Section II: General Program Management

RESPONSIBLE PARTIES
There are two major "Categories of Responsibility" that are central to the effective implementation of the exposure control plan. These are:

1. Employer
2. Employee
   
   

The following section defines the roles played by both of these groups in carrying out the plan.

Employer

The Administrator or appointed designee will be responsible for the overall management and support of the Bloodborne Pathogens Compliance Program. Activities, which would typically be included, but are not limited to, include:

1. Overall responsibility for implementing the Exposure Control Plan for the entire school district.
2. Work with the school district and other employees to develop and administer any additional bloodborne pathogens related policies and practices needed to support the effective implementation of this plan.
3. Periodically review the Exposure Control Plan to determine if revisions are needed.
4. Designate an employee to collect and maintain a suitable reference library on the Bloodborne Pathogen Standard and bloodborne pathogens safety and health information.
5. Know current legal requirements concerning bloodborne pathogens.
6. Act as facility liaison during OSHA inspections.
7. Conduct periodic facility audits to maintain an up-to-date Exposure Control Plan.
8. Designate employees who will be responsible for carrying out various aspects of the Exposure Control Plan.
9. Ensure that proper exposure control procedures are followed.
10. Consult with employees regarding changes in technology that eliminate or reduce exposure to bloodborne pathogens. Document annually. (See appendix-FORM A)
11. Make training available to employees identified as having the potential for exposure to bloodborne pathogens. This will include the following activities:
    1. maintain a current list of (school district) personnel requiring training.
    2. identify and schedule periodic suitable education/training programs
    3. maintain appropriate training documentation.
    4. periodically review the training programs to include appropriate new information.
    5. monitor occurrence reports related to employee exposure to bloodborne pathogens.
    6. conduct post-exposure evaluation and follow-up.
    7. conduct exposure incident investigation.
    8. maintain medical record keeping.

Employee

The employees of ( school district ) have the most important role in the bloodborne pathogens compliance program, for the ultimate execution of much of the Exposure Control Plan rests in their hands. In this role the employees function as follows:

1. Know what tasks they perform that have occupational exposure.
2. Attend the bloodborne< pathogens training sessions applicable to their exposure/risk level.
3. Plan and conduct all activities in accordance with established work practice controls. Develop good personal hygiene habits.
   
   

AVAILABILITY OF THE EXPOSURE CONTROL PLAN TO EMPLOYEES
Employees will have access to ( school district’s ) Exposure Control Plan at all times. Employees will be advised of this availability during education/training sessions. Copies of the Exposure Control Plan will be kept in each building in the administrative office. (Superintendent/Principal/Head Teacher).


REVIEW AND UPDATE OF THE PLAN
It is important to keep the Exposure Control Plan up to date. To ensure this, the plan will be reviewed and updated under the following circumstances:

1. Annually--on or before April 1 of each year at a meeting of the Safety Committee.
2. Whenever appropriate personnel are made aware of new or modified tasks and procedures are implemented which affect occupational exposure of employees.
3. Whenever appropriate personnel have been notified that employees' jobs have been revised whereby new instances of occupational exposure may occur.
4. Whenever new functional positions within the school district are established that may involve exposure to bloodborne pathogens.

Section III: Exposure Determination

One of the keys to implementation of a successful Exposure Control Plan is to identify exposure situations that employees may encounter. To facilitate this in the school district, the following information will be compiled:

1. Job classifications in which all employees have occupational exposure to bloodborne pathogens. (See appendix - FORM B)
2. Job classifications in which some employees have occupational exposure to bloodborne pathogens. (See appendix - FORM C)
3. Tasks and procedures in which occupational exposure to bloodborne pathogens occur. (See appendix-FORM D)

Section IV: Methods of Compliance

There are a number of areas that must be addressed in order to effectively eliminate or minimize employee exposure to bloodborne pathogens in the school district. The first five areas in the plan are explained below. Each of these areas will be reviewed with employees during their bloodborne pathogens related training. (See the Information and Training section of this plan for additional information.)

UNIVERSAL BLOOD AND BODY FLUID PRECAUTION
The practice of "Universal Blood and Body Fluid Precautions" shall be the standard within the school district to prevent contact with blood and other potentially infectious materials. As a result, all human blood and body fluids shall be treated as if they are known to be infectious for HBV, HIV, and other bloodborne pathogens. The administrator or appointed designee is responsible for overseeing the Universal Blood and Body Fluid Precautions Program.


ENGINEERING CONTROLS
One of the key aspects of the Exposure Control Plan is the use of engineering controls to eliminate or minimize employee exposure to bloodborne pathogens. Appropriate equipment such as sharps disposal containers shall be made available. A "sharp" can be needles, pencils,cutting equipment, or art, science, or industrial arts supplies. Document sharps injuries. (See (appendix-FORM E). During the annual review of the Exposure Control Plan, areas where engineering controls can be updated and areas where engineering controls can be beneficial are evaluated. Existing engineering controls are reviewed for proper function and needed repair or replacement. (See appendix-FORM F).

In addition to the engineering controls identified on the Engineering Equipment Control form, the following engineering controls will be used throughout the school district.

• Hand washing facilities (or antiseptic hand cleansers and towels or antiseptic towelettes) are readily accessible to all employees who have the potential for exposure.
• Containers for contaminated sharps are provided which are puncture resistant, color-coded or labeled with biohazard warning label, and leak proof on bottom and sides.
• Wastebaskets are lined with disposable, leak proof bags.
  
  
  WORK PRACTICE CONTROLS
  
  The following work practice controls have been adopted to help eliminate or minimize employee exposure to bloodborne pathogens.
  
  1. Employees shall wash their hands immediately (or as soon as is feasible) after removal of gloves or other personal protective equipment.
  2. Employees shall wash their hands and any other exposed skin with soap and water as soon as possible following any contact of body areas with blood or other infectious materials. Exposed mucous membranes will also be flushed with water.
  3. Contaminated needles and other contaminated sharps shall not be bent or recapped.
  4. Eating, drinking, smoking, applying cosmetics or lip balm, and handling contact lenses shall be prohibited in work areas where there is potential for exposure to bloodborne pathogens.
  5. Food and drink shall not be kept in refrigerators, freezers, on countertops, or in other storage areas where blood or other potentially infectious materials are present.
  6. In all procedures involving blood or other infectious materials, splashing, spraying, or other actions generating droplets of the materials shall be minimized.
  7. Contaminated materials shall be placed in designated leak proof containers (appropriately labeled). Double bagging may be necessary if the original container becomes contaminated.
  8. Student personal property that becomes contaminated shall be examined prior to sending home and decontaminated as necessary, unless it can be demonstrated that decontamination is not feasible.
  
  When an individual is hired or an employee changes jobs within the school district, the following process shall take place to ensure proper training in the appropriate work practice controls:
  1. The employee's job classification and the tasks and procedures that will be performed are checked against the Job Classifications and Tasks Lists, which were identified in the Exposure Control Plan as those in which occupation exposure occurs.
  2. If the employee is transferring from one job to another within the school district, the job classifications and tasks/procedures pertaining to their previous position are also checked against these lists.
  3. Based on this "cross checking", the new job classifications and/or tasks and procedures, which will bring the employee into occupational exposure situations, are identified.
  4. The employee will be trained regarding any work practice controls that the employee has not yet experienced.
     
     
     PERSONAL PROTECTIVE EQUIPMENT
     
     Personal protective equipment is the employees´ "last line of defense" against bloodborne pathogens. Because of this, ( school district ) provides (at no cost to the employees) the personal protective equipment needed to protect against exposure. This equipment may include but is not limited to:
     • Gloves
     • Heavy Duty Gloves
     • Gowns
     • Laboratory coats
     • Face shields/masks
     • Safety glasses
     • Goggles
     • Mouthpieces
     • Pocket masks
     • Hoods
     • Shoe covers
     • Dustpan/Broom
  Vinyl gloves and similar alternatives are provided to employees who are allergic to the gloves used by the school district. The Administrator or appointed designee is responsible for ensuring that all areas have appropriate protective equipment available to employees.
  
  All employees are trained regarding the use of appropriate personal protective equipment for their job classifications and task/procedures they perform. Training about personal protective equipment is provided, when necessary, if an employee takes a new position or if job functions are added to the current position. To determine whether additional training is needed, the employee's previous job classification and tasks are compared to those for any new job or function that is undertaken. Any needed training is provided by the Administrator or appointed designee.
  
  To ensure that personal protective equipment is not contaminated and is in the appropriate condition to protect employees from potential exposure, the school district adheres to the following practices:

  1. All personal protective equipment shall be inspected periodically and repaired or replaced as needed to maintain its effectiveness.
  2. Reusable personal protective equipment shall be cleaned, laundered, and decontaminated as needed.
  3. Single-use personal protective equipment (or equipment that cannot be decontaminated for whatever reason) shall be disposed of in the appropriate fashion.

  The monitoring of equipment will be accomplished by the Administrator or appointed designee. To make sure that this equipment is used as effectively as possible, employees are to adhere to the following practices when using personal protective equipment:

  1. Any garments penetrated by blood or body fluids or other infectious materials shall be removed immediately (or as soon as feasible).
  2. All personal protective equipment shall be removed prior to leaving the area where it is being used.
  3. Gloves shall be worn in the following circumstances:
     • whenever employees anticipate hand contact with potentially infectious materials.
     • when handling or touching contaminated items or surface
  4. Disposable gloves shall be replaced as soon as practical after contamination or if they are torn, punctured, or otherwise lose their ability to function as an "exposure barrier."
  5. Utility gloves shall be decontaminated for reuse unless they are cracked, peeling, torn, or exhibit other signs of deterioration, at which time they are disposed of and replaced.
  6. Masks and eye protection (goggles, face shields, etc.) shall be used whenever it is anticipated that splashes or sprays may generate droplets of infectious materials.
  7. Protective clothing (such as gowns and aprons) shall be worn whenever potential exposure of the employee's body is anticipated.
  8. Caps/gowns and/or shoe covers/boots shall be used in any instances where "gross contamination" is anticipated.
     
     

  5. HOUSEKEEPING
     
     Maintaining the school district in a clean and sanitary condition is an important part of the bloodborne pathogens compliance program. To facilitate this, a written schedule for cleaning and decontamination of the various areas of the school district shall be established. The schedule and the following information can be obtained from the custodial department:

     Work schedule
     Cleansers and disinfectants used
     Special instructions that are appropriate

     
     Using this information, the custodial staff employs the following practices:
     1. All equipment and surfaces are cleaned and decontaminated after contact with blood or other potentially infectious materials.
     2. Protective coverings are removed and replaced as soon as feasible when overtly contaminated.
     3. All pails, bins, cans, or other receptacles intended for routine use are inspected, cleaned, and decontaminated as soon as possible if visibly contaminated.
     4. Potentially contaminated broken glassware is picked up using mechanical means (such as dustpan and brush, tongs, forceps, etc.).
     5. The custodial staff is responsible for setting up a cleaning and decontamination schedule/practice and ensuring its implementation within the school district.

  Care needs to be exercised within the school district in handling regulated waste (including contaminated sharps, laundry, used bandages, and other potentially infectious materials). The following procedures are used with these types of wastes:

  1. Wastes are discarded or "bagged" in containers that are closable, puncture resistant, leak proof if the potential for fluid spill or leakage exists, and red in color or appropriately labeled with the biohazard-warning label.
  2. Containers for this regulated waste are located within the school district in easy access to employees and as close as possible to the source of the waste.
  3. Waste containers are maintained upright, routinely replaced or emptied, and are not allowed to overfill.
  4. Contaminated clothing is handled as little as possible and is not sorted or rinsed where it is used. It is laundered at school whenever possible. When it is not possible, it is bagged and secured in a leak proof bag and sent home with the student’s parent.
  5. Whenever employees move containers of regulated waste from one area to another, the containers are immediately closed and placed inside an appropriate secondary container if leakage is possible from the first container.

  The custodial staff is responsible for the collection and handling of contaminated waste. Waste that is not pourable or spillable will be handled as little as possible and disposed of in closable bagged containers.

Section V: Hepatitis B Vaccination

POST-EXPOSURE EVALUATION AND FOLLOW-UP
It is recognized that even with strict adherence to all exposure prevention practices exposure incidents can occur. As a result, procedures for post-exposure evaluation and follow-up have been established in the event that exposure to bloodborne pathogens occurs.

1. 
   
2. VACCINATION PROGRAM
   To protect employees as much as possible from the possibility of Hepatitis B infection, a vaccination program has been implemented by the school district. This program is available at no cost to all employees who may have occupational exposure to bloodborne pathogens. The vaccination program consists of a series of three inoculations over a six-month period. As part of the bloodborne pathogens training, employees receive information regarding hepatitis vaccination, including its safety and effectiveness.
   
   The Administrator or appointed designee is responsible for setting up and operating the vaccination program. Vaccinations are performed under the direction of a licensed physician or other health care professional. Lists of employees taking part in the vaccination program are available in the Employee Health Records. Informed Consent will be secured from employees. (See appendix-FORM G) The school district may require physician approval for hepatitis B vaccination. (See appendix-FORM H) Employees who have declined to take part in the vaccination program are listed and have signed the Vaccination Declination Form. (See appendix-FORM I).
   
   To ensure that all employees are aware of the vaccination program, the subject is thoroughly discussed in the bloodborne pathogens training and Hepatitis B vaccination clinic notices are posted in prominent places throughout the school district.
   
3. POST-EXPOSURE FOLLOW-UP
   
   If an employee is involved in an accident where exposure to bloodborne pathogens may occur, there are two things on which efforts need to be immediately focused.
   1. Investigation of the circumstances surrounding the exposure incident.
   2. Assurance that the employee receives medical consultation and treatment (if required) as expeditiously as possible.
   
   The Administrator or appointed designee shall investigate every reported incident that occurs within the school district. This investigation shall be initiated within 24 hours of the incident and involves gathering the following information (if at all possible):
   1. When the incident occurred--date and time.
   2. Where the incident occurred--location within the school district.
   3. What potentially infectious materials were involved in the incident--blood, body fluids, etc.
   4. Source of the potentially infectious material.
   5. Under what circumstances the incident occurred--type of work being performed.
   6. How the incident was caused--accident, unusual circumstances such as equipment failure, power outage, etc.
   7. Personal protective equipment being used at the time of the accident. Actions taken as a result of the incident--employee decontamination, cleanup, notifications made.
   
   After this information is gathered, it shall be evaluated, a written summary of the incident and its causes prepared, and recommendations made to avoid similar incidents in the future. An Exposure Incident Report will be completed. (See appendix-FORM J).
   
   If an exposure to bloodborne pathogens should occur, a comprehensive post-exposure evaluation and follow-up process shall be established to ensure that employees receive the best and most timely treatment. (See appendix-FORM K.) This process is overseen by the school nurse, a physician designated by the district, or the employee’s personal physician. The employee may refuse a post-exposure medical evaluation. (See appendix-FORM L).
   
   It is recognized that much of the information involved in this process must remain confidential and everything possible will be done to protect the privacy of the individual(s) involved. As a first step in this process, the following confidential information is provided to an exposed employee:
   1. Documentation regarding the routes of exposure and circumstances under which the incident occurred.<
   2. Identification of the source individual (unless infeasible or prohibited by law).
   
   The next step, if possible, is to test the source individual's blood to determine HBV and HIV infectivity. This is accomplished by the following tests: HBsAg and HIV antibody. This information will be made available to the exposed employee if it is obtained. At that time the employee will be made aware of any applicable laws and regulations concerning disclosure of the identity and infectious status of a source individual.
   
   The exposed employee's blood will be collected as soon as feasible after consent is obtained, and tested for HBV and HIV serological status. If the employee consents to baseline blood collection but does not give consent at that time for HIV serologic testing, the sample will be preserved for at least 90 days. If, within 90 days of the exposure incident, the employee elects to have the baseline sample tested, such testing will be done as soon as possible.
   
   Employees who have had hepatitis immunization and documented response need not be tested for hepatitis B. Once these procedures have been completed, the exposed employee will meet with a qualified healthcare professional to discuss the employee's medical status. This includes an evaluation of any reported illness as well as any recommended treatment.
   
   
   
4. THE EVALUATION AND WRITTEN REPORT
   
   After consultation, the Administrator or appointed designee shall provide a copy of the evaluating healthcare professional's written opinion within 15 days of the completion of the evaluation (See appendix-FORM M). In keeping with the emphasis on confidentiality, the written report will contain only the following information:
   1. Whether Hepatitis B vaccination is indicated for the employee.
   2. Whether the employee has received the Hepatitis B vaccination.
   3. Confirmation that the employee has been informed of the results of the evaluation.
   4. Confirmation that the employee has been told about any medical conditions resulting from the exposure incident which require further evaluation or treatment.
      
   All other finding or diagnoses will remain confidential and will not be included in the written report.
   
   
   
5. MEDICAL RECORDKEEPING
   
   Medical records pertaining to immunization for or exposure to bloodborne pathogens shall be maintained by the school district. (See appendix-FORM N) Records shall include the following information:
   1. Name of the employee.
   2. Social security number of the employee.
   3. A copy of the employee's Hepatitis B vaccination status, dates of any vaccinations, pertinent information related to the employee's ability to receive the vaccination.
   4. Copies of the results of the examinations, medical testing, and follow-up procedures which took place as a result of an employee's exposure to bloodborne pathogens. As with all information in these areas, it is recognized that it is important to keep the information in these medical records confidential. This information shall not be disclosed or reported to anyone without the employee's written consent (except as required by law).

Section VI: Containers, Signs, Disposal

The most obvious warning to employees of possible exposure to bloodborne pathogens is a sharps container with a biohazard-warning label. When necessary, biohazard-warning labels on containers/bags should be used.

The following items shall be labeled:

1. Sharps disposal containers.
2. Laundry bags and containers.
3. Contaminated equipment.

Section VII: Information and Training

Having well-informed and educated employees is extremely important when attempting to eliminate or minimize exposure to bloodborne pathogens. Because of this, all employees who have the potential for exposure to bloodborne pathogens will be provided access to a comprehensive training program and will be furnished with as much information as possible on this issue. Employees will be provided access to retraining at least annually to keep their knowledge current.

All new employees, as well as employees changing jobs or job function, will be provided access to any additional training required by their new position at the time of their new job assignment.

A. TRAINING TOPICS

The topics covered in the training program include, but are not limited to, the following:

• The Bloodborne Pathogens Standard itself.
• The epidemiology and symptoms of bloodborne disease.
• The modes of transmission of bloodborne pathogens.
• The school district’s Exposure Control Plan (and where employees can obtain a copy).
• Appropriate methods for recognizing tasks and other activities that may involve the exposure to blood and other potentially infectious materials.
• A review of the use and limitations of methods that will prevent or reduce exposures, including:
  • Engineering controls
  • Work practice controls/Universal Precautions
  • Personal protective equipment
• Information on the types, proper use, location, removal, handling, decontamination and disposal of personal protective equipment.
• An explanation of the basis for the selection of personal protective equipment.
• Information on Hepatitis B vaccine, including:
  • Efficacy
  • Safety
  • Method of administration
  • Benefits of vaccination
  • Free availability of vaccine
• Actions to take and persons to contact in an emergency involving blood or other potentially infectious materials.
• The procedures to follow if an exposure incident occurs, including incident reporting and medical follow-up that will be made available.
• Information on the post-exposure evaluation and follow-up that the employer is required to provide the employee following the exposure incident.
• An explanation of the signs and labels used.
• An opportunity for interactive questions and answers with the person conducting the training session.

B. TRAINING METHODS

The school district makes use of several training techniques, which may include, but not necessarily be limited to, the following:

• classroom with personal instruction
• videotape programs
• training manuals/employee handouts
• employee review sessions
• annual education day

Because employees need an opportunity to ask questions and interact with their instructors, time is specifically allotted for these activities in each training session.

C. RECORDKEEPING

To facilitate the training of employees, as well as to document the training process, training records are maintained containing the following information: date and time of training session
contents/summary of the training session
names and qualifications of the instructors
names, job titles, and social security numbers of the employees attending the training session
(See appendix- FORM O).

Use of a computer and/or the forms on the following page facilitate this record keeping. These training records are available for examination and copying to employees and their representatives as well as OSHA and its representatives.

Resources and Appendices

Nebraska Department of Health and Human Services

HIV/AIDS Prevention/Ryan White Program
Julane Hill
Nebraska Department of Health and Human Services Community Planning Coordinator
301 Centennial Mall South
PO Box 94817
Lincoln, NE 68509-4817
402-471-0361
(Fax) 402-471-0382
julane.hill@dhhs.state.ne.us

Nebraska Department of Health and Human Services

Office of School Health
Kathy Karsting, RN, BSN
Health and Human Services
School and Child Health Nursing Coordinator
301 Centennial Mall South
PO Box 95044
Lincoln, NE 68509-5044
402-471-0160
(Fax) 402-471-7049
kathy.karsting@dhhs.state.ne.us