Bloodborne Pathogens Plan

Amniotic Fluid means the fluid surrounding the fetus during pregnancy.

Blood means human blood, human blood components, and products made from human blood.

Bloodborne Pathogens means pathogenic microorganisms that are present in human blood and can cause disease in humans. These pathogens include, but are not limited to, Hepatitis B Virus (HBV) Human Immunodeficiency Virus (HIV) and Hepatitis C Virus (HCV).

Cerebral Spinal Fluid means the fluid surrounding the brain and spinal cord. Contaminated means the presence or reasonably anticipated presence of blood or other potentially-infectious materials on an item or surface.

Contaminated Laundry means laundry which has been soiled with blood or other potentially infectious materials, or which may contain sharps.

Contaminated Sharps means any contaminated object that can penetrate the skin including, but not limited to, needles and broken glass.

Decontamination means the use of physical or chemical means to remove, inactivate or destroy bloodborne pathogens on a surface or item to the point where they are no longer capable of transmitting infectious particles and the surface or item is rendered safe for handling, use or disposal.

Engineering Controls means (e.g., sharps disposal containers, self-sheathing needles) that isolate or remove the bloodborne pathogens from the workplace.

Exposure Incident means a specific eye, mouth, other mucous membrane, non-intact skin, or parental contact with blood or other potentially infectious materials that result from the performance of an employee's duties.

Hepatitis A Virus (HAV) an acute but benign form of viral hepatitis caused by an RNA virus that does not persist in the blood serum and is usually transmitted by ingesting food or drink that is contaminated with fecal matter.

Hepatitis B Virus (HBV) is a virus which infects the liver resulting in cirrhosis, liver cancer or chronic liver disease. HBV can be transmitted through dried, caked blood on surfaces.

Hepatitis C Virus (HCV) a viral hepatitis clinically indistinguishable from hepatitis B but caused by a single-stranded RNA virus; usually transmitted by parenteral means as injection of an illicit drug or blood transfusion or exposure to blood or blood products

Human Immunodeficiency Virus (HIV) is a virus which attacks the body's immune system reducing its ability to fight disease (i.e. AIDS). HIV is not transmitted by coughing, sneezing, touching or using the same equipment, toilets, etc.

Needless Systems means a device that does not use needles for: (1) the collection of bodily fluids after initial venous or arterial access is established; (2) the administration of medication or fluids; (3) any other procedure involving the potential or occupational exposure to bloodborne pathogens due to injuries form contaminated sharps.

Occupational Exposure means reasonably-anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially-infectious materials that may result from the performance of an employee's duties.

Other Potentially-Infectious Materials (O.P.I.M.) means 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.

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

Regulated Waste means liquid or semi-liquid blood or other potentially-infectious materials; contaminated items that would release blood or other potentially-infectious materials in a liquid or semi-liquid state if compressed; items that are caked with dried blood or other potentially infectious materials and are capable of releasing these materials during handling; and contaminated sharps.

Sharps with Engineered Sharps Injury Protections (SESEP'S) means a non-needle sharp or a needle device used for withdrawing body fluids, accessing a vein or artery, or administering medications or other fluids, with a built-in safety feature or mechanism that effectively reduces the risk if an exposure incident.

Titer The measurement of the amount or concentration of a substance in a solution. Usually refers to the amount of medication or antibodies found in a patient's blood and serum.

Universal Precautions is a method of infection control which assumes all human blood and certain human body fluids to be infectious for HBV, HIV, HCV other bloodborne pathogens.

Work Practice Controls means controls that reduce the likelihood of exposure by altering the manner in which a task is performed.

All employees with an occupational exposure, including those who are expected to provide first aid as a part of their job tasks, will have an accessible copy of the Exposure Control Plan to minimize or eliminate exposures.  Under OSHA Bloodborne Pathogens standard, "Good Samaritan" acts such as a teacher assisting a fellow teacher or student with injury (e.g. nose bleed) are not covered.  In addition, those employees who receive first aid training but are not required to provide first aid as part of their job tasks are not covered.  Appendix D provides a sample log to be used when making exposure determinations.  When completed this log will be retained in the permanent record.

The following list represents job classifications which all employees have occupational exposure (Category 1).

• School Nurses
• Health Assistants
• Coaches / Team Trainers

The following list represents job classifications with some employees may have occupational exposure (Category 2).

• Special Education
• Physical Education Teachers / Coaches
• Janitors / Custodians
• Playground Attendants

Note: The St. Cloud School District shall identify additional job classifications within categories 1 and 2 relative to their specific organizational structure and operations.

Specific work tasks an procedures which may result in occupational exposure to some employees  in Category 2 include the following when a specific job description specifically includes any of these duties:

• Coaches / Team Trainers --- Response to broken bones, cuts, abrasions or other injuries where exposure to blood or other bodily fluids is likely.
• Physical Education Teachers --- Response to broken bones, cuts, abrasions or other injuries where exposure to blood or other bodily fluids is likely.
• Janitors / Custodians --- Cleaning of surfaces, contaminated with blood.  Disposal of contaminated sharps from the nurse's station (office) and bandages / towels with blood from the training and locker roo ms.
• Playground Attendants --- Response to accidents or injuries which requires administering first aid (i.e. cuts, abrasions).
• Special Education --- Regular, Special Education, Early Childhood and EL Teachers and related support staff (paraprofessionals) -Response to accidents or injuries which requires administrating first aid and provisions of personal care activities.

All other job classifications are considered to have no occupational exposure (Category 3).

The following practices and procedures will be implemented by the St Cloud School District to minimize or eliminate occupational exposures to job classifications in Categories 1 and 2.

A. Universal Precautions.

The concept of Universal Precautions requires the St Cloud School District to require its employees to assume all human blood and specified human body fluids are potentially infectious for HIV, HBV, HCV and other bloodborne pathogens. Consequently, St Cloud School District employees should avoid any unnecessary exposure to blood or other specified bodily fluids at all times.

B. Engineering and Work Practice Controls.

Engineering controls reduce or eliminate employee exposures by either removing or isolating the hazard or isolating the worker from exposure. The safety committee, to include a representation of 50% of the affected employees, shall be responsible for monitoring the effectiveness of engineering and work practice controls. The St Cloud School District shall implement and enforce the following engineering and work practice controls.—If an exposure incident takes place, complete the Occupational Exposure Incident Report immediately (Appendix E).

1. Employees with lesions, dermatitis or other compromising conditions shall take extra precaution to avoid direct contact with blood or other infectious materials. 
2. Eating, drinking, smoking or handling contact lenses are prohibited in areas where there is a reasonable likelihood of occupational exposure.
3. Employees will wash their hands and skin after gloves are removed with soap and water immediately or as soon as possible following contact with blood or other potentially infectious materials. Where hand washing facilities are not available, antiseptic hand cleaners or towelettes along with a clean cloth or paper towel, should be available. Employees should proceed to wash hands or skin with soap and water once available.
4. Employees will flush mucous membranes (eyes, nose, mouth) with water immediately or as soon as possible following contact with blood or other potentially infectious materials.
5. All first aid or other procedures involving blood or other potentially infectious materials will be performed in a manner which minimizes splashing or spattering of these substances.
6. Contaminated needles or other contaminated sharps will not be bent, recapped or removed. All contaminated sharps will be placed in specified safe needle devices or containers that are available in areas of anticipated use.  Disposal will be per district policy.  Filled sharps containers will be secured and transported to St. Cloud Hospital for proper disposal and exchange. (refer to Regulated Waste Management - Section H).
7. All broken glass will be deposited in a specified puncture-resistant container to avoid accidents (cuts) during storage and disposal. Mechanical means (i.e. broom and dust pan) should be used to clean up all broken glassware.
8. Equipment or surfaces, including the body fluid spill itself, which have been contaminated with blood or other potentially infectious materials, will be properly decontaminated as soon as possible, by following direction listed on an EPA registered disinfectant. Once properly disinfected the material(s) need not be red bagged or otherwise disposed of as contaminated.

C. Personal Protective Equipment

Personal protective equipment is used if occupational exposure remains after implementation of engineering and work practice controls, or if these controls are not feasible. Personal protective equipment is considered appropriate only if it does not permit blood or other potentially infectious materials to pass through the employees' clothes or come in contact with their skin, eyes, mouth or other mucous membranes under normal working conditions. Personal protective equipment shall be provided at no cost to the employee in appropriate sizes and be readily available. The following personal protective equipment and practices shall be implemented by the School District.

1. Gloves will be worn by the employee when contact with blood or other potentially infectious materials is likely. Disposable gloves will be replaced as soon as practical when visibly contaminated, torn or punctured. Disposable gloves will not be washed or decontaminated for re-use. Utility gloves may be decontaminated for re-use if the integrity of the gloves are not compromised (i.e. torn, cracked, deteriorated). Hands should be washed with soap and water upon removal of gloves.
2. Masks or protective eyewear (prescription glasses require solid side shields) will be worn when providing care that is likely to splash or spray blood or other potentially infectious materials.
3. Protective body clothing (i.e. gown, apron) will be worn by the school nurse or designated school staff when providing care likely to generate splashes of blood or bodily fluids. All employees with occupational exposures should replace blood-contaminated or soiled clothing with clean clothing as soon as possible. Skin which has come in contact with blood or other potentially infectious materials should be washed with soap and water as soon as possible.
4. Resuscitation bags or masks shall be made available to those responsible for providing cardiopulmonary resuscitation (CPR).
5. Personal protective equipment should be removed prior to leaving the work area.
6. Cleaning, repair, replacement or disposal of personal protective equipment will be provided at no cost to the employee.

Note: The employee may temporarily decline the use of personal protective equipment when he/she uses their judgment that its use would have prevented delivery of health care or it would have posed a greater safety hazard to the employee.

D. Housekeeping Practices

The St Cloud School District is responsible for maintaining a clean and sanitary environment. Actual types of cleaning and cleaning schedules vary relative to location, site activities and types of surfaces. The schedule for these activities shall be included as a part of this exposure control plan. The following are general housekeeping practices to be implemented by the St Cloud School District.

1. All equipment and environmental/working surfaces shall be cleaned and decontaminated after contact with blood or other potentially infectious materials as soon as possible. Special cleaning schedules and procedures within the nurse's station may be necessary.
   • A hospital-grade disinfectant registered with the Environmental Protection Agency is (EPA) recommended.  Re-juv-nal a Hillyard product can also be used on most surfaces.
2. Reusable items which become contaminated during the cleaning process shall be properly decontaminated with EPA Recommended products or a 24 hour fresh bleach solutions before putting them back into service.
3. Protective coverings used in the nurse's station which become contaminated shall be properly disposed of and replaced with a new, clean cover.
4. Any receptacles intended for re-use will be decontaminated on a regular basis or if visibly contaminated.
5. Broken glassware shall be cleaned up using mechanical means (i.e. brush and dust pan).
6. Contaminated sharps or needles shall be stored in a closeable, puncture-resistant container. Employees shall never reach their hands directly into the container.

E. Laundry Practices

The following laundry practices will be implemented by the St Cloud School District if they operate their own laundry facilities.

1. Staff will wear protective gloves and other appropriate personal protective equipment to prevent exposure to blood or other potentially infectious materials during the handling and sorting of soiled linen. Note: Laundry soiled with body fluids not included in the OSHA definition is not considered contaminated and requires no special handling. However, as a general practice, all laundry should be handled as little as possible (Universal Precaution).
2. All contaminated laundry and regulated waste shall be placed and transported in the appropriate bags (refer to Regulated Waste Management - Section H). Contaminated laundry which is wet should be stored or transported in containers which prevent leakage.
3. Laundry workers should not mix contaminated laundry with other laundry.
4. All contaminated laundry which is shipped off-site should be transported in the appropriately labeled/colored bags (refer to Regulated Waste Management - Section H).

F. Human Bites

Any St Cloud School District employee that receives a human bite during the course of their work duties, whereby the skin of the employee is broken from such a bite and the potential for exposure of blood exists, you are required to perform the following steps immediately.

1. It is important to follow Universal/Standard Hygiene procedures. Injured area must be cleansed with disinfectant soap (present in soap dispenser) for 15 to 30 seconds.
2. Complete the Occupational Exposure Incident Report (Appendix E).
3. Contact Midwest Occupational Medicine (MOM) at 320-251 -9675 to discuss the exposure incident and to provide the necessary treatment and consultation. You must take the completed Occupational Exposure Incident/Report with you to Midwest Occupational Medicine (MOM) located at 4544 County Road 134 (Hwy 15), St. Cloud.

G. Hepatitis B Vaccination

The OSHA Bloodborne Pathogens standard requires the St Cloud School District to offer all employees who are required to provide first aid (Category 1) or may have occupational exposure (Category 2), the hepatitis B vaccination series. This includes initial vaccination, post exposure evaluations and the potential need for a routine booster dose(s) if required. The standard does not require the St Cloud School District to offer the vaccination to other employees who are considered to have no exposure (i.e. those employees in Category 3  where first aid and personal activities are not a primary job task assigned) relative to their overall job tasks. Employees in category 1 should be checked for immunity or antigens by a titer within 1-2 months after the 3rd shot in the primary series. If immunity has not been achieved, the hepatitis B vaccine and vaccination series must be offered again or the non-immune individual must be referred to a physician for evaluation. Complete Appendix F or a similar log to support delivery of appropriate training and to maintain a record of vaccinations and retain as part of the permanent record.

The following procedures will be implemented by the St Cloud School District.

1. Specified employees who have occupational exposure will be provided, at no cost, the hepatitis B vaccination series, as well as post-exposure evaluation and follow-up procedures. Actual vaccination and follow-up procedures shall be performed under the supervision of a licensed physician or other licensed healthcare professional and provided in accordance with the recommendations of the U.S. Public Health Service. The healthcare professional will be provided with a copy of the Bloodborne Pathogens standard (29 CFR 1910.1030).
   Note: The hepatitis B vaccine is not required if the employee has previously received the complete hepatitis B vaccination series and antibody testing reveals the employee is immune or the vaccine is inadvisable for medical reasons. A hepatitis B prescreening program will not be a prerequisite for receiving the vaccination.
2. The hepatitis B vaccination will be available to specified employees within ten working days of initial assignment. Each employee receiving the vaccination must be informed on the following:efficacy of the vaccine;
   • safety of the vaccine;
   • method of administration;
   • benefits associated with the vaccine; and
   • acknowledgement of free vaccine and vaccination.
3. An employee who initially declines the hepatitis B vaccination will be allowed to receive the vaccination at a later time. All employees who decline the hepatitis B vaccination made available will be required to sign the Employee Hepatitis B Vaccine Declination form (Appendix C).
4. The St Cloud School District shall offer the hepatitis B vaccination to all unvaccinated employees required to provide first aid as a collateral duty who have rendered first aid in any situation involving the presence of blood or other potentially infectious materials (regardless of whether an actual exposure incident occurred). The vaccination should be made available as soon as possible, but in no event later than 24 hours.

H. Regulated Waste Management

The following procedures will be implemented by the St Cloud School District to comply with federal and state (Minnesota) requirements for regulated infectious wastes.  Decontamination is the preferred method.

Decontamination:

1. Use a fluid control solidifier, sprinkle evenly over spill and remove solidified material with  scoop and scraper, according to manufacturer’s instructions.  Since materials have been   decontaminated they may be disposed of with the general trash for disposal.

Containment:

1. All regulated waste (blood or contaminated items) will be placed in properly labeled containers which prevent any leakage during the collection, handling, processing, storage, transport or shipping.
2. A properly labeled secondary container will be used if outside contamination of the primary container occurs. If waste items can puncture the primary container, the primary container will be placed within a secondary container which is puncture-resistant.
3. Contaminated sharps and needles will be immediately discarded in a closeable, puncture resistant, leak-proof container or safe needle device. The sharps container will be readily accessible to personnel and located as close as possible to the area of use (preferably located centrally in the nurse's station).
4. The sharps' containers will be maintained upright, replaced routinely and not be overfilled at any time. A regular schedule for emptying these containers will be implemented and be considered to be a part of this exposure control plan. The containers will be closed prior to removal to avoid any spillage. Reusable containers will not be emptied or cleaned manually to avoid any "stick" exposures to the skin.
5. The St Cloud School District shall store all regulated (contaminated) waste in a secure area.

Note: OSHA does not consider typical band-aids or feminine hygiene products to be considered regulated waste. Janitors/custodians are recommended to apply Universal Precautions when disposing of feminine hygiene products to avoid any unnecessary direct skin contact. In addition, de-contamination of any visible blood contamination in the receptacle may be required.

Labeling

1. Containers of regulated waste will be labeled with the Biohazard symbol and the wording "Biohazard" (refer to Figure 1). The Biohazard label will be fluorescent orange or orange red in color with the lettering in contrasting colors. The labels will be affixed so as to avoid their loss or unintentional removal.
   
   Figure 1. Biohazard Symbol
    
2. Red bags or red containers may be substituted for the Biohazard label. If Universal Precautions are utilized, the labeling/color-coded system is not necessary provided the containers are recognizable and treated as containing regulated waste. However, all regulated waste leaving the facility must be properly labeled or color-coded.

Disposal

1. Documented disposal of regulated waste must be done at least annually at a Minnesota Pollution Control Agency (MPCA) approved landfill or medical incinerator. Disposal of regulated waste at a sanitary landfill is not permissible unless the waste is first deemed "noninfectious." The St Cloud School District will not mix regulated (hazardous) waste with other waste.
2. All regulated waste shall be transported per Minnesota Department of Health, Department of Transportation and MPCA requirements. All shipments will be manifested accordingly.

The St Cloud School District is required to immediately provide a post-exposure evaluation and follow-up for employees who have had an occupational exposure to blood or other potentially infectious materials. The following protocol will be followed by the St Cloud School District for providing post-exposure evaluations and follow-up. Appendix G includes a flow chart of required follow-up activities.

1. All employees (Categories 1 and 2) shall immediately report an occupational exposure to the St Cloud School District or direct supervisor. In addition, all employees (Category 3) who render first aid where blood or other potentially infectious materials were evident (regardless of whether an exposure incident occurred) shall immediately report the incident to the St Cloud School District or direct supervisor. The St Cloud School District will make available a confidential medical evaluation and follow-up of the incident with a licensed healthcare professional.
   Note: The School District will record the event on the OSHA 300 Log of Occupational Injuries and Illnesses and OSHA 301 Supplementary Record of Occupational Injuries and Illnesses, if applicable.
2. Affected employee(s) shall be provided with space on the incident reporting form to render an opinion on how to minimize or reduce future such exposures or incidents and to offer an opinion on the possible impact of engineering controls to reduce such exposures or incidents.
3. The St Cloud School District's designated individual will document the circumstances under which the exposure occurred (or potential exposure in cases where first aid was provided), including the routes of exposure, the HBV, HIV or HCV status of the source patient(s), if known, and the employee's hepatitis B vaccine status. A copy of the OSHA Bloodborne Pathogen's standard and the above information collected upon review of the incident will be provided to the healthcare professional.
4. Within twenty four hours the St Cloud School District (administrator or licensed school nurse) will notify the source individual(s) of the incident and attempt to obtain written consent to collect and test the source's blood to determine the presence of HBV, HIV and/or HCV infectivity. If the source individual is known to be infected with HBV, HIV or HCV testing of the source individual is not required.
5. If consent is received, the results of the source individual's testing will be made available directly to the exposed employee through their healthcare provider. All applicable laws and regulations concerning disclosure of the identify and infectious status of the source individual will be available.
6. The exposed worker's blood will be collected as soon as feasible and tested upon written consent being obtained for determination of HBV, HIV and/or HCV status. In addition, the St Cloud School District may be required to provide repeat HIV testing to the exposed employee on a periodic basis thereafter depending on the healthcare professional's opinion.
7. Follow-up on the exposed worker will include counseling, medical evaluation of any acute illness that occurs, post-exposure prophylaxis and other post-exposure methods according to recommendations for standard medical practices.
8. The healthcare professional will submit a written opinion to the St Cloud School District documenting that the employee was informed of the evaluation results and the need for any further follow-up and whether the hepatitis B vaccine was received.
9. The St Cloud School District will provide a copy of the healthcare professional's written opinion to affected employee within 15 days of completed evaluation.

The St Cloud School District will mandate and provide training to all identified employees (Categories 1 and 2) with potential occupationally exposures to blood and other potentially infectious materials. This training will be conducted annually during normal work hours by a trainer knowledgeable on the subject matter. The training requirements include the following.

1. Training will be provided before an initial assignment to a task involving a potential occupational exposure.
2. Additional training will be provided by the St Cloud School District when any new tasks or modifications of procedures affect the employee's occupational exposure.
3. The training program shall include the following components:
   • information on how to access the OSHA Bloodborne Pathogen's standard;
   • routes of exposure and symptoms of bloodborne pathogens;
   • copy and explanation of the Exposure Control Plan;
   • methods for identifying tasks which may involve exposure to blood or other potentially infectious materials.
   • overview of engineering controls, work practices and personal protective equipment;
   • information on hepatitis B vaccine (refer to hepatitis B vaccination - Section G).
   • emergency procedures and notification requirements;
   • incident reporting;
   • post-exposure evaluation and follow-up; and
   • explanation of labels and color-coding system requirements.

Employee training records are provided upon request to the employee or the employee's authorized representative within 15 working days. Such request should be addressed to the bloodborne pathogen coordinator.

A. Training Records

The St Cloud School District is required to document and maintain training records for three years subsequent to the initial training date. Training records shall include the following:

• Date of the training session(s)
• Summary of the training topics discussed.
• Name and qualifications of trainer(s)
• Names and titles of all school employees who attended the training session (refer to Appendix B)

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 Supervisor of Environmental Health & Safety.

B. Medical Records

The St Cloud School District is required to maintain an accurate record for each employee with occupational exposure as specified in 29 CFR 1910.1030(Cv2) Access to Employee Exposure and Medical Records. Medical records are to remain confidential and shall be maintained for the duration of employment plus 30 years. The medical records relative to the Bloodborne Pathogen's standard shall include the following:

• Employee name and social security number.
• Hepatitis B vaccination status and dates.
• Results of evaluations and follow-up procedures.
• The St Cloud School District's copy of the healthcare professional's written opinion.
• Copy of the information provided to the healthcare professional by the St Cloud School District.

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 Supervisor of Environmental Health & Safety.

C. OSHA Recordkeeping

An exposure incident is recordable on the OSHA 300 Log if the case meets OSHA's Recordkeeping Requirements (29 CFR Part 1904). This determination and the recording activities are done by the Supervisor of Environmental Health & Safety.

D. Sharps Injury Log

In addition to the OSHA's 1904 Recordkeeping Requirements, all percutaneous injuries from contaminated sharps are also recorded in the sharps injury log (See Appendix J). All incidents must include at least:

• The date of injury
• The type and brand of the device involve;
• The department or work area where the incident occurred
• An explanation of how the incident occurred.

This log is reviewed at least annually as part of the annual evaluation of the program and is maintained for at least five years following the end of the calendar year that they cover. If a copy is requested by anyone, it must have any personal identifiers removed from the report.