This exposure control plan applies to U.S. Geological Survey (USGS) employees who are members of an Automatic External Defibrillator (AED) team that provides services under an AED plan that falls under the oversight of a medical director. This plan has been developed in accordance with the Centers for Disease Control and Prevention (CDC) guidelines and the Occupational Safety and Health Administration (OSHA) Bloodborne Pathogens Standard (29 CFR 1910.1030) to help protect employees from bloodborne pathogens (BBP). This plan will be reviewed and updated annually.
Date Reviewed: 5 June 2014
Reviewed by: Anthony Zepeda
The OSHA BBP Standard requires a determination be made as to which employees may be at risk for occupational exposure to BBP. This section identifies those job classifications and work activities with risk of exposure. Employees who are members of an endorsed AED team have the potential for exposure to bloodborne pathogens in the course of their duties. A list of the AED team members will be kept by each facility.
1. Universal precautions will be used by all employees whenever the potential for exposure to BBP’s exists. Universal precautions are defined as an approach to infection control. According to the concept of Universal Precautions, all human blood and certain human body fluids are treated as if known to be infectious for human immunodeficiency virus (HIV), hepatitis B virus (HBV), hepatitis C virus (HCV) and other bloodborne pathogens. Under circumstances in which differentiation between body fluid types is difficult or impossible, all body fluids shall be considered potentially infectious materials. These may involve standard work practices and the use of personal protective equipment (PPE), such as gloves, protective clothing, eye protection, and/or masks. Employees must adhere rigorously to the infection control precautions noted in this section in order to minimize the risk of exposure to blood and other body fluids.
2. The OSHA standard requires three forms of precautions or controls to minimize/reduce the exposure to BBP. These are engineering controls, work practices (procedures), and PPE. Engineering and work practice controls shall be used to eliminate or minimize employee exposure. Where occupational exposure remains after institution of these controls, PPE must be used.
a. Engineering controls offer the greatest risk reduction. The premise behind
engineering controls is to prevent the hazard from occurring through design.
The most common form of BBP engineering control is the sharps container. Other
forms considered by the standard as engineering controls are self-sheathing
needles and needless systems. Sharps such as the disposable razor in the AED
kit, scissors to cut away clothing, and broken glass will be disposed of in
a strong plastic container such as an empty bleach bottle when a sharps container
is not readily available. The containers must be puncture resistant, leakproof
on the sides and bottom, and labeled as shown below with a fluorescent orange
or orange-red label and lettering and symbols in a contrasting color. The container
of sharps will be disposed of as regulated waste. The hazardous waste coordinator
will prepare the waste for shipping.
b. The second level of hazard control is work practices or procedures. Work practices are designed to minimize the possibility of a hazard through the use of a specific set of procedures. Since this method of hazard control relies on the individual to correctly carry out the procedures, it is not considered as effective engineering controls for managing a hazard. This is because humans make errors, may ignore or circumvent the procedures, or the procedures may not be written to cover all contingencies. Sharps such as razors, scissor, and broken glass will be immediately disposed of into a readily accessible sharps container.
c. The third level of hazard control is PPE. It does not prevent the hazard from occurring, but provides protection to the worker if the hazard occurs. Because it does not prevent the hazard, the use of PPE is not considered as effective as engineering controls. Generally PPE is used as a secondary or back-up means of hazard control. However, in the case of exposure to BBP, especially as the result of an emergency or unplanned event, engineering control measures may not be available or practical, and PPE would be the primary means of control. PPE used by the AED team is:
Non-latex disposable gloves (i.e. nitrile or vinyl),
Plastic disposable aprons,
One-way valve resuscitation shields for CPR.
(1) USGS will supply PPE and replace it after an exposure incident.
(2) Disposable nitrile or vinyl gloves will be worn whenever there is a reasonable expectation that the employee will have hand contact with blood, other potentially infectious materials, nonintact skin, or mucous membranes. Disposable gloves will not be washed or reused once they have been soiled. Disposable gloves will be kept on hand in various sizes.
(3) Employees will be asked to dispose of personal clothing that may become contaminated by blood. The clothing will be covered with a 10% bleach solution and allowed to soak for at least 20 minutes before disposal.
d. Readily available hand washing facilities are available for employees occupationally exposed to bloodborne pathogens. In remote locations where hand washing facilities are not feasible, employees are provided with either an antiseptic cleanser and clean cloth/paper towels or with antiseptic towelettes. Should an exposure occur while in this remote location, hands should be washed with soap and running water as soon as possible.
e. Employees will not eat, drink, smoke, or apply cosmetics in areas where there is a reasonable likelihood of exposure to blood or other potentially infectious materials.
3. Areas that are contaminated by blood will be disinfected by the AED team members using either a 10% bleach solution or an EPA-registered germicide. After the area is disinfected, custodians that are not included in the exposure control plan may complete the cleaning.
4. Although regulated medical waste is not normally generated by this organization, when it is, it will be disposed of in accordance with all applicable Federal, State, and local requirements.
5. All AED team members have possible occupational exposure to bloodborne pathogens and will be offered the hepatitis B vaccine. The vaccine will be offered to the employee at no cost and will be available to the employee within 10 working days after their assignment to the AED team.
6. Employees will be provided information concerning the positive benefits and potential side effects to make an informed decision about whether or not to be vaccinated. Employees that do not wish to be vaccinated must sign a written declination form. Both forms will become part of the employee’s official occupational health record. Declination of the vaccine does not preclude the employee from being vaccinated at a later date should the employee change his or her mind.
7. Post-exposure Evaluation and Follow-up.
When an employee experiences an exposure incident it will be reported to his or her supervisor. Following a report of an exposure incident, the supervisor shall make immediately available to the exposed employee a confidential medical evaluation and follow-up, including at least the following elements:
a. Document the route of exposure and the circumstances under which the exposure incident occurred.
b. Identify and document of the source individual, unless the supervisor can establish that identification is infeasible or prohibited by state or local law.
c. When the source individual is already known to be infected with HBV or HIV, testing for the source individual's known HBV or HIV status need not be repeated.
d. Results of the source individual's testing will be made available to the exposed employee, and the employee shall be informed of applicable laws and regulations concerning disclosure of the identity and infectious status of the source individual.
e. The exposed employee's blood will be collected as soon as feasible and tested after consent is obtained.
f. 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 feasible.
g. The employee will be provided with post-exposure prophylaxis, when medically indicated, as recommended by the U.S. Public Health Service; counseling; and will have reported illnesses evaluated.
Training for AED team members will be conducted prior to their initial assignment to a task where exposure may occur. There will be an opportunity for interactive questions and answers with the person conducting the training session. Employees will receive annual refresher training. Training will include:
a. How to access a copy of the regulatory text of the BBP standard on the OSHA web page (1910.1030 - Bloodborne pathogens) and an explanation of the standard and its requirements;
b. A general discussion of the epidemiology and bloodborne diseases and their symptoms, and an explanation of how the diseases can be transmitted;
c. An explanation of this exposure control plan and how to access a copy of the written plan on the USGS web page;
d. An explanation of the appropriate methods for recognizing activities that may involve exposure to blood and other potentially infectious materials;
e. How to prevent or reduce occupational exposures, including appropriate engineering controls, work practices, and PPE;
f. Information on the types, proper use, location, removal, handling, decontamination, and disposal of PPE;
g. An explanation of the basis for selection of PPE;
h. The benefits of the hepatitis B vaccine and that the vaccine and vaccination will be offered free of charge; and
i. The reporting and follow-up procedures following an actual exposure incident including:
(1) Information on the appropriate actions to take and persons to contact in an emergency involving blood or other potentially infectious materials;
(2) An explanation of the procedure to follow if an exposure incident occurs, including the method of reporting the incident and the medical follow-up that will be made available; and
(3) Information on the post-exposure evaluation and follow-up that the employer is required to provide for the employee following an exposure incident.
j. An explanation of the required signs and labels and/or color coding.
Bureau Industrial Hygienist is responsible for ensuring that this policy is effectively implemented and for maintaining the records related to this policy.
a. Medical records will be maintained for 30 years post employment. Employee medical records are provided upon request of the employee or to anyone having written consent of the employee within 15 working days. Such requests should be sent to the Cost Center Manager.
b. Training records will be maintained for three years after the training date. The training records include: the dates of the training sessions, the contents or a summary of the training sessions, the names and qualifications of persons conducting the training, the names and job titles of all persons attending the training sessions. Employee training records are provided upon request to the employee or the employee's authorized representative within 15 working days. Such requests should be addressed to the Cost Center Manager.
c. Exposure incidents are evaluated to determine if they are a “recordable” under OSHA’s Recordkeeping requirements. The Collateral Duty Safety Program Coordinator will determine if an exposure incident is recordable.
d. Sharps Injury Log. In addition, all percutaneous injuries from contaminated
sharps are also recorded in the Sharps Injury Log as shown below. All incidents
will include at least: the date of the injury, the type and brand of the device
involved, the department or work area where the incident occurred, and an explanation
of how the incident occurred. The Bureau Industrial Hygienist will maintain
the sharps injury log and will review it at least annually as part of the annual
evaluation of the program. The log will be maintained for at least five years
following the end of the calendar year. If a copy is requested by anyone, it
will have any personal identifiers removed from the report.
Sharps Injury Log
Date of Injury
Device (sharp) used - type and brand
Office or Cost Center
Location where incident occurred
Explain how incident occurred
AED - automatic external defibrillator
BBP - Bloodborne Pathogens
CDC - Centers for Disease Control and Prevention
CDSPC - Collateral Duty Safety Program Coordinator
CFR - Code of Federal Regulations
HBV - hepatitis B virus
HCV - hepatitis C virus
HIV - human immunodeficiency virus
OSHA - Occupational Safety and Health Administration
OPIM - Other Potentially Infectious Materials - (1) The following human body fluids: 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; (2) Any unfixed tissue or organ (other than intact skin) from a human (living or dead); and (3) HIV-containing cell or tissue cultures, organ cultures, and HIV- or HBV-containing culture medium or other solutions; and blood, organs, or other tissues from experimental animals infected with HIV or HBV.
PPE - personal protective equipment
Universal Precautions - an approach to infection control. According to the concept of Universal Precautions, all human blood and certain human body fluids are treated as if known to be infectious for HIV, HBV, and other bloodborne pathogens.
USGS - United States Geological Survey