The Occupational Safety and Health Administration (OSHA) Bloodborne Pathogens Exposure Control Standard (29 CFR 1910.1030) requires that employers who have employees who are occupationally exposed to human blood or other potentially infectious materials develop a program to eliminate or minimize such exposures. This Bloodborne Pathogen Exposure Control Plan describes that program at Hampshire College. This plan is reviewed annually or more frequently as needed. The environmental health and safety office coordinates the review.
The program includes all employees who have occupational exposure to bloodborne pathogens. OSHA defines occupational exposure as "reasonably anticipated skin, eye, mucous membrane, or parenteral (under the skin) contact with blood or other potentially infectious materials that may result from the performance of an employee's duties". The OSHA Standard does not cover "good Samaritan" assistance provided in an emergency; however, should an employee be exposed while providing such assistance in the workplace, the College offers post-exposure evaluation and follow-up as described in Section VI.
This plan is maintained as an online document on the College intranet system. Paper copies are available upon request from the environmental health and safety office.
Employees in the following job classifications have occupational exposure to bloodborne pathogens. The environmental health and safety office maintains a list of employees with occupational exposure.
List of all job classifications in which all employees have occupational exposure:
- Campus police officers
- EMT staff
- Children center teachers
- EHS staff
List of job classifications in which some of the employees have occupational exposure:
- Outdoor Programs and Recreational Athletics (OPRA) employees
- Housing operations staff
- Cole Science faculty and staff
List of task and procedures performed in which occupational exposure occurs and that are performed by the employee classifications listed above in 1 and 2:
- First responder and first aid
- Equipment decontamination
- Packaging regulated waste
- Cleaning of bathrooms
- Cleaning of bodily fluids and wastes
- Teaching or research using human blood or tissue
Hampshire College Health Services health care providers are employees of the University of Massachusetts and are covered under that control plan.
Universal precautions must be observed to prevent contact with blood and other potentially infectious materials. Under the concept of universal precautions, all blood and certain human body fluids are always handled as if they are infectious. Blood is the single most important source of bloodborne pathogens in occupational settings. As defined by OSHA, other "potentially infectious materials" include tissue, semen, vaginal secretions, and the following fluids(surrounding the): cerebral (brain), spinal (spine), synovial (joints), pleural (lungs), peritoneal (abdomen), pericardial (heart), and amniotic (fetus). Feces, nasal secretions, sputum, saliva, sweat, tears, urine, and vomit are not included unless they are visibly contaminated with blood.
Under circumstances in which it is difficult to distinguish between infectious and noninfectious body fluids, all body fluids shall be considered "potentially infectious materials." If any of the exposure control methods are not feasible for a certain operation, permission to use alternate methods must be obtained from the department head.
Departments are responsible for providing all materials and equipment necessary to comply with the requirements of this plan.
A. Engineering and Work Practice Controls
The following engineering and work practice controls must be used in all applicable operations with potential exposure.
- Hand washing facilities or antiseptic towelettes (for use in remote locations) are available to all exposed employees. Exposed skin that comes into contact with any body fluid must be washed immediately. Employees must wash their hands immediately or as soon as feasible after removing gloves. If antiseptic towelettes are used, the hands must be washed with soap and water as soon as feasible. Antiseptic towelettes are kept in all first aid kits that are used in remote areas.
- Eating, drinking, smoking, applying cosmetics or lip balm, and handling contact lenses are prohibited in work areas where there is a reasonable likelihood of exposure. Each department is responsible for designating such areas.
- Food and drink must not be kept in areas (e.g., refrigerators, freezers, shelves, cabinets, or countertops) where blood or other potentially infectious materials are or may have been present.
- Contaminated needles or other contaminated sharps must not be bent, broken, or sheared. Recapping of needles is not allowed.
- All contaminated sharps must be immediately placed in a disposable, closeable, puncture resistant container, leak proof on the sides and bottom, and bearing a biohazard label. Official needle boxes must be used for all needles.
- Containers for contaminated sharps must be easily accessible and located as close as feasible to the area where sharps are being used or anticipated to be found.
- Campus police has sharps containers for use if sharps are found on campus. Staff other than campus police should call campus police if a needle is found. Campus police will respond and collect the needle for disposal.
- Containers must be kept upright and must not be overfilled.
- When full, containers of disposable sharps must be closed and taken to the biomedical waste collection area in the building behind Cole Science Center by campus police, the Cole Science laboratory manager, or environmental health and safety.
Material Handling Procedures
- All procedures involving blood or other potentially infectious materials must be performed so as to minimize splashing, spraying, spattering, or the generation of droplets or aerosols of these materials.
- Mouth pipetting or suctioning of blood or other potentially infectious materials, or any other material, is prohibited.
- Secondary containers must be used as necessary if outside contamination of the primary container occurs or if the specimen could puncture the primary container.
- Equipment that may be contaminated with blood or other potentially infectious materials must be examined and decontaminated as necessary prior to servicing or shipping. If portions cannot be decontaminated, a label must be affixed indicating those areas, and the appropriate service representative or manufacturer informed.
- All refrigerators or other storage areas where blood or other potentially infectious materials are kept must be marked with a biohazard label.
- Blood spill kits are available for emergency response from the environmental health and safety office. Response procedures are outlined in Appendix A.
B. Personal Protective Equipment
Hampshire College provides appropriate personal protective equipment (PPE) to all employees. The employee must use the equipment provided. Departments are responsible for providing the necessary PPE. If under unusual circumstances, it is the employee's professional judgment that use of the equipment would prevent the delivery of health care or campus police services or pose an increased risk to the worker or co-worker, the employee should petition the director of environmental health and safety.
If the employee's judgment is made in an emergency situation, the circumstances will be investigated by the director of environmental health and safety, and documented to determine whether changes can be instituted to prevent future occurrences.
- All PPE must be removed before leaving the work area. PPE, which is penetrated by blood or other potentially infectious material, must be removed immediately.
- Gloves must be worn by all employees when it is reasonably anticipated that there may be hand contact with blood, other potentially infectious materials, mucous membranes, and non-intact skin; and when handling or touching contaminated items or surfaces. This requirement includes all vascular access procedures, and all handling of specimens and specimen containers.
- Disposable (single use) gloves must be replaced as soon as practical when contaminated and immediately when they are torn, punctured, or no longer act as a barrier. Disposable gloves cannot be reused and must be discarded in the appropriate location after each use.
- Gloves must be changed between patient contact.
- Utility gloves may be decontaminated and reused, by washing with a disinfectant cleaner, rinsing and air-drying. They must be discarded when any deterioration is noticed (e.g., punctures, tears, cracks, peeling, discoloration).
- Masks, splash goggles, or face shields must be worn whenever splashes, spray, splatter, or droplets of blood or other potentially infectious materials may be generated and eye, nose, or mouth contamination is reasonably anticipated.
- Gowns, aprons, or other protective clothing must be worn in all situations where exposure is anticipated.
- Lab coats worn as PPE must be disposable.
- Mouthpieces, resuscitation bags (ambu), or pocket masks must be worn when performing artificial resuscitation.
- Any employee who is allergic to latex will be provided an alternative glove.
Campus police has gloves, masks, eye protection, a gown, and resuscitation devices in each vehicle and in the main office. Officers also carry gloves on their person. OPRA keeps with first aid supplies. The children's center keeps gloves with first aid supplies and in each classroom. Facilities and grounds personnel keep gloves with their cleaning or material handling supplies. Cole Science Center has supplies gloves and eye protection to every lab.
The work site must be maintained in a clean and sanitary condition. A bleach solution (1/4 cup per 1 gallon), or hospital disinfectant, is used for cleaning all surfaces visibly contaminated with blood. A general-purpose disinfectant is used for other surfaces. Gloves are worn during all cleaning procedures.
- All equipment and surfaces are decontaminated immediately with a disinfectant after overt contamination with blood or other potentially infectious materials; and at the end of the work shift if it may have been contaminated since the last cleaning.
- Protective coverings, such as foil or imperviously backed absorbent paper, are removed and replaced as soon as feasible when they become contaminated.
- All containers intended for reuse, including contaminated waste containers, that have a reasonable likelihood of becoming contaminated are inspected and decontaminated at least monthly and as soon as feasible after known contamination.
- Broken glassware, which may be contaminated, must not be picked up directly with the hands; forceps, dustpan, and brush/spatula or other equipment are used. A brush should not be used to avoid splashing or generation of aerosols.
- Only trained personnel are authorized to clean-up potentially infectious materials.
- Procedures for cleaning contaminated areas are included in Appendix A.
D. Waste Disposal
- All contaminated disposable sharps, including broken glass, are immediately placed in a disposable, closeable, puncture-resistant container, leak-proof on the sides and bottom, and bearing the international biohazard label.
- All other contaminated waste are segregated from uncontaminated trash and placed in red bags or other appropriate containers. Any wastes containing free liquids are placed in a liquid tight container marked with the international biohazard symbol. Any items that could puncture a bag should be put in a puncture-resistant container and then a red bag.
- Secondary containers must be used if outside contamination of the primary container occurs, or if the waste could puncture the primary container.
- All red bags are tied prior to removal from the area of generation to the biomedical waste storage area.
- In Cole Science Center contaminated material may also be autoclaved. Once autoclaved, waste is labeled with the statement "Noninfectious Biomedical Waste, Treated by Hampshire College" prior to disposal as solid waste.
Biomedical waste is stored in the waste storage building behind Cole Science Center. Waste can be brought to the storage area by: campus police, the Cole Science Center laboratory manager, custodial supervisors, or the environmental health and safety staff. Waste transport by a vendor to a licensed incinerator is coordinated by the environmental health and safety office.
E. Contaminated Laundry
- Gloves are worn when handling all dirty laundry. A gown is also used when the laundry is grossly soiled with blood or other potentially infectious materials.
- Soiled laundry is handled as little as possible and in a manner that prevents the laundry from coming into contact with the body or clothing.
- Soiled laundry is placed directly into designated laundry bags. Grossly soiled laundry is placed in the regular laundry bag and that bag placed in a red biohazard bag. If the laundry is wet it is placed in a double bag or other container to prevent soak-through or leakage of the fluids.
In addition to the specific engineering and work practice controls described above for handling needles, OSHA requires evaluation and implementation of commercially available and effective safer medical devices. Since, Health Services health care providers are University of Massachusetts employees, there is no or minimal use of needles or other medical devices by Hampshire College employees. Should a situation arise where needles or other medical devices will be used with potentially infectious materials, alternatives will be reviewed on a case-by-case basis.
Hepatitis B vaccination is available to all employees who have occupational exposure at no cost to the employee. The vaccine is offered to employees with occupational exposure after initial training and within 10 days of assignment to a position with occupational exposure. Vaccination records are maintained at health services as part of the employee's medical record.
Vaccines are administered by health services, or, when health services is closed, other arrangements are made with a local care provider. Appointments with health services can be made directly by the employee. When health services is closed, the employee should contact environmental health and safety.
Occupationally exposed employees are given a fact sheet (Appendix B) describing the vaccination series and are asked to elect to have the series or sign the mandatory declination (Appendix C). Declination statements are returned to the environmental health and safety office. The environmental health and safety office records that a declination statement has been received and forwards the signed statement to health services to be maintained as part of the employee's medical record. Should an employee who continues to work in a position with occupational exposure and who has signed a declination wish to have the vaccination at a later time, it will be provided upon request from health services or environmental health and safety.
Upon skin contact, the area should be washed immediately with soap and water. If soap and water is not available, an antiseptic towelette should be used, and soap and water used as soon as possible.
Upon eye or other mucous membrane contact, the area should be flushed immediately with water or saline solution, whichever is available.
Employees must immediately report all exposure incidents to their immediate supervisor, who will notify the department head. An exposure incident is "a specific eye, mouth, other mucous membrane, non-intact skin, or parenteral (under the skin) contact with blood or other potentially infectious material that results from the performance of an employee's duties."
The department head is responsible for initial investigation of the incident, and notification of human resources and the environmental health and safety office within 24 hours. The department head may designate these duties to a supervisor who has attended the bloodborne pathogen training.
An exposure incident report (see Appendix E) should be attached to the employee accident report form submitted to human resources. A copy should be sent to the environmental health and safety office. The investigation must document:
- The route and circumstances of exposure.
- Identification and documentation of the source individual, unless that identification is not feasible.
- Procedural changes identified which would prevent reoccurrence of any conditions that increased the risk of exposure.
Following a report of an exposure incident to the department head, the employee will be offered a confidential evaluation and follow-up. The employee and the source individual, if identified, will be immediately referred to the Cooley Dickinson Hospital by the department head, environmental health and safety, or human resources. If the exposed employee or source individual is a student, they will be referred to health services. The employee will be advised that post-exposure evaluation is recommended within 24 hours of exposure.
The college has confirmed that Cooley Dickinson Hospital has a copy of the OSHA Standard that describes the requirements for exposure evaluation and follow-up, and will provide, at the time of the incident, the results of the investigation of exposure. Cooley Dickinson Hospital will follow the procedures established by OSHA and the Center for Disease Control for post-exposure medical evaluation and provide human resources a written opinion within 15 days of completion of the evaluation as prescribed by the OSHA Standard.
Medical records required by the OSHA Standard are kept at health services. Those records include for all employees with occupational exposure:
- the employee name and social security number
- a copy of the employee's vaccination status or declination
- a copy of any results of examination and medical testing
- a copy of any health professional written opinions
- a copy of any information provided to the health care professional.
All medical records are kept confidential and are not be disclosed without the employee's express written consent to any person within or outside the workplace except as required by the OSHA Standard or as may be required by law.
Human resources maintains the sharps injury log required by OSHA in 29 CFR 1910 as part of the OSHA 300 log.
A. Signs and Labels
- Warning labels are firmly affixed to all equipment and containers used to store, or ship blood or other potentially infectious materials. The labels include the international biohazard symbol.
- Waste may either be labeled as described above or placed in a red bag or container.
- Containers of blood, blood components, or blood products that are labeled as to their contents and have been released for transfusion or other clinical use are exempt from additional labeling requirements.
- Individual containers of blood or other potentially infectious materials that are placed in a labeled container during transport, shipment, or disposal are exempted from the additional labeling requirements.
- If equipment that may be contaminated with blood or other potentially infectious materials cannot be decontaminated, a label is affixed indicating those areas, and the appropriate service representative or manufacturer informed.
B. Information and Training
All employees with occupational exposure are trained during working hours at no cost to the employee. All new or transferred employees with occupational exposure are trained at the time of initial assignment to tasks where occupational exposure may take place. Appendix D includes an attendance form.
Training is updated at least annually and whenever a modification of tasks or procedures affects occupational exposure. There is opportunity for the employee to ask questions during the training session.
On-line training customized to include Hampshire College policies may be used. When online training is used, the environmental health and safety office will follow up with the employees to answer any questions they may have.
Employee training is coordinated by the environmental health and safety office or campus police (campus police employees and EMTs). All supervisors with occupationally exposed staff must also attend training. Departments are responsible for scheduling new employee training with the environmental health and safety office. The environmental health and safety office maintains training records for at least three years.
A. Procedure for Cleaning Bodily Fluids Contamination
B. Hepatitis B Vaccine [Recombinant] Employee Information Sheet
C. Declination of Hepatitis B Vaccination
D. Training Record
E. Incident Report Form