGULATED MEDICAL WASTE SHOULD BE PLACED IN THE APPROPRIATE CONTAINERS THAT ARE: Approved as medical waste containers by the Federal, State, or local government and will meet or exceed all of the applicable regulations such as: container strength, lockable or sealable tops, puncture resistant (sharps container); Closable Constructed to contain all contents and prevent leakage of fluids during handling, storage, transport, or shipping. Labeled or color-coded in accordance with the OSHA Standard. Closed prior to removal to prevent spillage or protrusion of contents during handling, storage, transport, or shipping. If outside contamination of the regulated waste container occurs, it should be placed in a second container. - The second container should: 1. Closable; 2. Constructed to contain all contents and prevent leakage of fluids during handling, storage, transport, or shipping; 3. Labeled or color-coded in accordance with the OSHA Standard; and 4. Closed prior to removal to prevent spillage or protrusion of contents during handling, storage, transport, or shipping.
D. IN THIS OFFICE REGULATED MEDICAL WASTE DISPOSAL IS GIVEN CERTAIN CONSIDERATIONS Location and type of containers UCH – Ophthalmology, Cordova Office Implemented 10/1/2014 (Reviewed and Revised as needed July 13, 2016)
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- Sharps containers - Other regulated medical waste containers How packaged, who packages and how ultimately removed - When sharps are removed from locations - When other regulated medical waste is removed from locations - How ultimately disposed of IN THIS OFFICE REGULATED MEDICAL WASTE IS CONTAINED AND DISPOSED OF AS FOLLOWS: WASTE CONTAINER
LOCATION
REMOVAL FREQUENCY
Sharps
Each exam room When full (to full line)
Hazardous waste container
Sharps
Procedure Room When full (to full line)
Hazardous waste container
Exam room Receptacle
Each exam room Daily or when full (to full line)
Hazardous waste container
Procedure Room Receptacle; Photography Room
Procedure Room; Photography Room
Hazardous waste container
Daily or when full (to full line)
ULTIMATE DESTINATION
IN THIS OFFICE THESE EMPLOYEES ARE RESPONSIBLE FOR THE MANAGEMENT OF REGULATED MEDICAL WASTES: EMPLOYEE NAME Ophthalmic Assistants Charlotte Pepin
DATE GIVEN RESPONSIBILITY September 1, 2014 July 1, 2012
IN THIS OFFICE REGULATED MEDICAL WASTE IS:[29 CFR 10.1030(d)(4)(iii)(C)] RECEIVED BY: Bio-Waste Solutions
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DISPOSED OF BY:
Sterilization
REMOVED: Twice weekly IN THIS OFFICE Mark Melton Facilities Manager UCH 66 N. Pauline, Room 101 Memphis, TN 38105-5102 (901) 448-5005 is ultimately responsible for insuring proper (legal) disposal of regulated medical waste, including: - Verification of all permits - Verification of all insurance - Verification and maintenance of disposal records These verifications are filed in the office of: Mark Melton Facilities Manager UCH 66 N. Pauline, Room 101 Memphis, TN 38105-5102 (901) 448-5005 Burn Reports (disposal records) are available online at the Bio-Waste website: http://www.bio-wastesolutions.com and in Melissa Scurlock Office at Hamilton Eye Institute, Second Floor.
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CONTAMINATED LAUNDRY [29 CFR 1910.1030(d)(4)(iv)] A. Shall be handled as little as possible with a minimum of agitation; [29 CFR 1910.1030(d)(4)(iv)(A)] B. Shall be bagged or containerized IN THE ROOM WHERE IT WAS USED and shall not be sorted or rinsed in the area of use; [29 CFR 1910.1030(d)(4)(iv)(A)(1)] C. IF WET AND PRESENTS A REASONABLE LIKELIHOOD OF SOAKING THROUGH OR LEAKING FROM THE BAG OR CONTAINER, the laundry shall be placed an transported in bags or containers that prevent soaking or leakage of fluid (red plastic); [29 CFR 1910.1030(d)(4)(iv)(A)(3)] D. Shall be placed and transported in appropriately labeled or color-coded bags or containers labeled with the BIOHAZARD SYMBOL in accordance with the OSHA Standard. These bags or containers must be labeled or color-coded in such a manner that it permits all employees to recognize these bags or containers to require compliance with Universal Precautions. [29 CFR 1910.1030(d)(4)(iv)(A)(2)] E. The employer shall ensure that employees who have contact with contaminated laundry wear protective gloves or other appropriate PPE; [29 CFR 1910.1030(d)(4)(iv)(B)] F. Contaminated laundry includes PPE, but not clothing worn under PPE. G. SHALL NOT be taken home by employee to wash. H. THE PROCESS FOR HANDLING AND CLEANING CONTAMINATED LAUNDRY IN THIS OFFICE IS:
LAUNDRY TYPE
HOW BAGGED/CONTAINERIZED
WHERE CLEANED
Lab coats
"BIOHAZARD" Labeled Bags
Off-site
Towels
"BIOHAZARD" Labeled Bags or Red plastic bags (if soaked with blood or other potentially infectious materials), then placed in laundry bags.
Off-site
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I. The off-site laundry service utilized is: AmeriPride Linen and Apparel Services 800 Vance Avenue Memphis, TN 38126 (901) 525-3434 J. The off-site laundry service DOES utilize Universal Precautions, but repeated attempts to verify this policy were not successful (see letter). K. When shipping laundry to a facility that does not utilize Universal Precautions, laundry containers shall be appropriately labeled or color-coded in accordance with the OSHA Standard (red bags or red containers). L. Should be cleaned or laundered by employer at no expense to the employee.
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HEPATITIS B VACCINATION [29 CFR 1910.1030(f)(1)(i)] Initial Hepatitis B Vaccination A. Hepatitis B vaccination must be made available at no cost and at a reasonable time and place to all employees who have occupational exposure. [29 CFR 1910.1030(f)(1)(ii)(A),(B)] The vaccine shall be administered by a physician or other licensed health care professional. [29 CFR 1910.1030(f)(1)(ii)(C)] The vaccine shall be provided in accordance with current United States Public Health Service recommendations. [29 CFR 1910.1030(f)(1)(ii)(D)] Vaccination shall be made available after the employee has received the training described under "Training" and within 10 working days of initial assignment to tasks involving occupational exposure. [29 CFR 1910.1030(f)(2)(i)] The vaccination requirement is waived if the employee has previously received the complete HBV vaccination series, or if antibody testing reveals that the employee is immune, or if the vaccine is contraindicated for medical reasons. If the employee claims to have previously received the vaccination series the employee is required to document such immunization in WRITING. The employer shall not make pre-screening a pre-requisite for receiving hepatitis B vaccination. [29 CFR 1910.1030(f)(2)(ii)] If the employee wishes to be evaluated before vaccination, the employer must obtain the health care professional's written opinion (see section on health care professional's written opinion) and give it to the employee within 15 days of completion. The report should be limited to whether HBV vaccination is indicated and if vaccination has been received. [29 CFR 1910.1030(f)(5)(i)] The employer must provide a copy of the OSHA Standard to the health care professional who will evaluate the employee and/or administer the vaccine. Such vaccination series requirements apply to part-time, temporary and probationary employees.
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B. If the employee initially declines hepatitis B vaccination the employer must still make the vaccine available at a later date, at no cost to the employee, provided: The employee is still covered under the Standard; The employee still has occupational exposure. [29 CFR 1910.1030(f)(2)(iii)] C. Employees who decline to be vaccinated shall be required to sign the Hepatitis B Vaccination Declination Form. [29 CFR 1910.1030(f)(2)(iv)] D. If in the future, the United States Public Health Service recommends booster doses, the employer must provide these at no cost. [29 CFR 1910.1030(f)(2)(v)] E. All necessary laboratory tests shall be conducted by an accredited laboratory at no cost to the employees and this report should be filed in the employee's medical record. Findings and diagnoses not pertaining to HBV vaccination must remain confidential and cannot be included in the written report. [29 CFR 1910.1030(f)(1)(iii)]
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PROPHYLAXIS RECORD HEPATITIS B VACCINE
NAME SS#
Type of Vaccine Manufacturer
FIRST DOSE
DATE
/
/
ML
SECOND DOSE
DATE
/
/
ML
THIRD DOSE
DATE
/
/
ML
RECEIVED AT
PROVIDER SIGNATURE
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DATE
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HEPATITIS B VACCINE DECLINATION [29 CFR 1910.1030, Appendix A]
I understand that due to my occupational exposure to blood and other potentially infectious materials I may be at risk of acquiring Hepatitis B (HBV) infection.
I have been given the opportunity to be vaccinated with Hepatitis B vaccine at no charge to myself. However, I decline Hepatitis B vaccination at this time. I understand that by declining the vaccine I continue to be at risk of acquiring Hepatitis B, a serious disease.
If in the future I continue to have occupational exposure to blood or other potentially infectious materials and I want to be vaccinated with Hepatitis B vaccine, I can receive the vaccination series at no charge to me.
_______________________ Employee
_______________________ Employee Name
_______________ Date
___________________________ Job Classification
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POST-EXPOSURE PROCEDURES [29 CFR 1910.1030(f)(3)] A. Exposure Incident Evaluation Procedures (A checklist for completion is included in the Exposure Control Plan Book) Should an employee experience an Exposure Incident, the circumstances surrounding the Exposure Incident shall be evaluated including: - The procedures or tasks being performed; - Engineering controls in place at the time of the Exposure Incident; or why such controls were not in place; - Work practice controls in place at the time of the Exposure Incident; or why such practices were not observed; and/or - Personal Protective Equipment utilized at the time of the Exposure Incident; or why such equipment was not utilized. The goal of this evaluation is to identify and correct problems in order to prevent recurrence of similar incidents, not necessarily as a disciplinary measure. These factors should be evaluated by the employer to determine if certain trends involving engineering controls, work practices, or PPE should be added or modified. B. Post-exposure In the event of an Exposure Incident, the employee should report to the nearest hospital emergency department. Take a copy of the latest treatment protocol found in the First Aid Box in the clinic. You should also notify Brittany Moore, UCH Safety Officer at (901) 866-8109. The OSHA Coordinator should be notified as soon as possible. EPINET FORMS: "Uniform Blood an Body Fluid Exposure Report" or "Uniform Needlestick and Sharp Object Injury Report" Additional help and advice on treatment may be obtained from the PEPline at: 1-888-HIV-4911. Following a report of an Exposure Incident, the employer shall immediately make available to the exposed employee a confidential medical evaluation and follow-up including at least the following elements. UCH – Ophthalmology, Cordova Office Implemented 10/1/2014 (Reviewed and Revised as needed July 13, 2016)
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Exposure information - Documentation of the route(s) of exposure and the circumstances under which the Exposure Incident occurred. [29 CFR 1910.1030(f)(3)(i)] - Identify and document the source individual unless the employer can establish that such identification and documentation is impossible or prohibited by law. [29 CFR 1910.1030(f)(3)(ii)] - The source individual's blood shall be tested for HBV and HIV as soon as possible after consent is obtained. If the source individual is known to be seropositive for HBV or HIV, testing for that virus need not be done. [29 CFR 1910.1030(f)(3)(ii)(A)] - If consent cannot be obtained or is not required by state law, this should be noted IN WRITING. - The results of the source individual's testing shall be made available to the exposed individual, if allowed by state laws. The exposed employee must also be informed of laws and regulations governing confidentially of the source individual's status. [29 CFR 1910.1030(f)(3)(ii)(C)] Exposed employee - The exposed employee's blood shall be collected as soon as feasible and tested, after consent is obtained. 1910.1030(f)(3)(iii)(A)] - If employee consents to baseline blood collection, but does not give consent for HIV serologic testing, the sample must be preserved for at least 90 days. If, within 90 days of the incident, the employee decides to consent to have the baseline sample tested, such testing shall be done as soon as feasible - at no cost to the employee. {1910.1030(f)(3)(iii)(B)] - Administer postexposure prophylaxis, when medically indicated, as recommended by the United States Public Health Service. [29 CFR 1910.1030(f)(3)(iv)] - Provide counseling [29 CFR 1910.1030(f)(3)(v)] - Evaluate reported illnesses. [29 CFR 1910.1030(f)(3)(vi) Evaluating health care professional (physician) The employer is required to provide certain information to the health care professional who is responsible for the postexposure evaluation of the employee, including: - A copy of the OSHA Standard and subsequent modification (if not currently held UCH – Ophthalmology, Cordova Office Implemented 10/1/2014 (Reviewed and Revised as needed July 13, 2016)
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by the health care professional);[29 CFR 1910.1030(f)(4)(ii)(A)] - A description of the exposed employee's duties as they relate to the Occupational Exposure Incident; [29 CFR 1910.1030(f)(4)(ii)(B)] - Documentation of the route(s) of exposure and circumstances in which exposure occurred (from above); [29 CFR 1910.1030(f)(4)(ii)(C)] - Results of the source individual's blood testing, if available; [29 CFR 1910.1030(f)(4)(ii)(D)] - All medical records relevant to the appropriate treatment of the employee, including vaccination status, which are the employer's responsibility to maintain. [29 CFR 1910.1030(f)(4)(ii)(E)] Health care professional's written opinion after exposure incident The written opinion of the health care professional should be made available to the employer and employee within 15 days of completion of the evaluation. The written opinion should include only the following information: [29 CFR 1910.1030(f)(5)(ii)] - That the employee has been informed of the results of the evaluation; and [29 CFR 1910.1030(f)(5)(ii)(A)] - That the employee has been informed about any medical conditions resulting from exposure to blood or other potentially infectious materials which require further evaluation or treatment. [29 CFR 1910.1030(f)(5)(ii)(B)] All other findings or diagnosis by the health care professional shall remain confidential and shall not be included in the written report. [29 CFR 1910.1030(f)(5)(iii)] The employee/employer should realize the importance of such documentation for short-term and long-term obligations to the employee and employer. POST-EXPOSURE CHECK LIST (Fill In Date When Completed) EMPLOYEE______________________________DATE OF EXPOSURE _________ PROCEDURE TO BE COMPLETED
DATE
1. Fill out Exposure Report Form
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2. Referral of Employee to Evaluating Health Care Professional with (1) Exposure Report Form, (2) Copy of OSHA Standard, (3) Description of Employee's Duties, (4) Results of Source Individual's blood testing (if known) and (5) Employee's Medical Records relevant to treatment 3. Identify Source Individual (if possible) 4. Test Source Individual's Blood for HIV and HBV reactivity (if person will allow) 5. Document refusal of Source Individual to have blood tested 6. Disclosure to employee the results of testing of the Source Individual's blood 7. Evaluate Engineering Controls, Work Practice Controls and Use of Personal Protective Equipment at time of exposure 8. Receive report from Evaluating Health Care Professional within 15 days 9. Administer post-exposure prophylaxis if recommended 10. Provide counseling to employee 11. Evaluate illnesses reported by the employee
Evaluating Health Care Professional______________________________
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COMMUNICATION OF HAZARDS [29 CFR 1910.1030(g)(1)(i)] A. BIOHAZARD SYMBOL
The above is typically referred to as the universal "BIOHAZARD SYMBOL." The lettering and symbol are typically black or dark print against an orange or redorange background. This BIOHAZARD SYMBOL is notification to the health care employee that the item or contents may present a possible occupational exposure, and that appropriate precautions be observed. This BIOHAZARD SYMBOL should be printed on, or affixed to the following: - Containers of regulated waste; [29 CFR 1910.1030(g)(1)(i)(A)] - Refrigerators or freezers used to store blood or other potentially infectious material; [29 CFR 1910.1030(g)(1)(i)(A)] - Containers used to store, dispose of, or transport blood or other potentially infectious materials. [29 CFR 1910.1030(g)(1)(i)(A)] The BIOHAZARD SYMBOL label DOES NOT need to be placed on the following: - Blood and blood products labeled as to their contents that have been released for transfusion or clinical use; [29 CFR 1910.1030(g)(1)(i)(F)] - Individual containers of blood or other potentially infectious materials if placed in a larger labeled container; [29 CFR 1910.1030(g)(1)(i)(G)] - Decontaminated REGULATED WASTE; [29 CFR 1910.1030(g)(1)(i)(I) or - Containers or bags that are red. [29 CFR 1910.1030(g)(1)(i)(E)]
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TRAINING [29 CFR 1910.1030(g)(2)(i)] A. General The office/employer shall provide a training program for each of its employee at the time of initial employment or assignment to tasks with occupational exposure and annually thereafter. This training will be provided to the employee during regular working hours and at no cost to the employee. [29 CFR 1910.1030(g)(2)(i),(ii)(A),(C)] Additional training will be provided when any modification in tasks or procedures occurs or following the institution of new tasks or procedures. [29 CFR 1910.1030(g)(2)(v)] Materials appropriate in content and vocabulary to educational level, literacy, and language shall be used. [29 CFR 1910.1030(g)(2)(vi)] Documentation - Complete "Employee Confirmation" and "In-Service Training Checklist" forms after each training session. - These forms are to be filed in the Training Records File of the OSHA Coordinator in the Coleman Building Office. B. THE TRAINING PROGRAM WILL CONTAIN THE FOLLOWING ELEMENTS: [29 CFR 1910.1030(g)(2)(vii)] An accessible copy of the regulatory text of 29 CFR 1910.1030 and an explanation of all applicable regulations regarding exposure to occupational bloodborne disease; [29 CFR 1910.1030(g)(2)(vii)(A)] A general explanation of the epidemiology and symptoms of bloodborne disease; [29 CFR 1910.1030(g)(2)(vii)(B)] An explanation of the mode of transmission of bloodborne pathogens and other common microbial pathogens; [29 CFR 1910.1030(g)(2)(vii)(C)] An explanation of the employer's Exposure Control Program and a means by which employees can obtain a copy of the written plan; [29 CFR 1910.1030(g)(2)(vii)(D)] An explanation of the appropriate methods for recognizing tasks and other activities that may involve exposure to blood and other potentially infectious materials; [29 CFR 1910.1030(g)(2)(vii)(E)] An explanation of the use and limitations of practices that will prevent or reduce UCH – Ophthalmology, Cordova Office Implemented 10/1/2014 (Reviewed and Revised as needed July 13, 2016)
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exposure including appropriate engineering controls, work practices, and personal protective equipment; [29 CFR 1910.1030(g)(2)(vii)(F)] Information on the types, proper use, selection, location, removal, handling, decontamination and/or disposal of personal protective equipment; [29 CFR 1910.1030(g)(2)(vii)(G),(H)] Information on the appropriate actions to take and persons to contact in an emergency involving blood or other potentially infectious materials. [29 CFR 1910.1030(g)(2)(vii)(J)] An explanation of the signs and labels and/or color-coding that is required by applicable regulations; [29 CFR 1910.1030(g)(2)(vii)(M)] Posting and availability of emergency phone numbers and emergency response procedures; A detailed explanation of spill containment and spill decontamination procedures; An explanation of the various methods of waste decontamination and disposal; Information on the hepatitis B vaccine, including information on its safety, efficacy, safety, and the benefits of being vaccinated; [29 CFR 1910.1030(g)(2)(vii)(I)] An explanation of the medical and notification procedures to follow if an exposure incident occurs, including the method of reporting the incident and the medical followup that will be made available. Also information on the medical counseling that the employer is providing for exposed individuals. [29 CFR 1910.1030(g)(2)(vii)(K),(L)] An opportunity for interactive questions and answers with the person conducting the training session. [29 CFR 1910.1030(g)(2)(vii)(N)]
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IN-SERVICE TRAINING CHECKLIST Training Topics to Be Addressed
Done
1. A copy and explanation of the standard 2. An explanation of our EXPOCON and how to obtain a copy 3. An explanation of methods to recognize tasks and other activities that may involve exposure to blood and OPIM, including what constitutes an exposure incident 4. An explanation of the use and limitations of engineering controls, work practices, and PPE 5. An explanation of the types, uses, location, removal, handling, decontamination, and disposal of PPE 6. An explanation of the basis for PPE selection 7. Information on the hepatitis B vaccine, including information on its efficacy, safety, method of administration, the benefits of being vaccinated, and that the vaccine will be offered free of charge 8. Information on the appropriate actions to take and persons to contact in an emergency involving blood or OPIM 9. An explanation of the procedure to follow if an exposure incident occurs, including the method of reporting the incident and the medical follow-up that will be made available 10. Information on the post-exposure evaluation and follow-up that the employer is required to provide for the employee following an exposure incident 11. An explanation of the signs and labels and/or color coding required by the standard and used at this facility 12. An opportunity for interactive questions and answers with the person conducting the training session.
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B. BLOODBORNE PATHOGENS AND THEIR METHODS OF TRANSMISSION A bloodborne pathogen is defined as a "pathogenic microorganism that is present in human blood and can cause disease in humans." These pathogens include, but are not limited to Hepatitis B Virus (HBV), Hepatitis C Virus (HCV) and Human Immunodeficiency Virus (HIV). Although malaria, syphilis, and brucellosis are also examples of bloodborne diseases, OSHA's Final Rule focuses on exposure prevention to HBV, HCV and HIV. Body Fluids/Substances IN ADDITION TO BLOOD That May Contain Bloodborne Pathogens -
Semen Vaginal Secretions Cerebrospinal Fluid Synovial Fluid Pleural Fluid Pericardial Fluid Peritoneal Fluid Amniotic Fluid Saliva in dental procedures ANY BODY FLUID VISIBLY CONTAMINATED WITH BLOOD (HUMAN TEARS would fall in this category if visibly contaminated with blood) Any unfixed human tissue or organ (BIOPSY SPECIMENS would fall under this category) HIV-containing cell or tissue cultures HIV-containing culture media Blood or tissue from HIV or HBV infected research animals All body fluids in situations where it is difficult or impossible to differentiate between body fluids
How Exposure to Blood and/or Body Fluid/Substances May Occur - An exposure to blood and/or body fluid/substances require very specific conditions. - The fluid/substance must be directly introduced into the person's body. This means blood and/or body fluids/substances must be introduced through the skin (percutaneous) or by contact with mucous membranes such as the eye, mouth, or nose.
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- A percutaneous exposure occurs when body fluids/substances are introduced through the skin. This can occur by being injured by a needlestick, sustaining a cut by a sharp object, or having blood and/or body fluids/substances contaminate non-intact skin, that is, an existing wound, sore, broken cuticle, or chapped skin. - A mucous membrane exposure occurs when blood and/or body fluids/substances are splashed into the eye, mouth, or nose. - There are no known cases of HIV developing after mouth-to-mouth resuscitation. - HIV and HBV are not transmitted by casual contact or through intact skin. - Limiting routes of exposure means instituting Universal Precautions to ensure that health care workers will be adequately protected. What Does the Term "Universal Precautions" Mean? Universal Precautions is a concept of exposure/infection control. - ALL blood and certain body fluids are considered as potentially containing bloodborne pathogens. - This concept is to be followed regardless of whether the health care worker knows the HBV/HIV status of the patient. - Utilizing Universal Precautions is also beneficial in reducing the health care worker's exposure to other types of infection. Factors Influencing the Likelihood of Infection with Bloodborne Pathogens The likelihood of infection after exposure to HIV or HBV depends on: 1. 2. 3. 4.
The concentration of the virus (viral concentration is higher for HBV than HIV). The duration of the contact. The presence of skin lesions on the hands of health care workers. The immune status of the health care worker (for HBV).
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Therefore, IMMEDIATELY AND THOROUGHLY WASH HANDS AND SKIN SURFACES THAT ARE CONTAMINATED WITH: 1. 2. 3.
Blood. Body fluids/substances containing visible blood (bloody tears). Other body fluids to which Universal Precautions apply.
Remember to wear protective barriers for any anticipated contact with: 1. 2. 3.
Blood. Body fluids/substance containing visible blood (bloody tears). Other body fluids to which Universal Precautions apply.
How HIV and HBV Are Transmitted Both HIV and HBV are transmitted the same way, that is, through: 1. 2. 3.
Sexual contact. Mucous membrane or parenteral exposure to infected blood and/or body fluids/substances. Mother/infant (in utero/perinatal).
The primary potential risk for health care workers is a percutaneous or mucous membrane exposure to infected blood and/or body fluids/substances. - All health care workers are concerned about contracting HIV because of its fatal outcome. - Pregnant health care workers are not known to be at greater risk of contracting HIV or HBV infection than health care workers that are not pregnant: however, if a health care worker develops an HIV infection during pregnancy, the infant has a 50 percent risk of infection resulting from perinatal transmission. - If a health care worker develops HBV during pregnancy, the infant has a 70 to 90 percent risk of infection resulting from perinatal transmission. - The baby may then become a HBV carrier and has a 25 percent chance of developing chronic liver disease.
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Symptoms of Hepatitis B Infected Individuals - Approximately 1/3 have no symptoms. - Approximately 1/3 have flu-like symptoms and are not diagnosed with hepatitis. - The remaining 1/3 will exhibit: jaundice dark urine fatigue anorexia abdominal pain nausea skin rash fever Symptoms of HIV Infected Individuals (Please note that HIV is a virus and AIDS is the disease) - Clinical indicators of HIV infection: fever diarrhea fatigue rash lymphadenopathy - Clinical indicators of AIDS: Pneumocystis pneumonia Kaposi's sarcoma Non-Hodgkin's lymphoma Esophageal candidiasis CD4+ level of under 200
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HEPATITIS C VIRUS (HCV) Hepatitis C Virus (HCV) Formerly called "parenterally transmitted non-A, non-B hepatitis", this type of viral hepatitis accounts for 20 to 40% of acute viral hepatitis cases in the United States. It mode of transmission is similar to Hepatitis B (HBV). Groups which are at increased risk of acquiring this disease are health-care workers with frequent contact with blood, persons with close contact with others who have had hepatitis in the past, household contacts with infected persons, transfusion recipients, parenteral drug users, and dialysis patients. An average of 50% of patients with acute HCV develop chronic hepatitis. Protection Protective measures should be instituted to prevent infection with HCV. These measures are the same as recommended for protection from HBV infection. Observing Universal Precautions, utilizing gloves and other appropriate PPE, washing of hands, disinfecting of work surfaces, and following other procedures in the work place are all important factors in preventing infection with HCV. Post-Exposure Procedures In the event of parenteral injury such as a needle-stick or contaminated sharp puncture, the same procedure will be followed as for other injuries of this type. The CDC recommends testing of the employee's blood for HCV and the administration of Immune Globulin as soon as possible after exposure. No specific treatment is available. HEPATITIS D (HDV) Hepatitis D Virus (HDV) Infection with this virus (HDV) is most commonly seen as a co-infection with HBV or as a super-infection in patients with chronic HBV hepatitis. Replication of the HDV depends on the HBV. The co-infection causes an acute hepatitis with low risk of chronic hepatitis following the acute stage. Acute HDV can be prevented by HVB immunization. A super-infection usually develops in patients with chronic HBV and has a high risk of chronic liver disease. There is no prevention or treatment other than reduction in risk factor reduction to prevent transmission. Transmission of HDV is most commonly by the percutaneous route. Sexual transmission is less common than with HBV, while perinatal transmission is rare.
RECORD KEEPING AND DOCUMENTATION
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A. MEDICAL RECORDS [29 CFR 1910.1030(h)(1) The employer will establish and maintain an accurate medical record for each employee to include: - The name and Social Security Number of each employee; [29 CFR 1910.1030(h)(1)(ii)(A)] - A copy of each employee's hepatitis B vaccination record or refusal-to-receive HBV vaccination; [29 CFR 1910.1030(h)(1)(ii)(B)] - All records relative to the employee's ability to receive the vaccination; [29 CFR 1910.1030(h)(1)(ii)(B)] - All records detailing the circumstances of an Exposure Incident; [29 CFR 1910.1030(h)(1)(ii)(C)] - A copy of all results of physical examination, medical testing, and follow-up procedures as they relate to the employee's ability to receive the vaccination or post-exposure evaluation following an Exposure Incident. [29 CFR 1910.1030(h)(1)(ii)(C)] - The employer's copy of the physician's written opinion; [29 CFR 1910.1030(h)(1)(ii)(D)] and - A copy of the information provided to the physician. [29 CFR 1910.1030(h)(1)(ii)(E)] The office shall keep all medical records confidential as required by OSHA. [29 CFR 1910.1030(h)(1)(iii)] These records will be maintained in the UCH Office 1407 Union Avenue, Human Resources Department for at least the duration of employment plus 30 years and be available to the employees or their designated representative (upon presentation of appropriately executed release by the employee). [29 CFR 29 CFR 1910.20] [29 CFR 1910.1030(h)(1)(iv)] B. TRAINING RECORDS [29 CFR 1910.1030(h)(2)(i)] Training records will include the following information: - The dates of the training sessions; [29 CFR 1910.1030(h)(2)(i)(A)] - The contents or summary of the training sessions; [29 CFR 1910.1030(h)(2)(i)(B)] - The names and qualifications of the person(s) conducting the training sessions; [29 CFR 1910.1030(h)(2)(i)(C)] and
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- The names and job titles of all persons attending the training sessions. [29 CFR 1910.1030(h)(2)(i)(D)] The training records will be maintained by the office for at least three (3) years from date of training. [29 CFR 1910.1030(h)(2)(ii)] C. A Log and Summary of Illness and Injury shall NOT be required as the Standard Industry Classification (SIC) for this office (SIC 801) is exempt under 29 CFR 1904.2. In the event of a fatality or hospitalization of more than three employees, OSHA must be notified within 8 hours. 1-800-249-8510 D. A log of Needlestick Injuries Logs need NOT be kept as 29 CFR 1910.1030 (h)(5)(ii) states that only employers required by CFR 1904 to keep injury logs are required to keep a Needlestick Log.
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EMPLOYEE MEDICAL RECORD Name
Date
Birthdate
SS#
Home Phone
Address Zip Employment date Personal physician Illness in past five years
Medications currently taking
Allergies
Has the employee received the HBV vaccination series?
Yes
No
If yes, indicate vaccination series dates and attach written proof if possible. 1
2
3
Has the employee previously been occupationally exposed to blood or other potentially infectious materials? (Include date and circumstances, if known)
What post exposure vaccination and follow-up was completed after the above occupational exposures? (Include dates, explanations and medical records if available.)
Has the employee ever worked with toxic products such as: chemicals, gasses, asbestos, ethylene oxide, chemotherapy, formaldehyde, other
? (Please circle)
MAINTAIN THIS CONFIDENTIAL RECORD FOR 30 YEARS AFTER EMPLOYEE SEPARATION OR TERMINATION. D. RECORD AVAILABILITY [29 CFR 1910.1030(h)(3)(i)
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All records will be made available upon request to the Assistant Secretary and Director of OSHA for examination and copying. [29 CFR 1910.1030(h)(3)(i)] Employee training records will be provided upon request for examination to employees, employee representatives, and the Assistant Secretary of OSHA. [29 CFR 1910.1030(h)(3)(ii)] Employee medical records and training records will be provided upon request for examination and copying to the subject employee, to anyone having written consent of the subject employee, and to the Assistant Secretary of OSHA. [29 CFR 1910.1030(h)(3)(iii)] E. TRANSFER OF RECORDS [29 CFR 1910.1030(h)(4)(i)] The employer/office will comply with the requirements set forth under 29 CFR 1910.20(h) involving the transfer of records. [29 CFR 1910.1030(h)(4)(i)] If the employer/office ceases to do business and there is no successor, the employer/office will notify the Director of OSHA at least three (3) months prior ceasing business and transmit records if required by the Director of OSHA to do so during that three (3) month period. [29 CFR 1910.1030(h)(4)(ii)] F. IN THIS OFFICE THESE RECORDS/DOCUMENTATION ARE LOCATED AT: UCH - Ophthalmology, Cordova Office 8001 Centerview Parkway, Suite 101 Cordova, Tennessee 38018 And Department of Ophthalmology, UTHSC OSHA Coordinator’s Office 930 Madison Avenue, Room 475 Memphis, TN 38163 And maintained by: William R. Morris, MD
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