POLICY #5141.3
The Norwich Free Academy complies with the Bloodborne Pathogens Standard set forth in Title 29 of the Code of Federal Regulations at 29 C.F.R. Section 1910.1030, as promulgated pursuant to Section 6(b) of the Occupational Safety and Health Act of 1970 (“OSHA”), codified at 29 U.S.C. Section 655.
In accord with OSHA’s Bloodborne Pathogens Standard, the following Exposure Control Plan is in effect at Norwich Free Academy (“NFA”):
OSHA requires employers to prepare an exposure determination concerning which employees may incur occupational exposure to blood or other potentially infectious materials.  “Occupational exposure” is defined as “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.”  The exposure determination determines occupational exposure without regard to the use of personal protective equipment (i.e. employees are considered to be exposed even if they wear personal protective equipment).  The exposure determination is required to contain a list of all job classifications in which all employees in those job classifications have occupational exposure, regardless of frequency.  At this facility, all employees in the job classifications below have occupational exposure and are categorized as either Category I or Category II as further described below.
Category I
Category I  job classifications are jobs in which all job-related tasks or procedures that involve an inherent potential of mucous membrane or skin contact with blood, body fluids, or tissues, or a potential for spills or splashes of them. Use of appropriate protective measures will be required for every employee in a Category I job classification.
Category I Job Classifications:
1.   Nurses                                           5.   Special Education Teachers
2.   Campus Safety Personnel             6.    Special Education Aides
3.   Coaches                                         7.   Any staff member otherwise determined by the    
4.   Physical Education Teachers                medical advisor to be at risk due to unique circumstances
Category II
In addition to listing jobs in which , OSHA requires a listing of job classifications in which some employees have occupational exposure.  Since not all the employees in these categories would be expected to incur exposure to blood or other potentially infectious materials, job-related tasks or procedures that would cause these employees to have occupational exposure are also required to be listed in order to clearly understand which employees in these categories are considered to have occupational exposure.  The job classifications in which some employees have occupational exposure and associated tasks and procedures are below and categorized as follows:
Category II Job Classifications
1.   Administrators                               3.   Teacher Aides not in Category. I
2.   Teachers not in Category I             4.   Substitute Teachers
Job-related tasks and procedures in which occupational exposure may occur include:
1.         First aid assistance with injury causing bleeding or skin tear:
            *Non-sterile gloves
            *Infectious waste disposal
2.         Handling of Contaminated Dressings/Clothing:
            *Non-sterile gloves
            *Infectious waste disposal
3.         Handling and/or disposing of used needles/lancets/syringes:
            *Non-sterile gloves
            *Infectious waste disposal in needle box/sharps container
4.         Cleaning up spills or splashes of blood or other body fluids:
            *Non-sterile gloves
            *Infectious waste disposal
5.         CPR/Heimlich:
            *Pocket mouth-to-mouth resuscitation masks
            *Non-sterile gloves
6.         Assistance with oral care:
            *Non-sterile gloves
7.         Broken glass or other sharp objects contaminated with blood:
            *Non-sterile gloves
            *Infectious waste disposal-rigid box marked for sharp disposal – maintained
            in a secure area
8.         Searching personal effects:
            *Non-sterile gloves
9.         Parenteral:  Human bites, needle sticks, cuts or abrasions that break the skin:
            *Follow the post-exposure protocol described below
            *Get immediate assessment and first aid from school nurse and a licensed healthcare professional
The most likely route of exposure in all cases will be a break in the skin integrity.
Universal precautions are intended to prevent occupational exposure to a bloodborne infectious agent through contact with blood and other potentially infectious materials.  Since blood is the single most important source of a bloodborne infectious agent (such as HIV or Hepatitis B Virus) in the occupational setting, one should assume that ALL blood, or body fluids containing visible blood, may carry an infectious agent.  Universal precautions also apply to semen and vaginal secretions and non-excretory body fluids, such as cerebrospinal fluid, but these are not considered a source of transmission in the school setting.  Under circumstances in which differentiation between body fluid types is difficult or impossible, all body fluids shall be considered potentially infectious materials.
Engineering and work practice controls will be utilized to eliminate or minimize exposure to employees at NFA.  Where occupational exposure remains after institution of these controls, personal protective equipment shall also be utilized.  At NFA the following engineering controls will be utilized:
            Sharps Containers                   Masks
            Gloves                                     Handwashing
            Gowns                                     Pocket mouth-to-mouth resuscitation masks
            Goggles                                   Infectious Waste Disposal
Universal precautions require that gloves be used for touching blood, or body fluids that contain visible blood, whenever possible.  Gowns or protective clothing should be used if soiling of clothing with blood or blood-containing body fluids is likely.  Protective eyewear or face shields may be needed when there is risk of spattering or splashing blood or body fluids containing blood into the eyes, mouth, or nose during certain procedures.
Disposable gloves (non-sterile or sterile) provide barrier protection for both the student and the hands of the caregiver during performance of tasks when contact with blood, or body fluids containing blood, is likely.  These gloves must never be washed or cleaned with the intent to reuse.  Soaps and disinfectants can cause deterioration or increase permeability of disposable gloves.  New disposable gloves must be used for each task, removed as soon as the task is completed and disposed of appropriately.  This activity should be immediately followed by routine handwashing with soap and water.
General purpose utility gloves (rubber gloves) for housekeeping chores which involve potential contact with blood or body fluids may be decontaminated after contact and reused but should be discarded if there are any signs of deterioration such as holes, peeling, cracking or discoloration.
General infection control practices recommend the use of gloves for examination of the mucous membranes, endotracheal suctioning, or when a caregiver’s hand(s) must enter a student’s mouth to perform a specific treatment.  Gloves need not be worn when feeding or wiping saliva or nasal discharge with a tissue.
General infection control practices (for the prevention of transmission of other types of infectious agents) mandate the use of gloves when diapering, assisting in toileting, changing a dressing on a draining wound, or cleaning soiled articles of clothing.
The above controls will be reviewed annually by the Medical Center Staff. 
The following work practice controls are in place at NFA:
1.         Handwashing – hands and other skin surfaces shall be washed immediately and thoroughly with soap and warm water if contaminated with blood or other body fluids or potentially contaminated articles.  Hands shall always be washed after removing gloves or any other personal protective equipment.  Hand washing shall be completed using the appropriate facilities, such as utility or restroom sinks.  If blood or other potentially infectious materials contact mucous membranes, such membranes should immediately be flushed with water.
2.         Disposable gloves should be worn in all situations where there is blood or bodily fluids that have the potential of HIV contamination.
3.         Sharps Disposal – All workers shall take precautions to prevent injuries caused by sharp instruments.  Needles shall NOT be recapped, purposely bent or broken by hand, removed from a disposable syringe, or otherwise manipulated by hand.  After use, sharps shall be immediately placed in an appropriate receptacle for disposal.  The containers meet the requirements as outlined by OSHA regulations.  They are closable, biohazard marked, leakproof on the sides and bottom, and puncture resistant and are located in the use area.  The container will be replaced when ¾ full via a medical waste management company.  A Biomedical Waste transport log will be maintained.  A second labeled leak proof container will be used in the event of leakage of the original container.
4.         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.
5.         Storage of food and drink is prohibited where blood or potentially infectious materials are kept.  This applies to refrigerators, freezers, shelves, cabinets, countertops, and benchtops.
6.         All procedures involving blood or other potentially infectious materials shall be performed in such a manner as to minimize splashing, spraying, spattering, and generation of droplets of these substances.
7.         Mouth pipetting/suctioning of blood or other potentially infectious materials is prohibited.
8.         Specimens of blood or other potentially infectious materials shall be placed in a container which prevents leakage during collection, handling, processing, storage, transport, or shipping.
9.         Equipment which may become contaminated with blood or other potentially infectious materials shall be examined prior to servicing or shipping and shall be decontaminated as necessary, unless not feasible.
Standard Personal Protective Equipment
NFA will provide clean personal protective equipment at no cost to employees.  Spill kits are in place in every building in the janitors’ closets.  Non-sterile gloves are distributed to all House Offices at the beginning of the school year. Gloves shall be worn when it can be reasonably anticipated that there may be hand contact with blood, other potentially infectious materials, mucous membranes, and non-intact skin; and when handling or touching contaminated items or surfaces.
No one type of glove is appropriate for all situations.  In situations involving broken glass or sharp edge, gloves that meet OSHA requirements should be worn.  Utility gloves are available in all buildings in the janitors’ closets.  Employees have been instructed never to pick up by hand any broken glassware.  A brush, dust pan, forceps and/or tongs will be available for this purpose.  Disposable (single use) gloves shall be replaced as soon as practical when contaminated or as soon as feasible if they are torn, punctured, or when their ability to function as a barrier is compromised; they shall not be washed or decontaminated for re-use.  Utility gloves may be decontaminated for re-use 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 and eyewear shall be used in all medical emergencies and situations whenever splashes, spray, spatter, or droplets of blood or other potentially infectious materials may be generated and eye, nose, or mouth contamination can be reasonably anticipated.  Appropriate protective clothing such as gowns 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.  How and when masks, eyewear and gowns are used depends on the situation.
When personal protective equipment is removed it shall be placed in an appropriately designated area or container for storage, washing, decontamination or disposal.
Resuscitation Equipment
No transmission of HIV or HBV infection during mouth-to-mouth resuscitation has been documented.  However, other diseases can be transmitted during this emergency procedure and common sense dictates protection against possible infection.
Pocket mouth-to-mouth resuscitation masks shall be provided to all personnel who may provide emergency treatment.
1.         Employees are responsible for ensuring that equipment or surfaces are cleaned with appropriate disinfectant and decontaminated immediately after a spill or leakage occurs and at the end of the work day.
2.         Spilled bodily fluids shall be removed from the environment by proper cleaning techniques.  Grossly contaminated environmental surfaces shall be thoroughly cleaned with a quaternary agent.  Disposable gloves shall be worn.  Wastes and disposable cleaning equipment shall be placed in a toilet or plastic bag as appropriate.
3.         Non-disposable cleaning equipment (e.g., mops, buckets, bins, pails, cans) shall be washed thoroughly in hot water and thoroughly rinsed in a quaternary agent.  The solution shall be disposed of promptly down a drain pipe.
4.         Housekeeping responsibilities shall include daily cleaning with a quaternary agent of all areas of high risk for contact with bodily fluids such as the medical center toilets and sinks, student and staff lavatories, etc.  Plastic waste bags shall be changed daily and disposed of routinely; disposable gloves shall be worn.
5.         Food service/preparation surfaces shall be sanitized with a quaternary agent after first cleaning to remove all visible soil with soapy water.
6.         Protective coverings, such as plastic wrap, aluminum foil, or imperviously-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.
7.         Spilled bodily fluids on carpets shall be disposed of by routine use of a moisture absorbent which is swept/vacuumed and then followed by washing carpet with carpet cleaner.
8.         School nurses shall decontaminate all materials saturated with blood or other potential infectious materials by cleaning with a quaternary agent such as Sanicloth.
9.         Student clothing items that are soaked to the skin shall be removed, placed in a plastic bag, and sent home for laundering. Contaminated disposable items shall be handed with disposable gloves.
10.       Staff shall never pick up by hand any broken glassware that may be contaminated.  It shall be cleaned up using mechanical means, such as a brush and dust pan, tongs, or forceps.  The equipment used for this purpose must be cleaned and decontaminated if the glass container was contaminated by blood or other potentially infectious agents. 
Information on the Hepatitis B vaccine to include: efficacy, safety, administration, benefits and that the vaccine is offered free of charge, will be offered to all appropriate new employees working at the time of employment unless the employee has previously received the complete Hepatitis B vaccination series, antibody testing has shown the employee is immune, or medical evaluation shows that the vaccine is contraindicated for medical reasons.  If after receiving information on Hepatitis B disease and Hepatitis B vaccine, the employee consents or declines the vaccination, he/she must sign either a  consent for vaccine or declination form.  Employees who initially decline the vaccine but who later wish to have it may then have the vaccine provided at no cost.  If at a future date the U. S. Public Health Service recommends a booster dose or doses of Hepatitis B vaccine, the booster dose(s) will also be provided to the employee free of charge.
It will be the responsibility of Human Resources to assure that the vaccine is offered to the appropriate employee and to obtain the necessary permission or declination form.
When an exposure incident occurs, unless immediate first aid is required, the involved employee will report the incident to the building administrator, and then report to the School Nurse.  If immediate first aid is required, the involved employee should report directly to the School Nurse, and report the incident to the building administrator as soon as practicable.  The School Nurse or designee, after administering post-exposure incident intervention consistent with applicable protocols, shall immediately refer the employee to the Medical Director or another licensed healthcare professional who shall immediately make available, at NFA’s expense, a confidential medical evaluation and follow-up, consistent with state and federal law, at a reasonable time and place.  The confidential medical evaluation and follow-up shall include:
1.              Documentation of the route(s) of exposure and the circumstances under which the exposure incident occurred;
2.              Identification of the source individual unless such identification is not feasible or is prohibited by state or local law.
a.   The source individual’s blood shall be tested as soon as feasible and after consent is obtained in order to determine HBV and HIV infectivity.  If consent is not obtained, the employer shall establish that 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.  If the source individual is a student in school, the parents shall be counseled regarding the incident and asked to have the child/student tested if the exposed employee requests testing.  If the parent refuses, the child/student cannot be tested.
b.   If the source individual is already known to be infected with HBV or HIV, testing need not be repeated.
c.   The results of the source individual’s HBV and HIV tests, if known, shall be made available to the exposed employee.  At the time this information is made available to the employee, he/she shall be informed of applicable laws and regulations concerning disclosure of the identity and infectious status of the source individual. 
3.              Collection and testing of the employee’s blood for HBV and HIV serological status.
a.     The exposed employee’s blood shall be collected as soon as feasible by an accredited  lab and tested after consent is obtained.
b.     If the exposed employee consents to base line collection of blood but refuses HIV serological testing, the sample will be preserved by the laboratory for 90 days.  During this time period, the employee may elect to have the sample tested.
4.              If the source individual is HBV and/or HIV positive or has refused testing, the employee will be advised that he/she should be retested if seronegative at 6 weeks, 12 weeks, 6 months and one year after exposure.  At NFA’s option, retesting may also be provided annually for 1-2 years following the exposure incident.  The employee must consent to retesting on each occasion.
5.              Post-exposure prophylaxis, when medically indicated, as recommended by the U.S. Public Health Service.
6.              Counseling.
7.              Evaluation of reported illnesses.
In conducting the confidential medical evaluation and follow-up, the healthcare professional shall be provided at minimum the following information:
1.         A copy of the applicable OSHA regulation(s), including Section 1910.1030 of Title 29 regarding Bloodborne pathogens;
2.         Date of incident, when reported and to whom;
3.         Description of the employee’s job duties as they relate to the exposure incident;
4.         Documentation of the route(s) of exposure and circumstances under which exposure occurred;
5.         Results of the source individual’s blood testing, if available; and
6.         All medical records relevant to the appropriate treatment of the employee including vaccination status
The healthcare professional will prepare and provide to the Medical Center a written opinion following the post-exposure confidential medical evaluation and follow-up.  The written opinion shall be limited to the following information:
(1) that the employee has been advised of the evaluation result; and
(2) 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.
Any other findings or diagnoses shall remain confidential and shall not be included in the written report.  All applicable laws and standards of confidentiality apply to this information.  NFA may not be advised of an exposed employee’s HIV status.  NFA shall provide a copy of the healthcare professional’s written opinion to the employee within fifteen (15) days of the completion of the medical evaluation unless the healthcare professional has already given the employee a copy.
All evaluations, medical follow-ups, counseling and evaluations of reported illnesses are provided at no cost to the exposed employee.
All required laboratory tests are done by an accredited laboratory at no cost to the exposed employee.
1.              Training sessions will be mandated for all new employees during orientation and to any current employees assigned to a new assignment where occupational exposure may take place if not previously assigned to such an assignment.
2.              Annual mandatory review training sessions will be assigned to all employees.
3.              Employee training records will be maintained for three (3) years after the date of training.  These records will include the following information related to specific education about bloodborne pathogens and the Exposure Control Plan:
a.     the dates of the training sessions;
b.     the contents or a summary of the training sessions;
c.     the names and qualifications of persons conducting the training; and
d.     the names and job titles of all persons attending the training sessions.
4.         All training shall be provided at no cost to the employee and during working hours. 
NFA will establish and maintain a medical record for each employee who consents to receive the Hepatitis vaccine. Each employee’s medical record will contain:
1.              A copy of the employee’s Hepatitis B vaccination consent for vaccination and the Employee’s Hepatitis B Vaccination Tracking Form to include the dates
of all Hepatitis B Vaccinations and any medical records relative to the employee’s ability to receive vaccination.
2.              In the event of an employee exposure incident, a copy of all medical information will be kept in the Medical Center for the duration of employment plus 30 years.
Employee medical records will be kept confidential and shall not be disclosed or reported without the employee’s written consent except as required by applicable laws and regulations.  Employee medical records will be retained for the duration of employment plus three years. However in the event of an exposure, the record will be retained for the duration of employment plus 30 years.
Policy Revised:             4/21/09, 7/17/14, 10/20/15, 8/20/19
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