Environmental Health and SafetyHealth and Sanitation

Exposure Control Plan

Bloodborne Pathogens

    In accordance with the requirements of OSHA 29 CFR 1910.1030 and the Amherst College Environmental Health & Safety Policy, the following guidelines have been established to reduce the risk of exposure to bloodborne pathogens for our faculty, staff and students. Amherst College has developed this plan to properly mitigate the hazards of blood, body fluids, sewage and other similar materials that may pose a risk to the campus community.

    Through engineering controls, work place practices, personal protective equipment, housekeeping, immunizations and training, Amherst College will take the necessary steps to help protect our employees and the campus community from the risk of exposure and/or infection.

    Definitions
    Affected Employee
    Workplace Transmission
    Universal Precautions
    Personal Protective Equipment (PPE)
    Blood and Body Fluid Clean-Up
    Sewage and Sewer Back-up
    Safe Housekeeping
    Laundry
    Needles and Syringes
    General Practices
    Biohazard / Infection Control Kits
    Training
    Recordkeeping Requirements
    Incident Exposure Reporting

    INFORMED CONSENT FOR AMHERST COLLEGE EMPLOYEES

    Definitions:


    Affected Employees:
     Amherst College employees that have been identified as those for whom the risk of exposure is a possibility must not only acquire the appropriate training, but should seek (through their supervisor) immunizations for Hepatitis B (HBV), the virus that causes liver disease.
    The vaccine is available to all Amherst College personnel identified below. The Office of Human Resources strongly encourages (but does not require) employees to obtain the inoculation within ten (10) working days of their initial assignment. However, if the employee does not wish to take advantage of the free immunization provided for by the college they will be required to sign a waiver that indicates that they were made aware of such vaccination but choose not to acquire it.

    If the employee who had previously declined the inoculation opts to take advantage of the program for the free shot(s) at a later date, Amherst College will make it available to the employee at no cost provided they contact the office of Human Resources, first.

      Vaccinations are available;
      1. before exposure
      2. immediately after exposure


      Those employees for whom a risk assessment has been done, include;

      1. Amherst College Campus Police
        • Police Officers
          • First Aid / CPR
          • Crime scene analysis
          • Exposure to animal and human bites
      2. Physical Plant
        • Custodial Staff
        • Environmental Health & Safety
        • First Aid / CPR Certified Employees
        • Glass repair / replacement personnel
        • Plumbers
          • sewage, sink and toilet maintenance


    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 Amherst College personnel can not identify person(s) who may be infected, they shall not take unnecessary chances. It takes 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


    Personal Protective Equipment (PPE)

    Gloves


    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 patient and any necessary first aid that is required. Once the patient has been taken care of, the clean up needs to begin.

    1. In accordance with prudent practice, products like regular household bleach (diluted to ¼ cup per gallon of water) or Lysol I.C. should be used to properly disinfect areas where blood and body fluids may have been released.
    2. If a complete clean-up of the spilled blood and body fluid(s) will be delayed, then the Amherst College Campus Police, ACEMS or other initial response agency should begin the initial decontamination process. Application of a recognized disinfecting solution or spray can be applied until custodial staff can completely mitigate the hazard


    After a blood and body fluid incident, and before the arrival of either the custodial shop or the office of Environmental Health & Safety, it is necessary for the Amherst College Campus Police to start the decontamination process by applying bleach or another disinfectant. This stipulation shall not imply or require that it is their responsibility to completely clean-up the area. Simply, the Amherst College Campus Police are protecting other, unsuspecting persons from exposure by covering the blood and/or body fluids with the needed means of disinfectant.

    Sewage and Sewer Back-up
    The Centers for Disease Control has warned of the hazards associated with the inadequate cleaning of business, homes and other properties as a result of a sewer malfunction that resulted in an overflow or back-up of the sanitary sewer system. In order to properly mitigate the hazard, the CDC has published a document that instructs persons on how to effectively deal with this type of problem and the long term hazards.

    Our first goal is to protect the staff whose responsibility it is to clean up the spill. Sewer back-ups may be house 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, that this is someone else’s sewage and that the potential for blood and body fluid exposure is significant. Boots that can be properly bleached and washed should be utilized only in the room or house 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.
    Therefore, all pervious and semi-pervious materials that have been contaminated will most likely have to be discarded. Shoes, leather, furniture, sheetrock, wood and similar pieces will retain water and 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 bleach. The CDC requires that a 1 : 6 solution of bleach be used for the purpose of decontamination. The one part bleach and six parts water should then be placed in a sprayer so that the solution can be evenly spread throughout the area or room. The process may need to be repeated two or three times.
    · Never use a solution of bleach greater than 1:6, regardless of soiling

    Another recommendation of the CDC is to (while decontamination is in progress) install a temporary de-humidifier. This unit (with a small amount of bleach in its reservoir) should be run for not less than 3 days so as to remove the moisture (bacteria and mold) and any residual bleach from the room or area. The water from the reservoir is contained and can be properly discarded into the sanitary sewer.
    For recommendations and procedures contact the office of Environmental Health and Safety before the clean up process begins.

    Safe Housekeeping:


    Laundry:
    When dealing with or handling bags of laundry that could contain blood
    or body fluids, it is recommended that…

    1. always lift the bag 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…

    1. do not bend, recap, shear or otherwise break a needle used for any purpose
    2. always dispose of any needle into a puncture resistant, leak-proof “Biohazard” labeled container, as soon as possible.
    3. Report any full or damaged containers to your supervisor for repair or replacement


    General Practices


    Biohazard / Infection Control Kits:


    As a minimum the Infection Control and Bodily Fluid Disposal kits shall have;

    It shall be the responsibility of each departmental supervisor to make sure that the kits are inspected and refilled as necessary to insure adequate means of handling a biohazardous incident. EH&S suggests that a plastic tie be attached to the biohazard spill kit container to indicate if it has or has not been opened.

    Training:
    Training shall be provided to all affected or potentially exposed employees of Amherst College 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
      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 Amherst College 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 Human Resources Office at Converse Hall. 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 the Human Resources Office at Converse Hall. These records shall be available to employees, employees’ representatives, the Director of the National Institute for Occupational Safety and Health, the Assistant Secretary of Labor for Occupational Safety and Health, or their designated representatives.

    Incident Exposure Reporting:

    Incident Exposure Report
    An Accident Investigation Report shall be completed within 24 hours of an exposure incident. The employee’s supervisor, the Environmental Health & Safety Office 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 reoccurrence.

    Post-Exposure Evaluation
    Following a report of an exposure incident, Amherst College will make immediately available to the exposed employee a confidential medical evaluation and follow-up. Either the University of Massachusetts Health Services or the employee’s personal 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, I 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. Copy of OSHA standard
    2. Description of exposed employee’s duties as they relate to the exposure incident
    3. Documentation of the route of exposure
    4. Results of source individual’s blood testing; and
    5. 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.