Exposure Control Plan

April 2023

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.



  • Bloodborne Pathogens – microorganisms that are present in human blood that can cause disease
  • Hepatitis B Virus (HBV) – bloodborne pathogen that causes inflammation of the liver
  • Human Immunodeficiency Virus (HIV) – bloodborne pathogen that attacks the body’s immune system, causing the disease known as AIDS.image
  • Personal Protective Equipment – Equipment that is required to protect personnel from coming in contact with blood and body fluids. It may include but is not limited too;
    • Aprons, gowns and lab coats
    • face shields and/or goggles
    • gloves
    • masks for protection and resuscitation
  • Potentially Infectious Human Body Fluids – fluids in which bloodborne pathogens may be present.
    • blood
    • semen
    • vaginal secretions
    • cerebral spinal fluid
    • any other body fluid contaminated with blood
  • Potentially Infectious Materials tissue and organs (other than intact skin) from dead or living humans, cell or tissue cultures that contain HIV or HBV and any contaminated sharp object that can penetrate the skin
  • Sharps Container(s) – Red, labeled leak-proof, puncture resistant closeable containers used to discard (contaminated, presumed contaminated or non-contaminated) sharps.
  • Universal Precautions guidelines that require faculty and staff to treat all blood, body fluids, sewage and similar materials as infected with HBV, HIV or other bloodborne diseases.

Affected Employees:

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.image
  1. before exposure
  2. immediately after exposure

Amherst College Campus Police

  • Police Officers
  • First Aid / CPR
  • Crime scene analysis
  • Exposure to animal and human bites


  • Custodial Staff
  • Environmental Health & Safety
  • First Aid / CPR Certified Employees
  • Glass repair / replacement personnel
  • Plumbers
    • sewage, sink and toilet maintenance
  •  Vaccinations are available;
    • Those employees for whom a risk assessment has been done, include;

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;

  • Accidentally cutting yourself with a sharp object or glass that is contaminated with infected blood and body fluids
  • Getting infected blood or body fluids on your skin, especially if your skin has open sores, nicks, acne, dermatitis, broken cuticles and/or cuts
  • Getting infected blood or body fluids in the mucous membranes of your eyes, nose and mouth
  • Sharing or otherwise coming in contact with infected needles
  • 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

  • if not trained in first aid / CPR - call the Amherst College Campus Police at 2111
  • if trained, provide care and/or call the Amherst College Campus Police at 2111
    1. assess the scene
      • is it safe to enter ?
      • if no personal protective equipment available (gloves, face shields masks), then…
      • give the patient the first aid supplies so that they may treat (if possible) their own wound
      • if personal protective equipment is available, then…
    2. provide care utilizeimage
      • gloves (non latex if possible)
      • face mask or shields
      • resuscitation mask or shield
      • HEPA or TB Mask(s)
    3. clean-up 
      Body (if applicable) and handwashing is required regardless of whether or not gloves and other personal protective equipment was utilized.
      • wash affected areas for a minimum of 30 seconds, use…
        • antibacterial / antiseptic soap and water, or
        • disposable antibacterial / antiseptic waterless cleaner if no soap and water

Personal Protective Equipment (PPE)

  • Eye and face shields, gloves, masks and other similar items must be located within all department, shop and vehicle first aid and biohazard kits.
  • PPE may also include (when applicable) aprons, gowns, laboratory coats and mouthpieces
  • Gloves should be durable and doubled up when necessary to prevent exposures through rips and tears. In addition, it is recommended that the gloves be non-latex for staff who might be latex sensitive.
  • The appropriate type of Personal Protective Equipment depends on the type of work and degree of exposure anticipated. Its purpose is to protect the workers and their clothes from possible exposure and the spread of contamination.
    • blood soaked clothing should not be brought home for laundering.
      • contaminated clothing should be disposed of or laundered by an outside firm
      • disposable clothing should be discarded into a red biohazard bag for proper disposal purposes.


  • are required to be durable and double layered (if necessary).
  • they should fit properly and should not be so tight as to become easily ripped.
  • if damaged, ripped or torn, discard the eye and face protection, gloves and replace them with an appropriate PPE that is free from deficiency
    • Contaminated gloves must not come in contact with equipment, items or surfaces that were not contaminated or infected. Often gloves used to treat a patient remain in use until the patient has been relocated out of the building. Hence, door handles, refrigerators and lights that were previously not a problem have become so. Gloves are inexpensive. Personnel should not feel as though the gloves should be reused. Dispose of them whenever blood and body fluid is a potential or known concern.
    • Gloves should be removed one at a time.
      1. as you remove your hand from the glove, turn it inside out.
      2. take the other hand out of the 2nd glove, turning it inside out and place them into the 1st glove for disposal.

Blood and Body Fluid Clean-Up:

As soon as a blood and body fluid spill has occurred, the first issue is to deal with the 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.image

Safe Housekeeping:

  • Gloves are required. 
    • Amherst College recommends at least two pairs
  • Use an apron, coveralls or gown when necessary 
    • these items can be obtained from the office of Environmental Health & Safety
  • Restrict access to the area 
    • Amherst College Police Officers should protect a hazardous area until…
    • A trained custodial staff member arrives
    • Environmental Health and Safety arrives, or
    • They have applied the necessary disinfectant to prevent any potential exposure
  • Do not pick up broken pieces of glass or sharps with gloved or bare hands. 
    • use tongs, shovels, scoops or brush and dust pan
  • Needles and syringes (if discovered) should be reported to the Amherst College Campus Police. 
    • do not pick up the needles or attempt to re-cap
    • the needles and syringes will be removed by the Amherst College Campus Police or Environmental Health & Safety.
  • Use disposable towels and rags to soak up most of the blood and body fluids
  • Place all contaminated material into a red “labeled” biohazard bag for proper relocation and disposal. Do not overfill the containers
  • Clean all work areas at the end of each shift. Use the appropriate disinfecting solution. Bleach is recommended. 
    • after the cleaning has been performed…
      • disinfect mops and any other used cleaning equipment


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

  • Do not eat, drink, apply cosmetics or lip balms or handle contact lenses where personnel may be exposed to blood and body fluids
  • Avoid all petroleum-based lubricants that may dissolve or breakdown the latex gloves
  • Always wash your hands thoroughly (at least 30 seconds) before applying hand cream
  • Do not keep food and drinks in refrigerators, freezers or cabinets, or on shelves, countertops or benchtops where blood or other potentially hazardous material may be kept
  • Avoid splashing, splattering or spraying of blood
    • when necessary use the aprons, eye and face protection, gowns and other PPE
  • Never mouth-pipette or suction blood or other potentially hazardous materials
  • All containers used for the disposal of biohazardous materials must be red in color and shall be labeled “Biohazard” as is required.

Biohazard / Infection Control Kits:

  • Biohazard and Infection Control kits, in addition to First Aid Kits should be located in each Amherst College Police Car, the Amherst College EMS Response Vehicle, the applicable Biology Department Laboratories, Dining Services and the Physical Education Department.
  • Bodily Fluid Disposal Kit(s) should be located in at least (1) main custodial closet in each building that is staffed by Amherst College Personnel

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

  • Disinfectant cleaner
  • Gloves (adequate in size and number)
  • Handwash (waterless antibacterial / antiseptic)
  • Red “Biohazard” labeled bags
  • Paper or other type towels
  • Labels
  • Masks

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 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.

  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 79 South Pleasant St. 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 AEIOU Urgent Care 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, if feasible; and
  5. Result of medical records relevant to appropriate treatment of employee, including vaccination status.

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.\

Exposure Control Plan Evaluation