Section 3 – Methods of Compliance

    Table of Contents:

    Bloodborne Table of Contents

     

    Bloodborne pathogens assessment results

    Classification I:

    Employees Whose Primary Job Description is Administering First Aid, Healthcare or They Have Other Occupational Exposure to Bloodborne Pathogens.

    Below are listed the job classifications at St. Olaf College where the job description is administering first aid, healthcare or they have other occupational exposure to bloodborne pathogens.

    JOB TITLE TYPES OF BODY FLUIDS/
    BLOOD ENCOUNTERED    		 RELATED TASKS/
    PROCEDURES
    Health Care Nurse Practitioner Blood and other body fluids contaminated with blood Sharps-lancet for glucose testing; resuscitation/CPR; changing of dressings; first aid; working with injuries
    Athletic Trainer Blood and other body fluids contaminated with blood Working with injuries; first aid; changing of dressings; resuscitation/CPR

     

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    Bloodborne pathogens assessment results

    Classification II:

    Employees Who Provide First Aid as an Auxiliary Component of Their Duties and are Potentially Exposed to Bloodborne Pathogens.

    Below are listed the job classifications at St. Olaf College where employees provide first aid as an auxiliary component of their duties.

    JOB TITLE TYPES OF BODY FLUIDS/
    BLOOD ENCOUNTERED    		 RELATED TASKS/
    PROCEDURES
    Athletic Coaches Blood and other body fluids Working with injuries; Changing of dressings; Cleanup of blood spills
    Athletic Equipment Handlers Blood and other body fluids Cleanup of blood spills; Working with athletic equipment; Contaminated laundry
    Food Service Personnel Blood and other body fluids Preparing food; cleanup of tables, etc.; washing dishes
    Lab Technicians Blood and other body fluids Draw blood; handling serum products and other body fluids
    Nursing Faculty Blood and other body fluids Draw blood; handling blood and other body fluids
    Resident Assistants Blood and other body fluids Handling blood and other body fluids
    Junior Counselors Blood and other body fluids Handling blood and other body fluids
    Hall Directors Blood and other body fluids Handling blood and other body fluids
    Security Officers Blood and other body fluids Handling blood and other body fluids
    Custodians Blood and other body fluids Handling blood and other body fluids

     

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    Work activities/tasks

    Listed below are various activities and tasks performed by some of our classification I and II employees. Also included in this chart along with listed activities are corresponding work practices, prevention and appropriate personal protective equipment.

    ACTIVITIES WORK PRACTICES PREVENTION PERSONAL PROTECTIVE EQUIPMENT (PPE)
    • Delivering first aid/working with injuries and changing dressings.
    • Use disposable gloves and avoid contact by using appropriate barriers.
    • Direct the person to self-manage injury if at all possible.
    • Use antiseptic pad or paper towel to wipe injury.
    • Wash injury with water while avoiding exposure.
    • Remove soiled clothing to be laundered appropriately.
    • Remove/dispose of gloves and other contaminated materials in lined containers.
    • Follow appropriate blood spill cleanup procedures.
    • Follow proper procedures for glove use, removal and hand washing.
    • Promote self- management among students/staff.
    • Vaccinate for hepatitis B.
    • Avoid direct contact with body fluids if possible.
    • Gloves
    • Protective clothing
    • Face shield/masks
    • Eye protection
    • Other
    • Handling Sharps
    • Use disposable gloves.
    • Use sharps container to store contaminated sharps until disposal.
    • Utilize tongs/forceps or other mechanical devices for handling contaminated sharps.
    • Sharps should never be recapped.
    • Follow proper procedures for glove use/removal and hand washing.
    • Utilize appropriate sharps disposal containers.
    • Vaccinate for hepatitis B.
    • Avoid direct contact with body fluids if possible.
    • Gloves
    • Other
    • Resuscitation/CPR
    • If possible, try to avoid or limit contact with bodily fluids by using barriers.
    • Utilize proper protective wear based on situation and, if available, CPR shields/masks.
    • Follow appropriate glove use/removal procedures.
    • After provision of CPR, wash face/hands thoroughly, utilizing proper washing procedures.
    • Dispose of contaminated protective wear in a lined waste container or plastic bag.
    • Utilize proper PPE and protective barriers, i.e. CPR shields/masks.
    • Vaccinate for hepatitis B.
    • Avoid direct contact with body fluids if possible.
    • Gloves
    • Protective clothing
    • Face shield/mask
    • Eye protection
    • CPR shield
    • Other
    • Clean-up of blood/body fluid spills.
    • Wear proper gloves.
    • Spread absorbent disinfectant or paper towels over spill.
    • Dispose of material in lined waste container.
    • Clean with soap and water and use appropriate disinfectant over affected area, i.e. 1:10 bleach/water solution.
    • Wipe disinfectant with paper towels or follow appropriate procedure/dispose.
    • Remove gloves and use proper hand washing procedures.
    • Use tongs or other devices to pick up broken glass or sharps.
    • Use sharps containers for broken glass and other sharps.
    • Utilize tongs or dust pan and brush to pick up broken glass or other sharps.
    • Vaccinate for hepatitis B.
    • Avoid direct contact with body fluids if possible.
    • Gloves
    • Other
    • Contaminated laundry (If Universal Precautions are used by treating all soiled laundry as contaminated, the procedures listed need to be implemented.)
    • Handle as little as possible/minimize agitation.
    • If laundry is shipped off-site, additional procedures must be followed.
    • Place laundry in identifiable bags or appropriately lined containers that are leak-proof.
    • Use gloves and other protective equipment if appropriate.
    • Follow proper hand washing procedures.
    • Use appropriate barriers including mechanical devices such as tongs and other equipment to handle contaminated laundry.
    • Avoid direct contact with body fluids if possible.
    • Vaccinate for hepatitis B.
    • Gloves
    • Coat/apron
    • Other
    • Aggressive behavior
    • Use appropriate techniques to restrain and, therefore, limit exposure through biting/other aggressive behavior.
    • Follow proper glove use removal procedures and other protective clothing to avoid skin exposure.
    • Proper washing techniques should be followed if biting or other aggressive behavior occurs.
    • Vaccinate for hepatitis B
    • Avoid direct contact with body fluids if possible.
    • Gloves
    • Protective clothing
    • Other

     

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    Universal precautions

    Universal Precautions provide the first line of defense for employees against the risks of exposure to bloodborne pathogens. Universal Precautions shall be practiced at all times to reduce the risk to workers in the vicinity of an exposure. Since there is no way to know the status of body fluids from an unknown source, Universal Precautions must be consistently used. This relates to all activities involving contact with blood, tissue, body fluids, or equipment and materials which may have been contaminated by these substances.

    1. At a minimum, the following precautions are required of all employees when attending to an injured worker or working with equipment or materials which may have been contaminated with infectious material. These universal guidelines do not relieve personnel of responsibility for knowing and complying with more detailed policies included in this Exposure Control Plan which must be consulted and followed routinely.
      1. WASH HANDS with antiseptic towelettes if there is any possibility of contact with blood, body fluids or human tissue. Wash hands with soap and water as soon as possible.
      2. WEAR GLOVES when anticipating contact with blood, body fluid, tissues, mucous membranes or contaminated surfaces, or if breaks in the skin are present.
      3. WEAR AN IMPERVIOUS GOWN OR APRON if splattering of clothing is likely.
      4. WEAR A MASK if there is to be contact with an infectious disease spread by splatter droplets.
      5. WEAR APPROPRIATE PROTECTIVE EQUIPMENT at all times, including a mask and eye protection if splattering is likely to occur when attending to an injured worker.
      6. USE MOUTHPIECES, RESUSCITATION BAGS AND OTHER VENTILATION DEVICES during emergency resuscitation if this is a part of the job duties.
      7. HANDLE SHARP OBJECTS CAREFULLY:
        1. Do not cut, bend, break or reinsert used needles into original sheath by hand.
        2. Discard sharp objects intact, immediately after use or finding, into an impervious sharps disposal box.
        3. Report immediately all needle stick accidents, mucosal splashes or contamination open wounds with blood or body fluids.
      8. DISPOSE OF ALL SPILLS which contain, or may contain, biological contaminants in accordance with policies for infectious waste disposal. Until clean-up is complete, the area should be roped off to other workers.
      9. POST UNIVERSAL PRECAUTION SIGNS in all areas designated for first aid and on emergency response boxes and first-aid kits.
    2. Again, we must always assume that every situation involving unknown body fluids is a potential exposure to bloodborne pathogens. PPE is our first line of defense. This equipment is a physical barrier preventing skin or mucous membrane contact with potentially contaminated fluids or tissues. Wear gloves for most tasks. Always wear safety glasses with splash guards or goggles if splashing may occur in body fluid cleanups. If other protective clothing is necessary to prevent contact, use it. Your health and safety are our primary concern.

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    Engineering controls and work practices

    1. In spite of continual improvements in the design and manufacture of safety devices to protect employees from all types of environmental threats to their safety and health, many threats remain. St. Olaf College acknowledges the significant contribution made by these devices in protecting employees from occupational hazards associated with bloodborne pathogens and will insist that they be used on our job sites.
    2. Most BBP threats can be minimized greatly through engineering controls and modified work practices. An engineering control is a device which isolates or removes BBPs from the work place. Sharps containers in the health service would be an example. Work practice controls reduce a BBP threat by changing the manner in which we perform a task. Blotting large amounts of fluid with disposable toweling instead of scooping up quantities with a dust type pan might be an example. This would reduce the possibility of splashing. When engineering controls and work practices cannot ensure safety from an exposure incident, personal protective equipment must be used.
    3. The following applies to all classification I and II employees when attending to a situation which presents any risk of exposure to a bloodborne disease:
      1. Classification I and II employees are responsible for proper use and routine care of health safety devices and personal protective equipment.
      2. Each employee must recognize the possibility of failure of a safety device. Accordingly, employees shall adhere to the tenants of Universal Precautions, always working with care and without placing unjustifiable reliance on mechanical devices as the sole means of avoiding the risk of personal contamination.
      3. Each classification I and II employee is responsible for reporting observed deficiencies in existing devices to supervisors or the maintenance staff.
      4. Engineering safety controls and devices shall be maintained in working order consistent with manufacturer’s specifications and common sense, whichever offers the greater degree of worker protection.
      5. Administrators and professional staff shall be alert to the availability of new or improved protective devices.

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    Hand washing

    1. All employees must wash hands and any other skin with soap and water and flush exposed mucous membranes with water immediately or as soon as possible following contact with blood or other potentially infectious materials.
    2. Employees must advise supervisors directly of any locations where contamination could reasonably be expected to occur and hands cannot be cleaned in accordance with the following standards so that corrective action can be taken.
    3. It is vitally important to clean hands thoroughly after contact with possible infectious material. This helps to protect you, but is very important in preventing the hand-to-hand spread of contamination to your fellow employees. Inability to clean hands in accordance with the following standard prior to possible contamination of self or others which could result in transmitting a bloodborne disease must be reported and evaluated as a possible exposure incident.
    4. Hand washing is the single most important means of preventing the spread of infection. The principle of good hand washing is that of using friction to mechanically remove micro-organisms.
    5. After possible exposure:
      1. Wash hands with non-abrasive soap and running water.
      2. Rinse hands under running water.
      3. Dry hands well with paper towel.
      4. Use paper towel to turn off faucet. All manually controlled faucets are considered contaminated.
      5. Dispose of single use or linen towels in appropriately marked closable containers.
      6. Apply hand cream after frequent hand washing. Use lotion to prevent skin irritation, breakdown and subsequent infection.

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    Needles and sharps

    1. Classification I and II employees do not usually use needles or sharps such as scalpels. These implements, however, may be used in the health service in unusual circumstances. If contaminated by use, sharps must be safely contained in proper sharps containers at the use location.
    2. Do not cut, bend, break or routinely re-insert used needles into original sheath by hand.
    3. Discard sharp objects intact immediately after use into an impervious needle disposal box which should be conveniently placed in appropriate work areas.
    4. Report immediately all accidents, including needlesticks, mucosal splashes or contamination of open wound with blood or body fluids.
    5. Employees must adhere to the following Standard of Practice when working with uncapped needles, syringes or IV tubing:
      1. Place needle cap on flat surface, such as a table top.
      2. Thread unprotected needle into cap, holding syringe or tubing at needle juncture, securing firmly over the needle.
      3. Discard capped needle and syringe into designated sharps disposal container.
    6. For needle attached to IV tubing:
      1. Remove the capped needle from tubing and discard the needle into an approved sharps disposal container.

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    Ingestion of bloodborne pathogens

    1. 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.
    2. Food and drink shall not be kept in refrigerators, freezers, shelves, cabinets, on countertops or bench tops where blood or other potentially infectious materials are present.
    3. To every extent possible these cautions shall be communicated to the general work force through routine first aid or other safety training events and through written information distributed or posted as a part of normal employee general information dissemination.
    4. Employees who have been working at a site where the possibility of contamination exists shall avoid any behavior that could result in ingesting contaminated materials until they have washed their hands with soap and running water as described in the Exposure Control Plan’s policy on hand washing.

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    Availability and accessibility of personal protective equipment

    1. Personal Protective Equipment includes, but is not limited to, gloves, gowns, laboratory coats, face shields, masks, eye protection, mouthpieces, resuscitation bags, pocket masks and other ventilation devices.
    2. Appropriate equipment is that which does not permit blood or other potentially infectious materials to pass through to or reach the employee’s work clothes, street clothes, undergarments, skin, eyes, mouth or other mucous membranes under normal conditions and for the duration of use.
    3. Each Classification I and II employee is responsible for knowing the location and inventory level of appropriate and properly sized protective equipment, and for advising supervisors if adequate supplies are not available.
    4. Each Classification I and II employee is responsible for inspecting protective equipment before use and for placing defective pieces in the reject container located in each storage area.
    5. To reduce the risk of exposure, PPE should not be handled excessively for the purpose of inspection after use. Pieces observed to be damaged should be placed in a separate contaminated laundry container which is tagged defective.
    6. Incidence of possible exposure resulting from non-availability of appropriate personal protective equipment is a serious flaw in job performance for all involved.
    7. All Classification I and II employees shall use appropriate personal protective equipment to the extent judged appropriate based on any possibility of contracting an infection from bloodborne pathogens at work.
    8. Employees shall wear protective caps or hoods and shoe covers or boots in addition to routine personal protective equipment when there is reasonable anticipation of gross contamination, such as at the scene of a major accident.
    9. Employees shall remove immediately, or as soon as feasible, any garment that is penetrated by blood or other potentially infectious material. All personal protective equipment shall be removed prior to leaving the scene and shall be placed in a designated container for storage, washing, decontamination or disposal.
    10. Each employee is responsible for inspecting protective equipment before use. Defective pieces should be placed in the reject container located in each storage area.
    11. All employees are responsible for identifying pieces of protective equipment that have been damaged during use. However, to reduce the risk of personal exposure when removing protective equipment, pieces should not be handled excessively during inspection. Pieces known to have been damaged during use should be placed in a separate contaminated laundry container, and the container should then be tagged accordingly.

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    Specific use of personal protective equipment

    1. Masks, eye protection and face shield combinations shall be worn whenever splashes, spray, splatter or droplets of blood or other potentially infectious materials may be generated and eye, nose or mouth contamination can be reasonably anticipated.
    2. Employees shall wear gloves when it can be reasonably anticipated that the employee may have hand contact with blood, other potentially infectious materials, mucous membranes, or non-intact skin.
    3. Protective body clothing such as, but not limited to, gowns, aprons, lab coats, clinic jackets or similar outer garments shall be worn in occupational exposure situations. The type and characteristics will depend upon the task and degree of exposure anticipated.
    4. Employees shall wear protective caps or hoods and shoe covers or boots when there is reasonable anticipation of gross contamination in mass injury situations with extensive blood loss or body fragmentation, or when gaining access to the victim could result in exposure to blood or other potentially contaminated fluids.

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    Eye protection

    1. Eye protection such as goggles, eye glasses or a face shield will be worn when there is a possibility of contamination of the mucous membranes through splashing.
    2. To properly apply eye protection:
      1. Wash hands
      2. Apply eye protectors
      3. Glove
      4. Perform procedure
      5. Remove gloves
      6. Remove eye protectors
      7. Wash eye protectors with soap and water
      8. Wash hands
      9. Keep eye protectors in a convenient, clean, dry area
    3. Use this same procedure for putting on protective masks, head wear, footwear, gloves and gowns or aprons.

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    Gloves

    1. Gloves must be worn when it can be reasonably anticipated that the employee may have hand contact with infectious material.
    2. Utility (reusable) gloves may be reused if they are in good condition. If they are cracked, peeling or torn, they must be properly disposed of.
    3. Disposable (single use) gloves must be replaced as soon as possible if contaminated, or their integrity is compromised.
    4. After putting gloves on, reinspect for damage.
    5. When removing disposable gloves, pull down from the cuff. This will leave the glove inside out, but minimizes potential contamination of your hands. Place this first glove in the palm of the other hand and remove the second glove in the same manner.
    6. When removing reusable gloves, pull down from the cuff. This will leave the glove inside out, but minimizes potential contamination of your hands. Disinfect, dry and reinspect for damage. Discard if damaged in any way.

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    Removal of PPE

    1. To take off masks, head wear, footwear, gloves and gown:
      1. Remove, head wear, footwear and then gloves and discard into a waste container or place into an approved, properly marked laundry container located within the space where the task or procedure has been performed.
      2. Remove gown, turning it inside out. Handle only the inside of the gown. Place it into an approved, properly marked laundry container located within the space where the procedure has been performed.
      3. Wash hands and flush mucous membranes if there is any possibility that membrane exposure to blood or other infectious fluids or materials occurred.

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