Section 1: Purpose of the Plan

Section 1

Purpose of the Plan

SECTION 2

Exposure Control Officer

Exposure Control Program

Rose-Hulman Institute of Technology

Table of Contents

Section 2: General Program Management

a. Responsible Persons

b. Availability to Employees

c. Review and Update

Section 3: Exposure Determination

Section 4: Methods of Compliance

a. General

b. Engineering Controls

c. Work Practice Controls

d. Personal Protective Equipment

e. Housekeeping

Section 5: Hepatitis B Vaccination, Post-Exposure Evaluation and follow-up

a. Hepatitis B Vaccination

b. Post-Exposure Evaluation and Follow-up

c. Information Provided to the Healthcare Professional

d. Healthcare Professional’s Written Opinion

e. Medical Recordkeeping

Section 6: Labels and Signs

Section 7: Information and Training

a. Training Topics

b. Training Methods

c. Recordkeeping

One of the major goals of the Occupational Safety and Health Administration (OSHA) is to regulate facilities where work is carried out…to promote safe work practices in an effort to minimize the incidence of illness and injury experienced by employees. Relative to this goal, OSHA has enacted the Bloodborne Pathogens Standard, identified as 29 CFR 1910.1030. The purpose of the Bloodborne Pathogens Standard is to “reduce occupational exposure to Hepatitis B Virus (HBV), Human Immunodeficiency Virus (HIV) and other bloodborne pathogens” that employees may encounter in their workplace. Rose-Hulman Institute of Technology believes that there are a number of good general principles that should be followed when working with bloodborne pathogens. These include that:

· It is prudent to minimize all exposure to bloodborne pathogens.

· Risk of exposure to bloodborne pathogens should never be underestimated.

· Our Institution should implement as many work practice and engineering controls as possible to eliminate or minimize employee exposure to bloodborne pathogens.

We have implemented this Exposure Control Plan to meet the letter and intent of the OSHA Bloodborne Pathogens Standard. The objective of this plan is twofold:

· To protect our employees from the health hazards associated with bloodborne pathogens.

· To provide appropriate treatment and counseling should an employee be exposed to bloodborne pathogens.

GENERAL PROGRAM MANAGEMENT

General Program Management

A. Responsible Persons

There are four major “Categories of Responsibility” that are central to the effective implementation of our Exposure Control Plan. There are:

· The “Exposure Control Officer”.

· Department Heads and Supervisors.

· Education/Training Instructors.

· Our Employees.

The following sections define the roles played by each of these groups in carrying out our plan. (Throughout this written plan, employees with specific responsibilities are identified. If, because of promotion or other reasons, a new employee is assigned any of these responsibilities, the Health and Safety Manger is to be notified of the change, so that they can update their records.)

Dept/Operation

Control Equipment

Needs Updating

Last Review Date

The “Exposure Control Officer” will be responsible for overall management and support of our Institution’s Bloodborne Pathogens Compliance Program. Activities which are delegated to the Exposure Control Officer typically include, but are not limited to:

· Overall responsibility for implementing the Exposure Control Plan for the entire Institution.

· Working with management and other employees to develop and administer any additional bloodborne pathogens related policies and practices needed to support the effective implementation of this plan.

· Looking for ways to improve the Exposure Control Plan, as well as to revise and update the plan when necessary.

· Collecting and maintaining a suitable reference library on the Bloodborne Pathogens Standard and bloodborne pathogens.

· Knowing current legal requirements concerning bloodborne pathogens.

· Acting as Institution liaison during OSHA inspections.

· Conducting periodic Institution audits to maintain an up-to-date Exposure Control Plan.

The Environmental Health and Safety Coordinator has been appointed as the Institution’s Exposure Control Officer.

We have determined that the Exposure Control Officer will require assistance in fulfilling their responsibilities. To assist them in carrying out their duties, we have created an Exposure Control Committee composed of the following people :

Exposure Control Committee

· _____________To be determined at a later date ______________________________

· _____________________________________________________________________

Department Heads and Supervisors

Department Heads and Supervisors are responsible for exposure control in their respective areas. They work directly with the Exposure Control Officer and our employees to ensure that proper exposure control procedures are followed.

Education/Training Coordinator

Our Education/Training Coordinator will be responsible for providing information and training to all employees who have the potential for exposure to bloodborne pathogens. Activities falling under the direction of the Coordinator include:

· Maintaining an up-to-date list of Institution personnel requiring training (in conjunction with Institution management).

· Developing suitable education/training programs.

· Scheduling periodic training seminars for employees.

· Maintaining appropriate training documentation such as “Sign-in Sheets”, Quizzes, etc.

· Periodically reviewing the training programs with the Exposure Control Officer, Department Heads and Supervisors to include appropriate new information.

The Environmental Health and Safety Coordinator has been selected to be the Institution’s Education/Training Coordinator.

Employees

As with all of our Institution’s activities, our employees have the most important role in our bloodborne pathogens compliance program, for the ultimate execution of much of our Exposure Control Plan rests in their hands. In this role they must do things such as:

· Know what tasks they perform that have occupational exposure.

· Attend the bloodborne pathogens training sessions.

· Plan and conduct all operations in accordance with our work practice controls.

· Develop good personal hygiene habits.

B. Availability of the Exposure Control Plan to Employees

To help them with their efforts, our Institution’s Exposure Control Plan is available to our employees at any time. Employees are advised of this availability during their education/training sessions. Copies of the Exposure Control Plan are kept in the following locations:

The Environmental Health and Safety Coordinator’s Office

__________________________________________________________

C. Review and Update of the Plan

We recognize that it is important to keep our Exposure Control Plan up-to-date. To ensure this, the plan will be reviewed and updated under the following circumstances.

· Annually, on or before July1st of each year.

· Whenever new or modified tasks and procedures are implemented which affect occupational exposure of our employees.

· Whenever our employees’ jobs are revised such that new instances of occupational exposure may occur.

· Whenever we establish new functional positions within our Institution that may involve exposure to bloodborne pathogens

Section 3

Exposure Determination

EXPOSURE DETEMINATION

One of the keys to implementing a successful Exposure Control Plan is to identify exposure situations employees may encounter. To facilitate this in our Institution, we have prepared the following lists:

· Job classifications in which all employees have occupational exposure to bloodborne pathogens.

· Job classifications in which some employees have occupational exposure to bloodborne pathogens.

· Tasks and procedures in which occupational exposure to bloodborne pathogens occur (these tasks and procedures are performed by employees in the job classifications shown on the two previous lists).

The Health and Safety Coordinator will work with department heads and supervisors to revise and update these lists as our tasks procedures, and classification change.

Job Classifications in Which All Employees

Have Exposure to Bloodborne Pathogens

Below are listed the job classifications in our Institution where all employees may come into contact with human blood or other potentially infectious materials, which may result in possible exposure to bloodborne pathogens:

JOB TITLE		DEPARTMENT/LOCATION
First Aid Team Members		Campus-wide
Janitorial Staff		Campus-wide
Housekeeping Staff		Campus-wide
Animal Care Personnel		ABBE

Job Classifications in Which All Employees

Have Exposure to Bloodborne Pathogens

Below are listed the job classifications in our Institution where some employees may come into contact with human blood or other potentially infectious materials, which may result in possible exposure to bloodborne pathogens:

JOB TITLE		DEPARTMENT/LOCATION

Work Activities Involving Potential Exposure

To Bloods Pathogens

Below are listed the tasks and procedures in our Institution where employees may come into contact with human blood or other potentially infectious materials which may result in exposure to bloodborne pathogens:

Task/Procedure	Job Classification		Department/Location

Treating injured employees		First Aid Team Members	Campus-wide
Cleaning contaminated materials		First Aid Team Members	Campus-wide
Handling animals and related items associated with animal care		Animal Care personnel	ABBE
Routine housekeeping and janitorial duties		Janitorial/Housekeeping	Campus-wide

Section 4

Methods of Compliance

We understand that there are a number of areas that must be addressed n order to effectively eliminate or minimize exposure to bloodborne pathogens in our Institution. The first five areas we deal with in our plan are:

· The use of Universal Precautions.

· Establishing appropriate Engineering Controls.

· Implementing appropriate Work Practice Controls

· Using necessary Personal Protective Equipment.

· Implementing appropriate Housekeeping Procedures.

Each of these areas is reviewed with our employees during their bloodborne pathogens related training (see the “Information and Training” section of this plan for additional information.) By rigorously following the requirements of OSHA’s Bloodborne Pathogens Standard in these five areas, we feel that we will eliminate or minimize our employees’ occupational exposure to bloodborne pathogens as much as is possible.

A. Universal Precautions

In our Institution we have begun the practice of “Universal Precautions” on January 21, 1991. As a result, we treat all human blood and body fluids such as semen and vaginal secretions as if they are known to be infectious for HBV, HIV and other bloodborne pathogens.

In circumstances where it is difficult or impossible to differentiate between body fluid types, we assume all body fluids to be potentially infectious.

The Health and Safety Coordinator is responsible for overseeing our Universal Precautions Program.

B. Engineering Controls

One of the key aspects to our Exposure Control Plan is the use of Engineering Controls to eliminate or minimize employee exposure to bloodborne pathogens. As a result, employees use cleaning, maintenance and other equipment that is designed to prevent contact with blood or other potentially infectious materials.

The Health and Safety Coordinator periodically works with department heads and supervisors to review tasks and procedures performed in our Institution where engineering controls can be implemented or updated. As part of this effort, a Institution where engineering controls can be implemented or updated. As part of this effort, a Institution survey was completed on (To be determined) identifying three things:

· Operations where engineering controls are currently employed.

· Operations where engineering controls can be updated.

· Operations currently not employing engineering controls, but where engineering controls could be beneficial.

The results of this survey can be found on the following pages.

Each of these lists is reexamined during our annual Exposure Control Plan review and opportunities for new or improved engineering controls are identified. Any existing engineering control equipment is also reviewed for proper function and needed repair or replacement every three (3) months, in conjunction with the department head or supervisor where the equipment is located.

Engineering Control Equipment

The following operations have, or should have, Engineering Control Equipment to eliminate or minimize our employees’ exposure to bloodborne pathogens. If equipment is needed but not yet available “None” is indicated in the “Control Equipment” column.