Sample Bloodborne Pathogens Exposure Control Pathogens... This sample plan for bloodborne pathogens...

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Transcript of Sample Bloodborne Pathogens Exposure Control Pathogens... This sample plan for bloodborne pathogens...

  • Bloodborne Pathogens Exposure Control Plan - © Blue Gavel Press 1

    Sample Bloodborne Pathogens Exposure Control Plan

    OSHA requires all employers that can “reasonably anticipate exposure” of employees to infectious materials to prepare and implement a written Exposure Control Plan. The following sample Bloodborne Pathogens Exposure Control Plan was adapted from Appendix D of OSHA’s Bloodborne Pathogens Directive, which was published in 2001. The purpose of the model plan is to provide small employers with an easy-to-use format for developing a written exposure control plan. Each employer must modify the plan to meet the unique needs and circumstances of its workplace.

    This sample plan includes provisions for: • job classifications and exposure determinations • program administration • compliance methods • engineering and work practice controls • personal protective equipment • cleaning of contaminated areas • employee hygiene and housekeeping • hepatitis B vaccination and post-exposure follow-up • a sample form for an employee to decline a hepatitis B vaccine • communication of hazards to employees • training • recordkeeping • sharps injury log This sample plan does not include provisions for HIV/HBV laboratories and research facilities. Those facilities must comply with special provisions found at 29 CFR 1910.1030(e).

    Employers Covered All employers whose employees can “reasonably anticipate” contact with blood and other infectious materials while performing their job duties are covered. OSHA has not issued an exhaustive list of specific occupations in which exposures are likely to occur. However, in OSHA’s recent directive, it did identify several types of workers who are likely to have the potential for occupational exposure, including the following: • doctors, nurses, physicians’ assistants, and other employees in clinics, physicians’ offices,

    hospitals, and other health care settings

  • 2 Bloodborne Pathogens Exposure Control Plan - © Blue Gavel Press

    • dentists, dental technicians, and dental hygienists • employees of clinics, tissue banks, blood banks, and diagnostic labs • housekeepers in health care and other facilities • personnel in hospital laundries or commercial laundries that service laundry from health

    care or public safety personnel • employees designated to provide emergency first aid • home health care, nursing home, and hospice employees • staff of institutions for the developmentally disabled • funeral home and mortuary employees • employees at HBV and HIV research facilities • employees of substance abuse clinics • custodial workers who clean up contaminated sharps or spills of blood or other bodily

    fluids • employees who handle regulated waste • paramedics and other medical emergency personnel • police officers, firefighters, and personnel of correctional institutions • maintenance workers in health care facilities • medical equipment service and repair personnel The above types of employees are not automatically covered by the Bloodborne Patho- gens Standard unless they have the potential for occupational exposure. In addition, employees other than those listed above are covered by the standard if they have the potential for occupational exposure.

    Legal Source This sample plan for bloodborne pathogens exposure control follows the OSHA require- ment located at 29 CFR 1910.1030. The plan was adapted from Appendix A to OSHA’s Bloodborne Pathogens Directive, which was published in 2001, with additions based on various OSHA letters of interpretation and guidance documents that have been issues since that time. In 2001, OSHA revised its own bloodborne pathogens regulations to implement the Needlestick Safety and Prevention Act. These revised regulations require affected employers to do all of the following: • consider safer medical devices such as sharps with engineered protections and needle-

    less systems for use as “engineering controls” • solicit and document input regarding engineering and work practice controls from

    nonmanagerial employees who: - are responsible for direct patient care, and - may be injured from contaminated sharps.

  • Bloodborne Pathogens Exposure Control Plan - © Blue Gavel Press 3

    • review the annual plan to update and document technological changes that eliminate or reduce bloodborne pathogens exposure

    • keep a sharps injury log for percutaneous injuries from exposure incidents with con- taminated sharps, including:

    - the type and brand of device, - the department and area involved, and - an explanation of how the incident occurred. However, employers that are exempt from OSHA’s general recordkeeping requirements also are excluded from keeping a sharps injury log. This includes small employers (those with 10 or fewer employees), as well as employers in designated SIC codes (such as drug stores and doctor’s offices and clinics).

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    BLOODBORNE PATHOGENS EXPOSURE CONTROL PLAN

    company name street address city state ZIP code Prepared by: print name of preparer title phone number signature date

  • Bloodborne Pathogens Exposure Control Plan - © Blue Gavel Press 5

    POLICY The facility name

    is committed to providing a safe and healthful work environment for our entire staff. In pursuit of this endeavor, the following Bloodborne Pathogens Exposure Control Plan (ECP) is provided to eliminate or minimize occupational exposure to bloodborne pathogens in accordance with OSHA standard 29 CFR 1910.1030, “Occupational Exposure to Bloodborne Pathogens.” The ECP is a key document to assist our company in implementing and ensuring compliance with the standard, thereby protecting our employees. This ECP includes: • determination of employee exposure • implementation of various methods of exposure control, including:

    - universal precautions - engineering and work practice controls - personal protective equipment - housekeeping • hepatitis B vaccination • post-exposure evaluation and follow-up • communication of hazards to employees and training • recordkeeping • procedures for evaluating circumstances surrounding an exposure incident The methods of implementation of these elements of the standard are discussed in the subsequent pages of this ECP.

    PROGRAM ADMINISTRATION is (are) responsible for name of responsible person(s) or department

    implementation of the ECP.

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    will maintain, review, name of responsible person or department

    and update the ECP at least annually, and whenever necessary to include new or modified tasks and procedures. contact location phone number Those employees who are determined to have occupational exposure to blood or other potentially infectious materials (OPIM) must comply with the procedures and work practices outlined in this ECP.

    will maintain and provide name of responsible person or department

    all necessary personal protective equipment (PPE), engineering controls (e.g., sharps con- tainers), labels, and red bags as required by the Standard.

    will ensure that adequate name of responsible person or department

    supplies of the aforementioned equipment are available in the appropriate sizes. contact location phone number

    will be responsible for ensuring name of responsible person or department

    that all medical actions required are performed and that appropriate employee health and OSHA records are maintained. contact location phone number

    will be responsible for training, name of responsible person or department

    documentation of training, and making the written ECP available to employees, OSHA, and NIOSH representatives. contact location phone number

  • Bloodborne Pathogens Exposure Control Plan - © Blue Gavel Press 7

    EMPLOYEE EXPOSURE DETERMINATION

    All employees who have occupational exposure to bloodborne pathogens are covered by this ECP, including part-time, temporary, contract, and per diem employees. For some job titles, all employees who perform that job are at risk of occupational exposure. For others, only some employees who perform that job are at risk. All job titles and, where necessary, job tasks and procedures that involve a risk of exposure are identified in this section. The following is a list of all job classifications at our establishment in which all employees have occupational exposure: Job Title Department / Location

    Example: Phlebotomist Clinical Lab

    The following is a list of job classifications in which some employees at our establishment have occupational exposure. Included is a list of tasks and procedures, or groups of closely related tasks and procedures, in which occupational exposure may occur for these individuals:

    Job Title Department / Location Task / Procedure

    Examples: Housekeeper Environmental Services Handling Regulated Waste

  • 8 Bloodborne Pathogens Exposure Control Plan - © Blue Gavel Press

    METHODS OF IM