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, anybody 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 needle sticks, 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.

B. Exposure Categories

OSHA has established three (3) exposure categories for protection against occupational exposure to infectious diseases including HBV, HCV and HIV infections. These categories are as follows:

Category I: Tasks that involve exposure to human blood, body fluids, or tissues:

• · All procedures or other job-related tasks that involve an inherent potential for mucous membrane or skin contact with human blood, body fluids, or tissues, OR a potential for spills or splashes of them are Category I tasks. Use of appropriate personal protective equipment will be required for every employee engaged in Category I tasks.

Category II: Tasks that involve no exposure to human blood, body fluids, or tissues but employment may require performing unplanned Category I tasks.

• The normal work routine involves no exposure to blood, body fluids, or tissues, BUT exposure or potential exposure may be required as a condition of employment. Appropriate personal protective equipment will be readily available to every employee engaged in Category II tasks.

• Employees may be considered "designated first-aid providers." Designated first-aid providers may run a risk of occupational exposure, however, this risk arises in the context of the performance of a "collateral" duty, and is not performed on a regular basis.

Category III: Tasks that involve no exposure to human blood, body fluids or tissues, AND Category I tasks are not a condition of employment.

• The normal work routine involves no exposure to human blood, body fluids or tissues (although situations may be imagined or hypothesized under which anyone, anywhere, might encounter potential exposure to body fluids). 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 some other way.

• With regards to "Good Samaritans", the Cal/OSHA regulations do not cover the exposure of an employee to blood or infectious material where that exposure was not related to the performance of job duties, or collateral job duties.

In identifying the job classification, Cabrillo College must specify the job tasks and procedures in which occupational exposure is reasonably anticipated to occur. These job classifications and related job tasks and procedures are identified in Appendix A – Job Classifications in Which Employees Have Occupational Exposure to Bloodborne Pathogens." The "Exposure Determination Worksheet" also provided in Appendix A, or an equivalent form shall be used in initially determining positions subject to exposure.

The following Employee Job Descriptions have been categorized according to the exposure Categories:

Children Center and Early Childhood Education

• Children Center Teachers – Category I

• Child Care Specialists and Temporary/Hourly Employees – Category II

• Early Childhood Education Instructors – Category II

• Director of Children's Center – Category II

HASS

• Culinary Arts & Hospitality Management Instructor – Category II

• Instructional Assistant I/II (Culinary Arts) – Category II

HAWK

• Adaptive PE Instructors – Category II

• Allied Health Instructors – Category I

• Athletic Equipment Specialists I/II – Category II

• Athletic Trainer – Category II

• Dental Hygiene Instructors – Category I

• Health Science Instructors – Category I

• LIA's in Nursing Education – Category I

• Lifeguards – Category I

• Medical Assisting Instructors – Category I

• Nursing Education Instructors – Category I

• PE Instructors – Category II

• Pool Maintenance Worker – Category II

• Radiology Technology Instructors – Category I

• Therapeutic Learning Disabled Aides – Category II

NAS Division

• Science Laboratory Technicians (Biology) – Category II

• Science Laboratory Technicians (Chemistry) – Category II

• Biology, Physiology, Anatomy and Chemistry Instructors – Category II

Facilities Planning & Plant Operations (FP&PO)

• Custodial Supervisor – Category I

• Custodian I/II – Category I

• Lead Custodian – Category I

• FP&PO Director – Category II

• FP&PO Assistant Director – Category II

• Maintenance Technicians – Category I

• Maintenance Worker – Category I

• Pool Maintenance Worker – Category I

• Senior Maintenance Worker – Category I

• Utility Maintenance Worker – Category I

Stroke Center

• Instructional Assistant I/II – Category II

• Stroke Center Instructors – Category II

• Stroke Center Program Specialists I/II – Category II

• Temporary Instructors – Category II

Student Health Center

• Adaptive PE Instructors – Category II

• Clinical Nurses – Category I

• Director – Category I

• Nurse Practitioners – Category I

• Program Specialists I/II – Category II

Note: It is during the initial orientation process, that the individual is placed into one of the three exposure categories and the appropriate acknowledgment form found in Appendix A is filled out.

In addition, the exposure determination worksheet completed by the personnel dept. is found in Appendix B.

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.

Universal Precautions is an approach to infection control which assumes that all human blood and certain body fluids are treated as if known to be infectious for HIV, HBV, HCV and other bloodborne pathogens. Universal Precautions shall be consistently used for all individuals.

In the school setting, precautions shall include: handwashing, using gloves and other appropriate protective equipment, careful trash disposal, and using disinfectants. Universal precautions shall be used within the school setting at all times to prevent contact with blood or other potentially infectious materials.

All procedures involving blood or other body fluids shall be performed in such a manner as to minimize splashing, spraying, splattering, and generation of droplets of these substances.

Engineering controls refers to controls which isolate or remove the bloodborne pathogens from the workplace [i.e., sharps disposal containers]. Work practice controls that reduce the likelihood of exposure by altering the manner in which a task is performed.

Engineering and work practice controls will be used to eliminate or minimize employee exposure. Where occupational exposure remains after institution of these controls, personal protective equipment will also be used. Engineering controls shall be examined and maintained or replaced on a regular schedule to ensure their effectiveness. Work practice controls shall be evaluated and updated on a regular schedule to ensure their effectiveness.

Thorough handwashing is the single most effective means in preventing the spread of infectious diseases and should be practiced routinely by all school personnel and taught to students as routine hygienic practices.

Employers shall provide handwashing facilities, which are readily accessible to employees.

i) Employers shall ensure that employees wash their hands immediately or as soon as feasible after removal of disposable gloves or other personal protective equipment;

ii) Employers shall ensure that employees wash hands and other skin with soap and water, or flush mucous membranes with water immediately or as soon as feasible following contact of such body areas with blood or OPIM.

iii) When provision of handwashing facilities is not feasible, the employer shall provide either an appropriate antiseptic hand cleanser in conjunction with clean cloth/paper towels or antiseptic towelettes. When antiseptic hand cleansers or towelettes are used, hands shall be washed with soap and potable water as soon as feasible;

Work Area Restrictions:

• Eating, drinking, smoking, applying cosmetics or lip balm, and handling contact lenses are prohibited in work areas where there is a reasonable likelihood of occupational exposure.

• Food and drinks will not be kept in refrigerators, freezers, shelves, cabinets, counter tops, or bench tops where blood or other potentially infectious materials are present.

• Mouth pipetting or suctioning of blood or other potentially infectious materials is prohibited.

C. Cleaning and Decontamination

Exact procedures will depend upon Departmental activities and needs. In general, the following principles established by OSHA should be followed:

1. General Requirements.

a) Employers shall ensure that the worksite is maintained in a clean and sanitary condition.

b) Employers shall determine and implement appropriate written methods and schedules for cleaning and decontamination of the worksite.

c) The method of cleaning or decontamination used shall be effective and shall be appropriate for the:

• i) Location within the facility;

• ii) Type of surface or equipment to be treated;

• iii) Type of soil or contamination present; and

• iv) Tasks or procedures being performed in the area.

d) All equipment and environmental work surfaces shall be cleaned and decontaminated after contact with blood or OPIM [Other Potentially Infectious Materials] no later than at the end of the shift. Cleaning and decontamination of equipment and work surfaces is required more often as specified below.

2. Specific Requirements.

a) Contaminated Work Surfaces. Contaminated work surfaces shall be cleaned and decontaminated with an appropriate disinfectant immediately or as soon as feasible when:

• i) Surfaces become overly contaminated;

• ii) There is a spill of blood or OPIM;

• iii) Procedures are completed; and

• iv) At the end of the work shift, if the surface may have become contaminated since the last cleaning.

b) Receptacles. All bins, pails, cans, waste baskets and similar receptacles intended for reuse which have a reasonable likelihood for becoming contaminated with blood or OPIM shall be inspected and decontaminated as necessary and cleaned and decontaminated immediately or as soon as feasible upon visible contamination.

b) Protective Coverings. Protective coverings, such as plastic wrap, aluminum foil, or imperiously 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 the workshift if they may have become contaminated during the shift.

Cabrillo College, through its employing departments, will ensure that worksites involving bloodborne pathogenic materials are maintained in a clean and sanitary condition. For example, the Health Services, Nursing, Dental Hygiene and Medical Assisting Departments and all laboratories utilizing blood and other potentially infectious materials, shall prepare written schedules (e.g. infection control plans). These plans refer to the cleaning and method of decontamination based upon the location in the facility, type of surface to be cleaned, and tasks or procedures being performed in the area. The schedule shall be followed and it shall be made accessible to employees.

Contaminated work surfaces will be decontaminated with an appropriate disinfectant after completion of a procedure, immediately, or as soon as feasible when surfaces are overtly contaminated, or after any spill of blood or other potentially infectious materials; and at the end of the work shift if the surface has become contaminated since the last cleaning.

Broken glassware which may be contaminated shall not be picked up directly with the hands. It shall be cleaned up by mechanical means, such as brush and dustpan, tongs or forceps and be disposed of in an appropriate sharps container.

Laundry contaminated with blood or other potentially infectious materials [including, athletic uniforms and towels] should be handled as little as possible with a minimum of agitation. Contaminated laundry will be bagged or containerized at the location where it was used and shall not be sorted or rinsed in the location of use. The contaminated laundry will then be placed and transported in bags or containers labeled as " BIOHAZARD" or color-coded (red).

When Universal Precautions are utilized in the handling of all soiled laundry, alternative labeling or color-coding is sufficient, if it permits all employees to recognize the containers as requiring compliance with Universal Precautions. Whenever contaminated laundry is wet and presents a reasonable likelihood of soak- through of or leakage from the bag or container, the laundry shall be placed and transported in bags or containers which prevent soak-through and/or leakage of fluids to the exterior.

Cabrillo College will ensure that employees who have contact with contaminated laundry wear protective gloves and other appropriate personal protective equipment.

If the College ships contaminated laundry off-site to a second facility which does not utilize Universal Precautions in the handling of all laundry, the facility generating the contaminated laundry must place such laundry in bags or containers which are labeled biohazardous or color-coded (red).

Shearing or breaking of contaminated needles and other contaminated sharps is prohibited. Contaminated sharps shall not be bent, recapped, or removed from devices. EXCEPTION: Contaminated sharps may be bent, recapped or removed from devices if: The employer can demonstrated that no alternative is feasible or that such action is required by a specific medical or dental procedure; and the procedure is performed using a mechanical device or a one handed technique.

Immediately or as soon as possible after use, contaminated reusable sharps will be placed in appropriate containers until properly reprocessed. These containers must be puncture resistant, labeled biohazard or color-coded, leakproof on the sides and bottom and shall not be stored or processed in a manner that requires employees to reach by hand into the container where the sharps have been placed.

Disposable contaminated sharps will be discarded immediately or as soon as feasible in containers that are closable, puncture resistant, leakproof on the sides and bottom and labeled "BIOHAZARD" or color-coded. During use, containers for contaminated sharps will be easily accessible to personnel and located as close as feasible to the immediate areas where sharps are used or can be reasonably anticipated to be found; maintained upright throughout use and replaced routinely.

When moving containers of contaminated sharps from the area of use, the container must be closed immediately prior to removal or replacement to prevent spillage or protrusion of contents during handling, storage, transport, or shipping. If leakage is possible, a secondary container must be used. The second container must be closable, constructed to contain all contents and prevent leakage during handling, storage, transport or shipping and be labeled "BIOHAZARD", Reusable containers shall not be opened, emptied or cleaned manually, or in any other manner that would expose employees to the risk of percutaneous injury.

Note: When a sharps container is filled, the department has seven [7] days in which to dispose of the contents. If not disposed of in the allotted time frame, a violation of the Medical Waste Management Act has occurred.

To prevent needle stick injuries, contaminated needles or other sharps must not purposely be bent, sheared, broken, recapped, removed from disposable syringes, or otherwise manipulated by hand. They shall only be disposed of in sharps containers.

All health care workers and emergency response personnel shall take precautions to prevent injuries caused by needles, scalpels, and other sharp instruments during procedures; when cleaning used instruments or during disposal of used needles; and when handling sharp instruments after procedures. After use, disposable syringes and needles, scalpel blades, and other sharp items shall be placed in puncture-resistant sharps containers for disposal. The puncture-resistant container should be located as close as practical to the use area and identified as biohazardous.

The employer shall establish and maintain a sharps injury log, which is a record of each exposure incident involving a sharp. The information recorded shall include the following information, if known or reasonably available.

1. Date and time of the exposure incident;

2. Type and brand of sharp involved in the exposure incident;

3. A description of the exposure incident, which shall include:

• Job classification of the exposed employee;

• Department or work area where the exposure incident occurred;

• The procedure that the exposed employee was performing at the time of incident;

• How the incident occurred;

• If the sharp had engineered injury protection, whether the protective mechanism was activated, and whether the injury occurred before the protective mechanism was activated, during activation of the mechanism or after activation of the mechanism, if applicable;

• If the sharp had no engineered sharps injury protection, the injured employee's opinion as to whether and how such a mechanism could have prevented the injury; and

• The employee's opinion about whether any engineering, administrative or work practice control could have prevented the injury.

Each exposure incident shall be recorded in the Sharps Injury Log within 14 working days of the date the incident is reported to the employer. The information in the Sharps Injury Log shall be recorded and maintained in such a manner as to protect the confidentiality of the injured employee

Refer to Appendix K – Sharps Injury Log.

H. Personal Protective Equipment

Personal protective equipment (PPE) is specialized clothing worn by an employee for protection against a hazard. General work clothes, not intended to function as protection against a hazard, are not considered to be personal protective equipment.

When there is a potential for occupational exposure, the employing department of Cabrillo College will provide, at no cost to the employee, the following appropriate personal protective equipment. It shall include, but not be limited to, disposable gloves, gowns, laboratory coats, face shields or masks, eye protection, mouthpieces, resuscitation bags, pocket masks and/or other ventilation devices.

Personal protective equipment is considered appropriate only if it does not permit blood or other potentially infectious materials to pass through or reach the employee's work clothes, street clothes, undergarments, skin, eyes, mouth, or other mucous membranes under normal conditions of use and for the duration of time which the protective equipment will be used.

It is the employing department's responsibility to ensure that employees use appropriate personal protective equipment. The employing department will ensure the appropriate personal protective equipment is available in the appropriate sizes and is readily accessible at the worksite. Hypoallergenic gloves, glove liners, powderless gloves, or other similar alternatives will be readily accessible to those employees who are allergic to the gloves normally provided.

The employing department will clean, launder or dispose of personal protective equipment and will repair or replace personal protective equipment as needed to maintain its effectiveness, at no cost to the employee. If blood or other potentially infectious materials penetrate a garment, the garment(s) will be removed immediately or as soon as feasible. All personal protective equipment will be removed prior to leaving the work area, and placed in an appropriate designated area or container for storage, washing, decontamination or disposal.

Gloves will be worn when it can be reasonably anticipated the employee may have hand contact with blood, other potentially infectious materials, mucous membranes, and non-intact skin; when performing vascular access procedures, and when handling or touching contaminated items or surfaces.

• Disposable (single use) gloves will be replaced as soon as practical when contaminated, or as soon as feasible if they are torn or punctured, or when their ability to function as a barrier is compromised. Disposable (single use) gloves will not be washed or decontaminated for reuse.

• Utility gloves may be decontaminated for reuse if the integrity of the glove is not compromised. However, they must be discarded if they are cracked, peeling, torn, punctured or exhibit other signs of deterioration, or when their ability to function as a barrier is compromised.

Masks in combination with eye protection devices, such as goggles or glasses with solid side shields or chin-length face shields, shall be worn whenever splashes, spray, spatter, or droplets of blood or other potentially infectious materials may be generated, and eye, nose, or mouth contamination can reasonably be anticipated.

Appropriate protective clothing such as, but not limited to, gowns, aprons, lab coats clinic jackets, or similar outer garments will be worn in occupational exposure situations. The type and characteristics will depend upon the task and the degree of exposure anticipated.

Surgical caps or hoods and/or shoe covers or boots need only be worn in situations when gross contamination can be reasonably anticipated.

I. On-Site Treatment

Autoclaving and Chemical Sterilization: Steam autoclaving is a suitable treatment technique for small volumes of infectious wastes. These include used first aid supplies, blood spill clean up sorbents, liquids, and other small volumes of infectious wastes.

Chemical sterilization is accomplished by use of ethylene oxide; isolyzer compounds or dilute bleach solutions. Ethylene oxide treatment is impractical except in large hospitals. Isolyzer compounds or bleach solutions are practical for small blood spills such as lacerations or bloody noses.

Whatever treatment procedure is used, red bags should not be used for the disposal of TREATED infectious waste in the normal trash as this may cause undo concerns from the campus solid waste hauler or, perhaps, the general public.

J. Waste Disposal

Infectious waste which is disposed of by means other than washing into the sewage system is regulated by federal, state and local laws and is termed "regulated waste". The following specific procedures and precautions must be followed for the handling, treatment and disposal of regulated infectious wastes:

• All sharps must be disposed of in regulated sharps containers, regardless of other protective features built into the tool such as self-sheathing needles.

• If regulated waste is stored prior to disposal, it must be stored in a secure area that is locked or otherwise secured to eliminate access by the general public, and must be afforded protection from adverse environmental conditions and vermin.

• Untreated infectious waste shall not be shipped off-site unless it is hauled by a licensed commercial transported to a licensed infectious waste treatment facility.

• If outside contamination of the regulated waste container occurs, it will be placed in a second container.

• Disposal of Other Regulated Waste. Regulated waste not consisting of sharps shall be disposed of in containers which are: Closable and constructed to contain all contents and prevent leakage during handling, storage, transport, or shipping. These containers will be labeled biohazardous or color-coded (red bagged) and closed prior to removal to prevent spillage or protrusion of contents during handling, storage, transport, or shipping.

Note: OSHA has issued a letter stating that they do not include soiled sanitary napkins and other feminine hygiene products in the definition of regulated waste because they are designed so as to prevent the release of liquid or semi-liquid blood or the flaking off of dried blood. Therefore, employees handling such wastes are not covered by the Bloodborne Pathogens Rule solely due to that duty. However, OSHA does expect that containers for soiled sanitary products to be lined with a plastic or wax paper bag and that employees will be provided suitable gloves for removal of the bags from the waste container.

K. Blood Spills

Blood spills on non-porous surfaces can very simply be handled by diluting the spill with an equal volume of 1:10 household bleach solution, or with other EPA registered disinfectants, and then absorbing it with disposable toweling or absorbent pads. This approach is used in hospitals and exceeds the guidelines issued by the CDC. If the spill involves any broken glassware, it must be picked up using a mechanical means, such as a brush and dustpan, tongs or forceps. In cases where the absorbent becomes saturated with blood and bleach, the spill clean up materials should be autoclaved prior to being disposed of in the normal trash.

There is also a number of "clumping" powdered products (e.g. Vital 1, Isolyzer) that absorb and solidify blood spills and chemically treat the material at the same time. There are also products that fix sharps in a plastic polymer while treating them by heat and chemical disinfectant (e.g. Isolyzer). While these methods are effective and convenient they are very expensive compared to bleach and absorbent material and have not yet withstood the "test of time". Bleach or other EPA approved disinfectants are most highly recommended.

Cabrillo College will establish and maintain an accurate record for each employee with occupational exposure, to include:

1. The name and social security number of the employee.
2. 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.
3. A copy of all results of examinations, medical testing, and follow-up procedures.
4. The College's copy of the healthcare professional's written opinion.
5. 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.