What To Do In Case Of Bloodborne Pathogens
On December 6, 1991, the Occupational Safety and Health Administrations (OSHA) issued an order regulating occupational exposure to bloodborne pathogens (29CFFR 1919.1030. OSHA determined that employees face a significant health risk as a result of occupational exposure to blood and other body fluids because these materials ma contain microscopic organisms that can cause disease. These pathogens include Hepatitis B and C viruses (HBV and HCV) which cause serious liver diseases and Human Immunodeficiency Virus (HIV) which cases Acquired Immunodeficiency Syndrome (AIDS). OSHA concluded that this hazard can be minimized or eliminated using a combination of engineering controls, work practice controls, personal protective clothing and equipment, training, medical surveillance, Hepatitis B vaccination, signs, labels, and other provisions.
The California version of the bloodborne pathogen legislation became effective on January 8, 1993. The text of the law can be found in Section 5193 of Title 8 of the California Code of Regulations (8CCR 5193). The following exposure control plan has been developed in accordance with the Cal/OSHA Bloodborne Pathogen Standard.
Any student, staff, or faculty in any division or department who may come in contact with blood or body fluids must observe the Center for Disease Control (CDC) and Cal-OSHA guidelines. In addition, those Cabrillo College divisions and departments which have a greater exposure to body fluids shall incorporate operational procedures and guidelines to meet problems and challenges resulting from the HIV, HBV and HCV epidemics specific to their areas. These guidelines or procedures shall be developed in consultation with local health officials and shall conform with existing law, District policy, CDC Guidelines regarding Universal Precautions, and OSHA requirements on bloodborne Pathogens (8 CCR § 5193). In order to provide consistency and continuity, the Vice President of Business, and the Dean of Student Services will review these division and department guidelines prior to adoption.
Cabrillo College shall review and update the Exposure Control Plan at least annually and whenever necessary as follows:
- To reflect new or modified tasks and procedures which affect occupational exposure;
- To reflect changes in technology that eliminate or reduce exposure to bloodborne pathogens and to document consideration and implementation of appropriate commercially available needleless systems and needle devices and sharps with engineered sharps injury protection;
- To include new revised employee positions with occupational exposure;
- To review and evaluate the exposure incidents which occurred since the previous update;
- To review and respond to information indicating that the Exposure Control Plan is deficient in any area;
- The employer shall solicit input from non-managerial employees responsible for direct patient care who are potentially exposed to injuries from contaminated sharps in the identification, evaluation, and the election of effective engineering and work practice controls, and shall document the solicitation in the Exposure Control Plan;
- The Exposure Control Plan shall be made available to the Chief or NIOSH or their respective designee upon request for examination and copying;
- The Exposure Control Plan will be accessible to all employees.
The person in charge of the Cabrillo College Exposure Control Plan is the Vice-President of Business.
- A bloodborne pathogen is a pathogenic microorganism present in human blood that can cause disease in humans. These pathogens include, but are not limited to Hepatitis B Virus [HBV], Hepatitis C Virus [HCV], and Human Immunodeficiency Virus [HIV].
- Means human blood, human blood components and products made from human blood.
- A titer is a semi-quantitative (volume to volume) measurement. For the purpose of this policy, the term "blood titer" refers to the indirect measurement of blood levels of the Hepatitis B antibody, through a measurement of the Hepatitis B surface antigen.
- The presence, or the reasonably anticipated presence, of blood or other potentially infectious materials on an item or surface.
- This means laundry, which has been soiled with blood or other potentially infectious materials, or may contain sharps.
- 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.
Designated First Aid Provider
- For the purpose of this policy, these are the individuals who are required to provide first aid in emergency situations as a condition of their employment. These individuals may perform this function as a primary duty (e.g. life guard), or as a duty incidental to other duties (e.g. day care providers).
- Controls [e.g., sharps disposal containers, needless systems and sharps injury protection] that isolates or remove the bloodborne pathogen hazard from the workplace.
- A specific eye, mouth, other mucous membrane, non-intact skin, or parenteral contact with blood or other potentially infectious materials that results from the performance of an employee's duties.
- A facility providing an adequate supply of running, potable water, soap and single use towels or hot air drying machines.
- Hepatitis B Virus.
- Hepatitis C Virus.
- Human Immunodeficiency Virus.
- Hepatitis B Virus.
- A reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance from an employees duties.
Other Potentially Infectious Materials (OPIM)
- This means certain human body fluids: semen, vaginal secretions, cerebrospinal fluid, synovial fluid, pleural fluid, peritoneal fluid, amniotic fluid, saliva in dental procedures, and 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. It also includes any unfixed tissue or organ (other than intact skin) from a human (living or dead) and HIV-containing cell or tissue cultures, organ cultures, and HIV- HBV- or HCV-containing culture medium or other solutions; and blood, organs, or other tissues from experimental animals infected with HIV, HBV or HCV.
- Piercing mucous membranes or the skin barrier through such events as needle sticks, human bites, cuts, and abrasions.
Personal Protective Equipment
- A specialized clothing or equipment worn or used by an employee for protection against a hazard.
- A waste that is any of the following:  liquid or semi-liquid blood, or OPIM,  contaminated items that [a] contain liquid or semi-liquid blood, or are caked with dried blood or OPIM and [b] are capable of releasing these materials when handled or compressed and  contaminated sharps.
- For the purpose of this policy, the term used to describe the results of blood testing to determine whether an individual has measurable levels of the Hepatitis B Virus or the Human Immunodeficiency Virus. A "positive" serologic status means the person has measurable blood levels of virus; a "negative" serologic status means the individual has not. A person who "seroconverts" changes from a negative to a positive status.
Sharps and Contaminated Sharps
- A "sharp" is any object that can readily penetrate the skin, including, but not limited to, broken glass, needles, scalpels, broken capillary tubes, and exposed ends of dental wires. For the purpose of this policy, the definition of "contaminated sharps" is limited to those contaminated with blood or other potentially infectious materials.
- Any injury caused by a sharp, including, but not limited to, cuts, abrasions or needle sticks.
Sharps Injury Log
- A written or electronic documentation log.
This is an approach to infection control whereby all human blood and certain human body fluids are treated as if known to be infectious for HIV, HBV, HCV and other bloodborne pathogens.
II. Exposure Determination
Any member of the student body, staff, or faculty of Cabrillo College with occupational exposure to blood or other potentially infectious materials is covered by the Exposure Control Plan. Potentially infectious materials include the following human body fluids: blood, 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.
Occupational exposure is defined by Cal/OSHA as "reasonable anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that my result from the performance of an employee's duties." parenteral means piercing mucous membranes or the skin barrier through such events as needlesticks, human bites, cuts and abrasions. Further, to be considered "occupational exposure," under the standard, the contact must result from the performance of an employee's duties.
The Cal/OHSA Bloodborne Pathogens Rule does not cover Students, since an employer – employee relationship must exist between the parties. However, it is the mission of Cabrillo College to provide students with adequate training so they may pursue their studies and eventually their career safety and knowledgeably. Therefore, the College has identified those curricula which involve reasonably anticipated exposure of students to blood or other potentially infectious materials. The use of blood must be evaluated in light of its risk to student and the fulfillment of each departments academic mission. When possible, alternatives to the use of blood and other potentially infectious materials must be adopted. Alternatives include the use of non-infectious animal blood, synthetic blood or computer simulations.
OSHA has established three (3) exposure categories for protection against occupational exposure to infectious diseases including HBV, HCV and HIV infections. These categories are as follows:
Category I: Tasks that involve exposure to human blood, body fluids, or tissues:
All procedures or other job-related tasks that involve an inherent potential for mucous membrane or skin contact with human blood, body fluids, or tissues, OR a potential for spills or splashes of them are Category I tasks. Use of appropriate personal protective equipment will be required for every employee engaged in Category I tasks
Category II: Tasks that involve no exposure to human blood, body fluids, or tissues but employment may require performing unplanned Category I tasks.
The normal work routine involves no exposure to blood, body fluids, or tissues, BUT exposure or potential exposure may be required as a condition of employment. Appropriate personal protective equipment will be readily available to every employee engaged in Category II tasks.
Employees may be considered "designated first-aid providers." Designated first-aid providers may run a risk of occupational exposure, however, this risk arises in the context of the performance of a "collateral" duty, and is not performed on a regular basis.
Note: Cabrillo College is not required to provide pre-exposure Hepatitis B vaccinations to designated first-aid providers. However, unvaccinated, designated first-aid providers must be offered the Hepatitis B vaccination series no later than 24 hours after rendering assistance in any situation involving the presence of blood or infectious material, regardless of whether an "occupational exposure" has occurred. Designated first-aid providers are also subject to reporting requirements.
Category III: Tasks that involve no exposure to human blood, body fluids or tissues, AND Category I tasks are not a condition of employment
The normal work routine involves no exposure to human blood, body fluids or tissues (although situations may be imagined or hypothesized under which anyone, anywhere, might encounter potential exposure to body fluids). Persons who perform these duties are not called upon as part of their employment to perform or assist in emergency medical care or first aid or to be potentially exposed in some other way.
With regards to "Good Samaritan", the Cal/OSHA regulations do not cover the exposure of an employee to blood or infectious material where that exposure was not related to the performance of job duties, or collateral job duties.
In identifying the job classification, Cabrillo College must specify the job tasks and procedures in which occupational exposure is reasonably anticipated to occur. These job classifications and related job tasks and procedures are identified in Appendix A – Job Classifications in Which Employees Have Occupational Exposure to Bloodborne Pathogens." The "Exposure Determination Worksheet" also provided in Appendix A, or an equivalent form shall be used in initially determining positions subject to exposure.
The following Employee Job Descriptions have been categorized according to the exposure Categories:
Children Center and Early Childhood Education
Children Center Teachers – Category I
Child Care Specialists and Temporary/Hourly Employees – Category II
Early Childhood Education Instructors – Category II
Director of Children's Center – Category II
Culinary Arts & Hospitality Management Instructor – Category II
Instructional Assistant I/II (Culinary Arts) – Category II
Adaptive PE Instructors – Category II
Allied Health Instructors – Category I
Athletic Equipment Specialists I/II – Category II
Athletic Trainer – Category II
Dental Hygiene Instructors – Category I
Health Science Instructors – Category I
LIA's in Nursing Education – Category I
Lifeguards – Category I
Medical Assisting Instructors – Category I
Nursing Education Instructors – Category I
PE Instructors – Category II
Pool Maintenance Worker – Category II
Radiology Technology Instructors – Category I
Therapeutic Learning Disabled Aides – Category II
Science Laboratory Technicians (Biology) – Category II
Science Laboratory Technicians (Chemistry) – Category II
Biology, Physiology, Anatomy and Chemistry Instructors – Category II
Facilities Planning & Plant Operations (FP&PO)
Custodial Supervisor – Category I
Custodian I/II – Category I
Lead Custodian – Category I
FP&PO Director – Category II
FP&PO Assistant Director – Category II
Maintenance Technicians – Category I
Maintenance Worker – Category I
Pool Maintenance Worker – Category I
Senior Maintenance Worker – Category I
Utility Maintenance Worker – Category i
Instructional Assistant I/II – Category II
Stroke Center Instructors – Category II
Stroke Center Program Specialists I/II – Category II
Temporary Instructors – Category II
Student Health Center
Adaptive PE Instructors – Category II
Clinical Nurses – Category I
Director – Category I
Nurse Practitioners – Category I
Program Specialists I/II – Category II
Note: It is during the initial orientation process, that the individual is placed into one of the three exposure categories and the appropriate acknowledgment form found in Appendix A is filled out.
In addition, the exposure determination worksheet completed by the personnel dept. is found in Appendix B.
III. Hepatitis B – Vaccination Program
Hepatitis B is a type of viral hepatitis acquired from exposure to human blood and body fluids that results in liver inflammation. While the use of universal precautions helps in the protection from Hepatitis B, the Hepatitis B vaccine is an additional measure offered to all employees in Category I and Category II free of charge through the college.
- As part of the initial orientation process through the Personnel Dept., education and training will be provided regarding the Hepatitis B vaccine. This can occur by way of handouts, videos, and/or presentation. All associated training records must be maintained for a minimum of 3 years from the date on which the training occurred.
Once an employee is sent to his/her designated department, a more structured and formalized training occurs. At this time, the employee will give a copy of their signed acknowledgment form to their supervisor, who in turn is responsible for the appropriate record keeping. At a minimum, this training will include efficacy, safety, method of administration, benefits of being vaccinated, and the fact that the vaccine is available at convenient times in-house at no charge to any employee where occupational exposure may take place.
This training will be provided during working hours at no cost to the employee by a health care or safety professional knowledgeable in the subject matter as it relates to the workplace.
- Following the required training, all employees in Category I and Category II will be offered the Hepatitis B vaccine, free of charge, within 10 working days of initial assignment unless the employee has previously received the complete Hepatitis B vaccination series and antibody testing has revealed that the employee is immune or if the vaccine is contraindicated for medical reasons (e.g. allergic to yeasts). Refer to Appendix C – Employees Eligible for Hepatitis B Vaccination Form.
- All employees offered the Hepatitis B vaccine would complete the Consent Form. Once completed, the Consent Form shall be placed in the employee's permanent record. It is recommended that a copy of the form be kept in the departmental records as well as in the Personnel Office. Refer to Appendix D – Initial Hepatitis B Consent Form.
- For those desiring the Hepatitis B vaccine, an Employee Immunization Record will be maintained until each of the 3 steps of the vaccination process is complete. (Initial, 30 days from initial and 6 months from initial.) Refer to Appendix E – Immunization Record.
- Once the series is complete, the Immunization Record will become part of the employee's permanent record.
- Vaccines will not be provided for employees that are no longer employed by the College. Employees may choose not to complete the series of 3 inoculations. If an employee leaves the College's employment, they will not receive initial or subsequent inoculations. If the series is not completed, the reason and the employee's signature must be written on the Immunization Record.
- An employee may initially decline the Hepatitis B vaccine, but at a later date may decide they want the vaccination. If this occurs, the employee must complete a new Consent form and steps 3-6 of this procedure must be followed. Refer to Appendix F – Vaccination Declination Form.
- If a routine booster dose(s) of Hepatitis B vaccine is recommended by the U.S. Public Health Service at a future date, the booster dose(s) will be made available, free of charge to the employee.
- The Hepatitis B vaccine must be performed by or under the supervision of a licensed physician, or under the supervision of another licensed healthcare professional.
An employee who experiences an exposure incident must cease work and report it immediately to her/his supervisor, even if the employee does not feel the exposure poses a risk for contracting bloodborne disease. The supervisor, together with exposed employee, must immediately fill out the "Employer's First Report of Injury or Disease" and an "Occupational Accident and Injury" form. The supervisor does not have the discretion to deny the employee's ability to report the incident. The Supervisor immediately refers the employee to an attending physician. Refer to Appendix G – Occupational Exposure "Incident Report Form".
Following a report of an exposure incident, Cabrillo College will immediately make available a confidential medical evaluation and follow-up, to include at least the following:
- Documentation of the route(s) of exposure and the circumstances under which the exposure incident occurred.
- Identification and documentation of the source individual, unless the College can establish that identification is infeasible or prohibited by state or local law. Refer to Appendix H – Record of Bloodborne Pathogens Exposure and Treatment.
After consent is obtained, the source individual's blood will be tested as soon as feasible in order to determine HBV, HCV and HIV infectivity. If consent is not obtained, the College will establish that the legally required consent cannot be obtained. When the source individual's consent is not required by law, the source individual's blood, if available, shall be tested and the results documented. Refer to Appendix I – Source Individual Consent Form.
Note: When the source individual is already known to be infected with HBV, HCV or HIV, testing for the source individual's known HBV, HCV or HIV status need not be repeated.
Results of the source individual's testing will be made available to the exposed employee, and the employee will be informed of applicable laws and regulations concerning disclosure of the identity and infectious status of the source individual. Refer to Appendix J – Authorization for Disclosure Forms.
The exposed employee's blood will be collected as soon as feasible and tested after consent is obtained. Typical scenarios for HBV testing (HIV testing covered under HIV policy) may include the following.
- Source individual's HBV status is unknown and the exposed employee has had the complete Hepatitis B vaccination series. The source individual should be tested as soon as feasible to determine HBV status and the exposed employee should be tested as soon as feasible to establish appropriate immunization level.
- Source individual is known to be HBV positive and the exposed employee has had the complete Hepatitis B vaccination series. A repeat test on the source individual is not necessary, but the exposed employee should be tested as soon as feasible to establish appropriate immunization level.
- Source individual's HBV status is unknown and the exposed employee has either not received or completed the Hepatitis B vaccination series. The source individual should be, as soon as feasible, tested to determine HBV status and the exposed employee should be tested to establish baseline and again six (6) weeks post exposure, twelve (12) weeks post exposure and six (6) months post exposure to determine seroconversion.
- Source individual is known to be HBV positive and the exposed employee has either not received or completed the Hepatitis B vaccination series. The source individual need not be tested, but the exposed employee should be tested as soon as feasible to establish baseline and again six (6) weeks post exposure, twelve (12) weeks post exposure and six (6) months post exposure to determine seroconversion.
If the employee consents to baseline blood collection, but does not give consent at that time for HIV serologic testing, the sample shall 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 shall be done as soon as feasible.
Post-exposure prophylaxis, when medically indicated, as recommended by the U.S. Public Health Service includes counseling and the evaluation of reported illnesses.
Cabrillo College will ensure that the healthcare professional evaluating an employee after an exposure incident is provided with the following information:
- A description of the exposed employee's duties as they relate to the exposure incident.
- Documentation of the route(s) of exposure and the circumstances under which the exposure occurred.
- Results of the source individual's blood testing, if available.
- All medical records relevant to the appropriate treatment of the employee including vaccination status.
Cabrillo College will obtain and provide the employee with a copy of the evaluating healthcare professional's written opinion within 15 days of the completion of the evaluation. The healthcare professional's written opinion for Hepatitis B vaccination shall be limited to whether Hepatitis B vaccination is indicated for an employee, and if the employee has received such vaccination.
The healthcare professional's written opinion for post-exposure evaluation and follow- up shall be limited to include only that the employee has been informed of the results of the evaluation and that the employee has been told about any medical conditions resulting from exposure to blood or other potentially infectious materials which require further evaluation or treatment. All other findings or diagnoses shall remain confidential and shall not be included in the written report.
In keeping with these principles, the following shows the recommended campus wide procedure to use for initiating post-exposure follow-up.
IV. Methods of Compliance
To protect employees against exposure to human bloodborne pathogenic diseases the following exposure control steps will be undertaken. First, "Universal Precautions" will be observed to prevent contact with blood or other potentially infectious materials. Second, engineering and work practice controls will be followed to prevent contact with potentially infectious materials. Third, specimens and equipment will be handled under strict guidelines. Finally, a hazard communication procedure will be followed to alert all employees to the possibility that pathogenic materials are present.
Universal Precautions is an approach to infection control which assumes that all human blood and certain body fluids are treated as if known to be infectious for HIV, HBV, HCV and other bloodborne pathogens. Universal Precautions shall be consistently used for all individuals.
In the school setting, precautions shall include: handwashing, using gloves and other appropriate protective equipment, careful trash disposal, and using disinfectants. Universal precautions shall be used within the school setting at all times to prevent contact with blood or other potentially infectious materials.
All procedures involving blood or other body fluids shall be performed in such a manner as to minimize splashing, spraying, splattering, and generation of droplets of these substances.
Engineering controls refers to controls which isolate or remove the bloodborne pathogens from the workplace [i.e., sharps disposal containers]. Work practice controls that reduce the likelihood of exposure by altering the manner in which a task is performed.
Engineering and work practice controls will be used to eliminate or minimize employee exposure. Where occupational exposure remains after institution of these controls, personal protective equipment will also be used. Engineering controls shall be examined and maintained or replaced on a regular schedule to ensure their effectiveness. Work practice controls shall be evaluated and updated on a regular schedule to ensure their effectiveness.
Thorough handwashing is the single most effective means in preventing the spread of infectious diseases and should be practiced routinely by all school personnel and taught to students as routine hygienic practices.
Employers shall provide handwashing facilities, which are readily accessible to employees.
- Employers shall ensure that employees wash their hands immediately or as soon as feasible after removal of disposable gloves or other personal protective equipment;
- Employers shall ensure that employees wash hands and other skin with soap and water, or flush mucous membranes with water immediately or as soon as feasible following contact of such body areas with blood or OPIM.
- When provision of handwashing facilities is not feasible, the employer shall provide either an appropriate antiseptic hand cleanser in conjunction with clean cloth/paper towels or antiseptic towelettes. When antiseptic hand cleansers or towelettes are used, hands shall be washed with soap and potable water as soon as feasible;
Work Area Restrictions:
- Eating, drinking, smoking, applying cosmetics or lip balm, and handling contact lenses are prohibited in work areas where there is a reasonable likelihood of occupational exposure.
- Food and drinks will not be kept in refrigerators, freezers, shelves, cabinets, counter tops, or bench tops where blood or other potentially infectious materials are present.
- Mouth pipetting or suctioning of blood or other potentially infectious materials is prohibited.
Exact procedures will depend upon Departmental activities and needs. In general, the following principles established by OSHA should be followed:
01 General Requirements
- Employers shall ensure that the worksite is maintained in a clean and sanitary condition.
- Employers shall determine and implement appropriate written methods and schedules for cleaning and decontamination of the worksite.
- The method of cleaning or decontamination used shall be effective and shall be appropriate for the:
- Location within the facility;
- Type of surface or equipment to be treated;
- Type of soil or contamination present; and
- Tasks or procedures being performed in the area.
- All equipment and environmental work surfaces shall be cleaned and decontaminated after contact with blood or OPIM [Other Potentially Infectious Materials] no later than at the end of the shift. Cleaning and decontamination of equipment and work surfaces is required more often as specified below.
2. Specific Requirements.
- Contaminated Work Surfaces. Contaminated work surfaces shall be cleaned and decontaminated with an appropriate disinfectant immediately or as soon as feasible when:
- Surfaces become overly contaminated;
- There is a spill of blood or OPIM;
- Procedures are completed; and
- At the end of the work shift, if the surface may have become contaminated since the last cleaning.
- Receptacles. All bins, pails, cans, waste baskets and similar receptacles intended for reuse which have a reasonable likelihood for becoming contaminated with blood or OPIM shall be inspected and decontaminated as necessary and cleaned and decontaminated immediately or as soon as feasible upon visible contamination.
- Protective Coverings. Protective coverings, such as plastic wrap, aluminum foil, or imperiously backed absorbent paper used to cover equipment and environmental surfaces, shall be removed and replaced as soon as feasible when they become overtly contaminated or at the end of the workshift if they may have become contaminated during the shift.
Cabrillo College, through its employing departments, will ensure that worksites involving bloodborne pathogenic materials are maintained in a clean and sanitary condition. For example, the Health Services, Nursing, Dental Hygiene and Medical Assisting Departments and all laboratories utilizing blood and other potentially infectious materials, shall prepare written schedules (e.g. infection control plans). These plans refer to the cleaning and method of decontamination based upon the location in the facility, type of surface to be cleaned, and tasks or procedures being performed in the area. The schedule shall be followed and it shall be made accessible to employees .
Contaminated work surfaces will be decontaminated with an appropriate disinfectant after completion of a procedure, immediately, or as soon as feasible when surfaces are overtly contaminated, or after any spill of blood or other potentially infectious materials; and at the end of the work shift if the surface has become contaminated since the last cleaning.
Broken glassware which may be contaminated shall not be picked up directly with the hands. It shall be cleaned up by mechanical means, such as brush and dustpan, tongs or forceps and be disposed of in an appropriate sharps container.
Laundry contaminated with blood or other potentially infectious materials [including, athletic uniforms and towels] should be handled as little as possible with a minimum of agitation. Contaminated laundry will be bagged or containerized at the location where it was used and shall not be sorted or rinsed in the location of use. The contaminated laundry will then be placed and transported in bags or containers labeled as " BIOHAZARD" or color-coded (red).
When Universal Precautions are utilized in the handling of all soiled laundry, alternative labeling or color-coding is sufficient, if it permits all employees to recognize the containers as requiring compliance with Universal Precautions. Whenever contaminated laundry is wet and presents a reasonable likelihood of soak- through of or leakage from the bag or container, the laundry shall be placed and transported in bags or containers which prevent soak-through and/or leakage of fluids to the exterior.
Cabrillo College will ensure that employees who have contact with contaminated laundry wear protective gloves and other appropriate personal protective equipment.
If the College ships contaminated laundry off-site to a second facility which does not utilize Universal Precautions in the handling of all laundry, the facility generating the contaminated laundry must place such laundry in bags or containers which are labeled biohazardous or color-coded (red).
Shearing or breaking of contaminated needles and other contaminated sharps is prohibited. Contaminated sharps shall not be bent, recapped, or removed from devices. EXCEPTION: Contaminated sharps may be bent, recapped or removed from devices if: The employer can demonstrated that no alternative is feasible or that such action is required by a specific medical or dental procedure; and the procedure is performed using a mechanical device or a one handed technique.
Immediately or as soon as possible after use, contaminated reusable sharps will be placed in appropriate containers until properly reprocessed. These containers must be puncture resistant, labeled biohazard or color-coded, leakproof on the sides and bottom and shall not be stored or processed in a manner that requires employees to reach by hand into the container where the sharps have been placed.
Disposable contaminated sharps will be discarded immediately or as soon as feasible in containers that are closable, puncture resistant, leakproof on the sides and bottom and labeled "BIOHAZARD" or color-coded. During use, containers for contaminated sharps will be easily accessible to personnel and located as close as feasible to the immediate areas where sharps are used or can be reasonably anticipated to be found; maintained upright throughout use and replaced routinely.
When moving containers of contaminated sharps from the area of use, the container must be closed immediately prior to removal or replacement to prevent spillage or protrusion of contents during handling, storage, transport, or shipping. If leakage is possible, a secondary container must be used. The second container must be closable, constructed to contain all contents and prevent leakage during handling, storage, transport or shipping and be labeled "BIOHAZAR", Reusable containers shall not be opened, emptied or cleaned manually, or in any other manner that would expose employees to the risk of percutaneous injury.
Note: When a sharps container is filled, the department has seven  days in which to dispose of the contents. If not disposed of in the allotted time frame, a violation of the Medical Waste Management Act has occurred.
To prevent needle stick injuries, contaminated needles or other sharps must not purposely be bent, sheared, broken, recapped, removed from disposable syringes, or otherwise manipulated by hand. They shall only be disposed of in sharps containers.
All health care workers and emergency response personnel shall take precautions to prevent injuries caused by needles, scalpels, and other sharp instruments during procedures; when cleaning used instruments or during disposal of used needles; and when handling sharp instruments after procedures. After use, disposable syringes and needles, scalpel blades, and other sharp items shall be placed in puncture-resistant sharps containers for disposal. The puncture-resistant container should be located as close as practical to the use area and identified as biohazardous.
The employer shall establish and maintain a sharps injury log, which is a record of each exposure incident involving a sharp. The information recorded shall include the following information, if known or reasonably available.
- Date and time of the exposure incident;
- Type and brand of sharp involved in the exposure incident;
- A description of the exposure incident, which shall include:
- Job classification of the exposed employee;
- Department or work area where the exposure incident occurred;
- The procedure that the exposed employee was performing at the time of incident;
- How the incident occurred;
- If the sharp had engineered injury protection, whether the protective mechanism was activated, and whether the injury occurred before the protective mechanism was activated, during activation of the mechanism or after activation of the mechanism, if applicable;
- If the sharp had no engineered sharps injury protection, the injured employee's opinion as to whether and how such a mechanism could have prevented the injury; and
- The employee's opinion about whether any engineering, administrative or work practice control could have prevented the injury.
Each exposure incident shall be recorded in the Sharps Injury Log within 14 working days of the date the incident is reported to the employer. The information in the Sharps Injury Log shall be recorded and maintained in such a manner as to protect the confidentiality of the injured employee
Refer to Appendix K – Sharps Injury Log.
Personal protective equipment (PPE) is specialized clothing worn by an employee for protection against a hazard. General work clothes, not intended to function as protection against a hazard, are not considered to be personal protective equipment.
When there is a potential for occupational exposure, the employing department of Cabrillo College will provide, at no cost to the employee, the following appropriate personal protective equipment. It shall include, but not be limited to, disposable gloves, gowns, laboratory coats, face shields or masks, eye protection, mouthpieces, resuscitation bags, pocket masks and/or other ventilation devices.
Personal protective equipment is considered appropriate only if it does not permit blood or other potentially infectious materials to pass through or reach the employee's work clothes, street clothes, undergarments, skin, eyes, mouth, or other mucous membranes under normal conditions of use and for the duration of time which the protective equipment will be used.
It is the employing department's responsibility to ensure that employees use appropriate personal protective equipment. The employing department will ensure the appropriate personal protective equipment is available in the appropriate sizes and is readily accessible at the worksite. Hypoallergenic gloves, glove liners, powderless gloves, or other similar alternatives will be readily accessible to those employees who are allergic to the gloves normally provided.
The employing department will clean, launder or dispose of personal protective equipment and will repair or replace personal protective equipment as needed to maintain its effectiveness, at no cost to the employee. If blood or other potentially infectious materials penetrate a garment, the garment(s) will be removed immediately or as soon as feasible. All personal protective equipment will be removed prior to leaving the work area, and placed in an appropriate designated area or container for storage, washing, decontamination or disposal.
Gloves will be worn when it can be reasonably anticipated the employee may have hand contact with blood, other potentially infectious materials, mucous membranes, and non-intact skin; when performing vascular access procedures, and when handling or touching contaminated items or surfaces.
- Disposable (single use) gloves will be replaced as soon as practical when contaminated, or as soon as feasible if they are torn or punctured, or when their ability to function as a barrier is compromised. Disposable (single use) gloves will not be washed or decontaminated for reuse.
- Utility gloves may be decontaminated for reuse if the integrity of the glove is not compromised. However, they must be discarded if they are cracked, peeling, torn, punctured or exhibit other signs of deterioration, or when their ability to function as a barrier is compromised.
Masks in combination with eye protection devices, such as goggles or glasses with solid side shields or chin-length face shields, shall be worn whenever splashes, spray, spatter, or droplets of blood or other potentially infectious materials may be generated, and eye, nose, or mouth contamination can reasonably be anticipated.
Appropriate protective clothing such as, but not limited to, gowns, aprons, lab coats clinic jackets, or similar outer garments will be worn in occupational exposure situations. The type and characteristics will depend upon the task and the degree of exposure anticipated.
Surgical caps or hoods and/or shoe covers or boots need only be worn in situations when gross contamination can be reasonably anticipated.
Autoclaving and Chemical Sterilization: Steam autoclaving is a suitable treatment technique for small volumes of infectious wastes. These include used first aid supplies, blood spill clean up sorbents, liquids, and other small volumes of infectious wastes.
Chemical sterilization is accomplished by use of ethylene oxide; isolyzer compounds or dilute bleach solutions. Ethylene oxide treatment is impractical except in large hospitals. Isolyzer compounds or bleach solutions are practical for small blood spills such as lacerations or bloody noses.
Whatever treatment procedure is used, red bags should not be used for the disposal of TREATED infectious waste in the normal trash as this may cause undo concerns from the campus solid waste hauler or, perhaps, the general public.
Infectious waste which is disposed of by means other than washing into the sewage system is regulated by federal, state and local laws and is termed "regulated waste". The following specific procedures and precautions must be followed for the handling, treatment and disposal of regulated infectious wastes:
- All sharps must be disposed of in regulated sharps containers, regardless of other protective features built into the tool such as self-sheathing needles.
- If regulated waste is stored prior to disposal, it must be stored in a secure area that is locked or otherwise secured to eliminate access by the general public, and must be afforded protection from adverse environmental conditions and vermin.
- Untreated infectious waste shall not be shipped off-site unless it is hauled by a licensed commercial transported to a licensed infectious waste treatment facility.
- If outside contamination of the regulated waste container occurs, it will be placed in a second container.
- Disposal of Other Regulated Waste. Regulated waste not consisting of sharps shall be disposed of in containers which are: Closable and constructed to contain all contents and prevent leakage during handling, storage, transport, or shipping. These containers will be labeled biohazardous or color-coded (red bagged) and closed prior to removal to prevent spillage or protrusion of contents during handling, storage, transport, or shipping.
Note: OSHA has issued a letter stating that they do not include soiled sanitary napkins and other feminine hygiene products in the definition of regulated waste because they are designed so as to prevent the release of liquid or semi-liquid blood or the flaking off of dried blood. Therefore, employees handling such wastes are not covered by the Bloodborne Pathogens Rule solely due to that duty. However, OSHA does expect that containers for soiled sanitary products to be lined with a plastic or wax paper bag and that employees will be provided suitable gloves for removal of the bags from the waste container.
Blood spills on non-porous surfaces can very simply be handled by diluting the spill with an equal volume of 1:10 household bleach solution, or with other EPA registered disinfectants, and then absorbing it with disposable toweling or absorbent pads. This approach is used in hospitals and exceeds the guidelines issued by the CDC. If the spill involves any broken glassware, it must be picked up using a mechanical means, such as a brush and dustpan, tongs or forceps. In cases where the absorbent becomes saturated with blood and bleach, the spill clean up materials should be autoclaved prior to being disposed of in the normal trash.
There is also a number of "clumping" powdered products (e.g. Vital 1, Isolyzer) that absorb and solidify blood spills and chemically treat the material at the same time. There are also products that fix sharps in a plastic polymer while treating them by heat and chemical disinfectant (e.g. Isolyzer). While these methods are effective and convenient they are very expensive compared to bleach and absorbent material and have not yet withstood the "test of time". Bleach or other EPA approved disinfectants are most highly recommended.
Cabrillo College will ensure that all employees with potential occupational exposure participate in a training program that will be provided at no cost to the employee and will be provided during working hours. This training will begin in the Personnel Dept. when each individual will be provided an orientation and hazard determination. It is provided to all new employees prior to/or at the time of initial assignment to tasks that may involve occupational exposure.
Initial communication of the program will be provided by way of handouts. More extensive training will be given in each applicable department, by a qualified professional, knowledgeable in the subject matter covered. These departments will be responsible for generating sign in sheets for documentation purposes.
Training will be provided at the time of initial assignment to tasks where occupational exposure may take place and at least annually thereafter, within one year of their previous training using material appropriate in content and vocabulary to the educational level, literacy, and language of the employees. Cabrillo College will provide additional training when changes, such as modifications of tasks, changes in procedures, institution of new tasks or procedures affect the employee's occupational exposure. The additional training will be limited to addressing the new exposures created.
The records of training will be held jointly by the applicable departments and the Personnel Office for retention of a minimum of three (3) years. Additional training will be provided as changes occur that will affect an employee's occupational exposure status.
It is the responsibility of all employing departments of Cabrillo College to ensure that this information is conveyed to all affected employees, to all service representatives, and/or all manufacturer representatives, as appropriate, prior to the handling, servicing, or shipping of contaminated materials, so that appropriate actions can be taken.
For Category I employees and those Category II employees with potential occupational exposure to bloodborne pathogens the training program will contain the following elements:
1. An accessible copy of the regulation and an explanation of its contents.
2. A general explanation of the epidemiology and symptoms of bloodborne diseases.
3. An explanation of the modes of transmission of bloodborne pathogens.
4. An explanation of the Exposure Control Plan and the means by which the employee can obtain a copy of the written plan.
5. An explanation of the appropriate methods for recognizing tasks and other activities that may involve exposure to blood and other potentially infectious materials.
6. An explanation of the use and limitations of methods that will prevent or reduce exposure, including appropriate engineering controls, work practices and personal protective equipment.
7. Information on the types, proper use, location, removal, handling, decontamination, and disposal of personal protective equipment.
8. An explanation of the basis for selection of personal protective equipment.
9. Information of the Hepatitis B vaccine, including information on its efficacy, safety, method of administration, the benefits of being vaccinated, and that the vaccine and vaccination will be offered free of charge (except for students and volunteers). Information on the appropriate actions to take and persons to contact in an emergency involving blood or other potentially infectious materials.
10. 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.
11. Information on the post-exposure evaluation and follow-up that will provide for the employee following an exposure incident.
12. An explanation of the biohazard signs and labels and/or color-coding required by the facility and by law.
13. An opportunity for interactive questions and answers with the person conducting the training.
For Category III employees, the training program will contain the following elements:
1. Basic understanding about the subject of Bloodborne diseases and how they are transmitted.
2. Basic training on how employees are expected to respond to situations involving blood, if they unexpectedly encounter it.
3. Basic training of post-exposure follow-up and how it would apply to employees if they were exposed.
4. A video training session supplemented with basic handout material will be the primary training methodology for this group.
The person conducting the training will be knowledgeable in the subject matter covered by the elements contained in the training program as it relates to the workplace/facility.
Training records will include the following information:
1. The dates of the training sessions.
2. The contents or a summary of the training sessions.
3. The names and qualifications of the person(s) conducting the training.
4. The signed names and job titles of all persons attending the training sessions.
5. The social security number of the employee.
6. A means of assessing learning.
Training records will be maintained for 3 years from the date on which the training occurred.
Employee training records will be provided upon request for examination and copying to employees and employee representatives, and others as required by law.
Refer to Appendix L – Training Documentation Form.
One of the most obvious warnings of possible exposure to bloodborne pathogens is a biohazard label. Therefore, warning labels must be affixed to containers of regulated waste, refrigerators and freezers containing blood or other potentially infectious materials, and other containers used to store, transport or ship blood or other potentially infectious materials. The following rules shall apply.
- The Biohazard label shall be fluorescent orange or orange-red with lettering or symbols in a contrasting color.
- Labels must be affixed as close as feasible to the container by string, wire, adhesive or other method that prevents their loss or unintentional removal.
- Red bags or red containers may be substituted for labels.
- 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 exempted from the labeling requirements.
- Individual containers of blood or other potentially infectious materials that are placed in a labeled container during storage, transport, shipment or disposal are exempted from the labeling requirement.
- Contaminated equipment [i.e., athletic equipment] shall be labeled and state which portions of the equipment remain contaminated.
- Sharps disposal containers.
- Regulated waste that has been decontaminated need not be labeled or color-coded.
- Contaminated laundry bags and containers.
Equipment that may become contaminated with blood or other potentially infectious material must be examined prior to servicing or shipping and must be decontaminated as needed, unless it can be demonstrated that the decontamination of such equipment or portions of such equipment is not feasible. If the equipment can't be decontaminated, then a readily observable biohazard label must be attached to the equipment stating which portion(s) remains contaminated.
Cabrillo College will establish and maintain an accurate record for each employee with occupational exposure, to include:
- The name and social security number of the employee.
- A copy of the employee's Hepatitis B vaccination status, including the dates of all the Hepatitis B vaccinations and any medical records relative to the employee's ability to receive the vaccination.
- A copy of all results of examinations, medical testing, and follow-up procedures.
- The College's copy of the healthcare professional's written opinion.
- A copy of all information provided to the healthcare professional.
Cabrillo College will ensure that the employee's medical records are kept confidential and are not disclosed or reported without the employee's express written consent to any person within or outside the workplace except as required by law.
Cabrillo College will maintain the records for employees with occupational exposure for at least the duration of employment PLUS an additional 30 years.
Employee medical records shall be provided upon request for examination and copying to the subject employee, to anyone having written consent of the subject employee or others as required by law.
VII. Implementation of Exposure Control Plan Standards
No later than March 1, 2000, a copy of Cabrillo College's Bloodborne Pathogen Program will be available/accessible to all employees. Individual copies will be made available to the following individuals:/departments.
- College President;
- Vice President, Instruction;
- Vice President, Business Services;
- Vice President, Student Services;
- Director, Nursing Education;
- Director, Medical Assisting Program;
- Director, Dental Hygiene;
- Director, Health Services;
- Director, Physical Education;
- Director, Personnel and Human Resources;
- Manager, Maintenance and Operations [M&O].
- Director, Radiologic Technology
As soon as possible, but no later than March 1, 2000, Cabrillo College will begin providing training for all employees with possible occupational exposure. A training program will also be provided for all new employees prior to/or at the time of initial assignment to tasks that may involve occupational exposure. Additional training will be provided as changes occur that will affect an employee's occupational exposure status, as well as annual training.