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.