What To Do In Case Of Bloodborne Pathogens
Introduction
On December 6, 1991, the Occupational Safety and Health Administrations (OSHA) issued an order regulating occupational exposure to bloodborne pathogens (29CFFR 1919.1030. OSHA determined that employees face a significant health risk as a result of occupational exposure to blood and other body fluids because these materials ma contain microscopic organisms that can cause disease. These pathogens include Hepatitis B and C viruses (HBV and HCV) which cause serious liver diseases and Human Immunodeficiency Virus (HIV) which cases Acquired Immunodeficiency Syndrome (AIDS). OSHA concluded that this hazard can be minimized or eliminated using a combination of engineering controls, work practice controls, personal protective clothing and equipment, training, medical surveillance, Hepatitis B vaccination, signs, labels, and other provisions.
The California version of the bloodborne pathogen legislation became effective on January 8, 1993. The text of the law can be found in Section 5193 of Title 8 of the California Code of Regulations (8CCR 5193). The following exposure control plan has been developed in accordance with the Cal/OSHA Bloodborne Pathogen Standard.
II. Exposure Determination
Any member of the student body, staff, or faculty of Cabrillo College with occupational exposure to blood or other potentially infectious materials is covered by the Exposure Control Plan. Potentially infectious materials include the following human body fluids: blood, semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid, pericardial fluid, peritoneal fluid, amniotic fluid, saliva in dental procedures, any body fluid that is visibly contaminated with blood, and all body fluids in situations where it is difficult or impossible to differentiate between body fluids.
Occupational exposure is defined by Cal/OSHA as "reasonable anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that my result from the performance of an employee's duties." parenteral means piercing mucous membranes or the skin barrier through such events as needlesticks, human bites, cuts and abrasions. Further, to be considered "occupational exposure," under the standard, the contact must result from the performance of an employee's duties.
The Cal/OHSA Bloodborne Pathogens Rule does not cover Students, since an employer – employee relationship must exist between the parties. However, it is the mission of Cabrillo College to provide students with adequate training so they may pursue their studies and eventually their career safety and knowledgeably. Therefore, the College has identified those curricula which involve reasonably anticipated exposure of students to blood or other potentially infectious materials. The use of blood must be evaluated in light of its risk to student and the fulfillment of each departments academic mission. When possible, alternatives to the use of blood and other potentially infectious materials must be adopted. Alternatives include the use of non-infectious animal blood, synthetic blood or computer simulations.
III. Hepatitis B – Vaccination Program
Hepatitis B is a type of viral hepatitis acquired from exposure to human blood and body fluids that results in liver inflammation. While the use of universal precautions helps in the protection from Hepatitis B, the Hepatitis B vaccine is an additional measure offered to all employees in Category I and Category II free of charge through the college.
- As part of the initial orientation process through the Personnel Dept., education and training will be provided regarding the Hepatitis B vaccine. This can occur by way of handouts, videos, and/or presentation. All associated training records must be maintained for a minimum of 3 years from the date on which the training occurred.
Once an employee is sent to his/her designated department, a more structured and formalized training occurs. At this time, the employee will give a copy of their signed acknowledgment form to their supervisor, who in turn is responsible for the appropriate record keeping. At a minimum, this training will include efficacy, safety, method of administration, benefits of being vaccinated, and the fact that the vaccine is available at convenient times in-house at no charge to any employee where occupational exposure may take place.
This training will be provided during working hours at no cost to the employee by a health care or safety professional knowledgeable in the subject matter as it relates to the workplace. - Following the required training, all employees in Category I and Category II will be offered the Hepatitis B vaccine, free of charge, within 10 working days of initial assignment unless the employee has previously received the complete Hepatitis B vaccination series and antibody testing has revealed that the employee is immune or if the vaccine is contraindicated for medical reasons (e.g. allergic to yeasts). Refer to Appendix C – Employees Eligible for Hepatitis B Vaccination Form.
- All employees offered the Hepatitis B vaccine would complete the Consent Form. Once completed, the Consent Form shall be placed in the employee's permanent record. It is recommended that a copy of the form be kept in the departmental records as well as in the Personnel Office. Refer to Appendix D – Initial Hepatitis B Consent Form.
- For those desiring the Hepatitis B vaccine, an Employee Immunization Record will be maintained until each of the 3 steps of the vaccination process is complete. (Initial, 30 days from initial and 6 months from initial.) Refer to Appendix E – Immunization Record.
- Once the series is complete, the Immunization Record will become part of the employee's permanent record.
- Vaccines will not be provided for employees that are no longer employed by the College. Employees may choose not to complete the series of 3 inoculations. If an employee leaves the College's employment, they will not receive initial or subsequent inoculations. If the series is not completed, the reason and the employee's signature must be written on the Immunization Record.
- An employee may initially decline the Hepatitis B vaccine, but at a later date may decide they want the vaccination. If this occurs, the employee must complete a new Consent form and steps 3-6 of this procedure must be followed. Refer to Appendix F – Vaccination Declination Form.
- If a routine booster dose(s) of Hepatitis B vaccine is recommended by the U.S. Public Health Service at a future date, the booster dose(s) will be made available, free of charge to the employee.
- The Hepatitis B vaccine must be performed by or under the supervision of a licensed physician, or under the supervision of another licensed healthcare professional.
IV. Methods of Compliance
To protect employees against exposure to human bloodborne pathogenic diseases the following exposure control steps will be undertaken. First, "Universal Precautions" will be observed to prevent contact with blood or other potentially infectious materials. Second, engineering and work practice controls will be followed to prevent contact with potentially infectious materials. Third, specimens and equipment will be handled under strict guidelines. Finally, a hazard communication procedure will be followed to alert all employees to the possibility that pathogenic materials are present.
VI. Recordkeeping
Cabrillo College will establish and maintain an accurate record for each employee with occupational exposure, to include:
- The name and social security number of the employee.
- A copy of the employee's Hepatitis B vaccination status, including the dates of all the Hepatitis B vaccinations and any medical records relative to the employee's ability to receive the vaccination.
- A copy of all results of examinations, medical testing, and follow-up procedures.
- The College's copy of the healthcare professional's written opinion.
- A copy of all information provided to the healthcare professional.
Cabrillo College will ensure that the employee's medical records are kept confidential and are not disclosed or reported without the employee's express written consent to any person within or outside the workplace except as required by law.
Cabrillo College will maintain the records for employees with occupational exposure for at least the duration of employment PLUS an additional 30 years.
Employee medical records shall be provided upon request for examination and copying to the subject employee, to anyone having written consent of the subject employee or others as required by law.
VII. Implementation of Exposure Control Plan Standards
No later than March 1, 2000, a copy of Cabrillo College's Bloodborne Pathogen Program will be available/accessible to all employees. Individual copies will be made available to the following individuals:/departments.
- College President;
- Vice President, Instruction;
- Vice President, Business Services;
- Vice President, Student Services;
- Director, Nursing Education;
- Director, Medical Assisting Program;
- Director, Dental Hygiene;
- Director, Health Services;
- Director, Physical Education;
- Director, Personnel and Human Resources;
- Manager, Maintenance and Operations [M&O].
- Director, Radiologic Technology