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Dano's Manufacturing is a manufacturer of durable goods with one hundred employees. The owner and employees are proactive in maintaining optimum health to all employees.
The Bloodborne Pathogens Standards' (29 CFR 1910.1030) goal is to eliminate or alleviate employee exposure to Hepatitis B Virus (HBV), Human Immunodeficiency Virus (HIV) and other Bloodborne Pathogens that workers can be exposed to in their place of employment.
Bloodborne Pathogen: "Pathogenic microorganisms that are present in human blood and can cause disease in humans." (OSHA Standards for the General Industry, 2000, p. 587)
Exposure: Contact with the eyes, mucous membranes or skin with "blood or other potentially infectious material." (OSHA Standards for the General Industry, 2000, p. 587)
Parenteral: Piercing the skin into the body such as needle pricks or cuts.
Work Practice Controls: Procedures to eliminate or minimize exposure to Bloodborne Pathogens.
There are three areas of responsibility that are to the effective implementation of the exposure plan:
The Program Coordinator.
Owner, Department Managers, Forepersons and Emergency Response Team.
The employees and contractors.
The Program Coordinator is responsible for implementation, control, and support of the Bloodborne Pathogens Compliance Program. The Dano's Manufacturing Program Coordinator is the Safety Coordinator. Activities which are delegated to the Program Coordinator include:
Overall responsibility of implementing the Bloodborne Procedures for the facility.
Working with management and employees to implement any further Bloodborne Pathogen procedures and to maintain a current and comprehensive Bloodborne Pathogen Plan.
Looking for ways to countermeasure deficiencies, improve the quality or update the Exposure Control Plan.
Keeping current on legal requirements concerning Bloodborne Pathogens.
Acting as the management representative during OSHA inspections.
Auditing periodically to maintain current and comprehensive Bloodborne Procedures.
The Program Coordinator is responsible for incorporating educational materials and training to all employees who have the capacity for exposure to Bloodborne Pathogens. Duties and direction of the Program Coordinator include:
Maintaining a current list of company personnel that needs training.
Developing proper education and training programs.
Preparing periodic training documentation such as attendance sheets and tests. Periodically reviewing the training programs with the Owner, Department Managers, Forepersons, Emergency Response Team, and employees to include up-to-date information.
3.1.2 Owner, Department Mangers, Forepersons and Emergency Response Team The Owner, Department Managers, Forepersons and Emergency Response Team must be responsible and diligent for Bloodborne Pathogen exposure control and prevention in their specific areas. They work closely with the Program Coordinator and the employees to ensure proper exposure control procedures are implemented and followed.
The facility's employees shall do the following:
Be knowledgeable in performing tasks that have the potential to create exposure to Bloodborne Pathogens.
Attend the Bloodborne Pathogens educational sessions.
Administer and conduct all operations in accordance with the work practice controls.
Encourage and promote good and consistent personal hygiene habits.
Dano's Manufacturing adheres to principles that shall be implemented when working with Bloodborne Pathogens:
Never underrate the risk of Bloodborne Pathogens exposure in the workplace.
It is prudent to eradicate or minimize all exposure to Bloodborne Pathogens.
The facility shall implement and maintain as many administrative and engineering controls as possible to eliminate or alleviate employee exposure to Bloodborne pathogens.
4.1. Exposure Control Plan Availability
Dano's Manufacturing Bloodborne Pathogen Work Procedures is available on the company's electronic network. Employees are advised of the accessibility and availability of work procedures during their educational sessions.
4.2 Review and Update of the Plan
Dano's Manufacturing recognizes the importance of keeping the Bloodborne Pathogen Plan
current. The plan will be reviewed annually. The plan will be updated whenever the following conditions occur:
Whenever additional or changed work processes entails possible exposure to Bloodborne Pathogens.
Whenever a new position entails possible exposure to Bloodborne Pathogens.
4.3 Exposure Determination
One of the instrumental facets of implementing a successful Bloodborne Pathogens Control Plan is identifying exposure circumstances employees may encounter. Aiding the organization, Dano's Manufacturing has prepared the following lists:
Job classification where employees exposure to Bloodborne Pathogens occurs.
Whenever a new job or task entails possible exposure to Bloodborne Pathogens.
The Program Coordinator will work with the Owner, Department Managers, Forepersons, and Emergency Response Team to revise and update these lists, procedures, and classifications when changed.
4.4 Job Classifications Who Has Exposure to Bloodborne Pathogens
The following list denotes job classifications that are deemed to be more apt to come in contact with Bloodborne Pathogens:
Emergency Response Team Members
4.5 Work Tasks and Categories Involving Possible Exposure to Bloodborne Pathogens
The facility's work tasks and categories below are at risk for possible exposure to Bloodborne Pathogens:
Tasks/Procedures Job Classifications
First Aid & CPR See 4.3
Although employees may be trained in CPR and/or First Aid, only designated employees (see 4.3) should respond in an emergency situation.
Methods of Compliance
The following four items are standardized across all aspects of Dano's Manufacturing:
Implementing proper "Work Practice Controls." (OSHA Standards for General Industry, 2000, p. 588)
The use of "Universal Precautions" (OSHA Standards for General Industry, 2000 p. 588)
Comprehensive Personal Protective Equipment.
Establishing and maintaining proper Engineering Controls.
4.6.1 Universal Precautions
The result of conforming to "Universal Precautions," (OSHA Standards for General Industry, 2000, p. 588) Dano's Manufacturing shall regard all blood and body fluids as already contaminated with Bloodborne Pathogens.
4.6.2 Engineering Controls
One of the critical components the Bloodborne Pathogen plan is the Engineering Controls to eradicate or lessen employee exposure to Bloodborne Pathogens. The employees listed in Section 4.3 will utilize cleaning, maintenance, and other equipment designed to prevent exposure with "blood or other potentially infectious materials." (OSHA Standards for the General Industry, 2000, p. 587) The Program Coordinator periodically works with the Owner, Department Mangers, Forepersons and the Emergency Response Team to implement engineering controls where needed.
4.6.3 Work Practice Controls
Engineering controls in conjunction with additional facility practices, helps eliminate or alleviate exposure to Bloodborne Pathogens. The Program Coordinator is responsible for supervising the implementation of work practice controls. This person works in tandem with the Owner, Department Managers, Forepersons, and the Emergency Response Team.
Immediately, individuals shall wash their hands after removal of contaminated personal protective equipment.
After exposure of any part of the body with "blood or any other infectious material,"
(OSHA Standards for the General Industry, 2000, p. 587) employees shall wash all exposed body surfaces with soap and water, immediately. Eyes or other areas of the body where soap could itself be detrimental shall, at minimum, be flushed with water.
Suitable biohazard warning labels is affixed to any contaminated equipment.
Remaining contamination is discussed to affected employees, equipment manufacturers, and contactors before any handling of equipment.
4.6.4 Contaminated Needles and Sharp Containers
Contaminated needles and sharps will not be bent, removed, or broken. Under no circumstances shall contaminated needles and sharps be picked up by the hands. Forceps in the first aide cabinet shall be used to hold and move contaminated needles and sharps. After use, sharps shall be placed into the sharps containers as soon as possible. The sharps containers are puncture resistant, leak proof, and marked with a biohazard label.
Sharp containers are located in each department.
Department Foreperson is responsible for contacting the Program Coordinator when the sharps container is full and the Program Coordinator performs the proper disposal.
When a new employee comes to the facility or an employee changes jobs, the following will take place:
If the employee moves from one job to another within the facility, the job classification and tasks relating to their previous positions are reviewed.
The employee's job classification and the tasks that they administer are checked against the job classifications and task list.
Based on number 1 and 2 above, new job classifications or tasks are checked against the Bloodborne Pathogen Plan and ensures the employee receives training in areas he or she has not been trained.
The employee is then trained by the Program Coordinator or another qualified instructor regarding any administrative and engineering controls. This includes employees who have not received any formal training in Bloodborne Pathogens.
4.6.5 Personal Protective Equipment
Personal Protective Equipment is the employees' final opportunity against Bloodborne Pathogens. The facility provides free of charge, the personal protective equipment to employees that is a necessity to protect workers against Bloodborne Pathogen exposure. This equipment includes in various sizes:
Safety Glasses or Goggles
Mouth Protectors for CPR
The Program Coordinator is diligently committed to working with the Owner, Department Managers, and Forepersons and making sure that all work areas provide appropriate personal protective equipment easily available for all employees. Employees are educated in using appropriate personal protective equipment for their job functions. Additional training is provided if an employee takes a new position or if a new job function changes or if additional duties such as being on the Emergency Response Team are added. Any needed training is provided by their manager or foreperson in tandem with the facility's Program Coordinator.
Making sure that personal protective equipment is not contaminated and is well-suited to protect employees from potential exposures; the facility adheres to:
All personal protective equipment is inspected at the beginning of the month and after an occupational exposure. All personal protective equipment is repaired, or if needed, to be replaced in order to continue its effectiveness.
Reusable personal protective equipment is decontaminated.
One-time usage of personal protective equipment or equipment does not have the ability to be decontaminated, will be discarded into a disposable biohazard bag and placed in a biohazard container.
Using protective equipment as effectively as possible, the employees must adhere to these following procedures when using their personal protective equipment:
Before leaving the work area, all potentially contaminated personal protective equipment is removed.
Gloves are worn in all events that a Bloodborne Pathogen possibly exists.
Disposable gloves are disposed of immediately after contamination if ripped, punctured, or lose their ability to be a well-suited exposure barrier.
Utility gloves are sanitized for re-using, however, if the gloves have any signs of functionality loss, the glove is immediately and properly disposed.
Masks and eye protection are used to protect against splashes of contaminated materials.
The facility practices maintaining "clean and sanitary conditions" (OSHA Standards for the General Industry, 2000, p. 590) as a paramount part of our Bloodborne Pathogen procedures. Using this schedule, the cleaning employees follow these practices:
The area to be cleaned and sanitized before work leaves for the day and optimally before the end of a shift.
Scheduled work date and times.
Any particular instructions that is needed.
The cleaning employees shall follow these practices:
"All equipment and environmental and working surfaces are cleaned and decontaminated after contact with blood or other potentially infectious materials."
(OSHA Standards for the General Industry, 2000, p. 590)
Protective coverings are "removed or replaced." (OSHA Standards for the General Industry, 2000, p. 590) This is done as soon as possible, if there is any potential for contamination.
All containers inside the facility containing trash shall be inspected, cleaned, and decontaminated; particularly if the ability of contamination exists.
Contaminated broken glassware will never in any circumstances be picked up with the hands directly. Dustpans, brushes, and forceps are the required method for picking up and moving contaminated broken glassware along with wearing proper personal protective equipment to an appropriate biohazard container.
Dano's Manufacturing takes precautions in relation to handling regulated wastes, including used bandages and "other potentially infectious materials." (OSHA Standards for the General Industry, 2000, p. 587) The following procedures are to be followed, in regards to handling of these types of regulated waste:
Regulated waste are to shall be discarded and placed in containers that are:
- Free of the ability to be punctured
- Free of all potential leaks
- Having a red biohazard label.
Containers for regulated waste are placed in proper locations in the facility. These containers are easily accessible and are positioned as closely as possible to the waste source.
Waste containers are positioned upright and emptied regularly to prevent contaminated overfill.
Contaminated laundry is carefully and minimally handled. Employees shall not place contaminated laundry with the regular laundry under no circumstances.
Whenever employees move containers of contaminated waste from place to place, the containers are closed. Then placed inside a secondary container, if there is possibility of leakage from the original container.
4.7 Hepatitis B Vaccination
Even when all proactive measures are taken, exposure to Bloodborne Pathogens is still possible. Dano's Manufacturing provides a Hepatitis B Vaccination Program as an additional preventative measure to Hepatitis B exposure. Reactively, Dano's Manufacturing also provides evaluation for post-exposure incidents and successive follow-ups.
4.7.1 Vaccination Program
The Hepatitis B Vaccination Program is free and must be available to all employees, who have the threat occupational exposure to Bloodborne Pathogens. The vaccination program consists of a series of three shots over a six-month period. During Bloodborne Pathogens training, employees are educated in Hepatitis B vaccinations, including its safety, risks, and effectiveness. The Program Coordinator is responsible for establishing and maintaining the vaccination program. Vaccinations are performed under the "supervision of a licensed physician or other health care professional." (OSHA Standards for the General Industry, 2000, p. 592) Employees are made aware of the vaccination program during their Bloodborne Pathogens training.
4.7.2 Post-Exposure Evaluation and Follow-Up
If an employee is involved in an accident where exposure to Bloodborne Pathogens could have happened, the following two points are initially focused on:
Employees receive medical review and treatment as expeditiously as possible.
Investigating the circumstances surrounding the exposure incident.
The Program Coordinator investigates every exposure incident as soon as possible and completes an accident form.
The facility ensures the employees receive the most optimal and expeditious treatment possible. If an exposure to Bloodborne Pathogens happens, a detailed post-exposure evaluation and successive follow-ups are incorporated. The following steps happen when occupational exposure occurs:
The method and events under which the exposure happened are recorded.
A concerted effort is made to identify the source of the exposure.
The source individual's blood will be tested to determine HBV and HIV status. This information will be conveyed to the exposed employees, after the results are obtained. If the source proves to be infectious, a follow-up visit with a qualified healthcare provider to inform the employee of current and future health issues. Upon evaluation of the exposed employee, and discussion of any unusual symptoms the employee may be noticing, the healthcare professional will recommend a treatment plan.
4.7.3 Information Provided to the Healthcare Professional
Assisting healthcare professionals we partner with, the following items are submitted to them:
A copy of the Bloodborne Pathogens Standard.
A description of the exposure accident report.
The exposed employee's relevant medical records.
Additional information as necessary.
4.8 Medical Record Keeping
The Program Coordinator is responsible for employees' medical records which include the following:
Social Security Number of the employee.
A copy of the employee's Hepatitis B Vaccination Status with vaccination dates.
"Medical records relative to the employee's ability to receive vaccination."
(OSHA Standards for the General Industry, 2000, p. 592)
All medical documentation will be provided to the employee who had an occupational exposure.
The facility recognizes the importance to keep the information in employee's medical records confidential. The facility will not reveal any medical records to anybody without the consent of any affected employee, except as required by law.
Labels and Signs
A Biohazard Warning Label Program is instituted within the facility. The Program Coordinator
is responsible for administering and maintaining the program. The following facility's items are
labeled in accordance with biohazard labels:
Containers of regulated waste.
If specific portions of equipment are contaminated, they are labeled accordingly, in the affected areas.
4.10 Information and Training
Well educated employees are imperative when eradicating or reducing the employee's exposure to Bloodborne Pathogens. All at risk employees are put through a rigorous training program and provided with as much information as possible. Additional training will be given if an employee's job roles or tasks change and puts them at risk of occupational exposure. The Program Coordinator shall be responsible for administering the Bloodborne Pathogens Program training to all employees who have possible exposure.
4.10.1 Training Topics
The OSHA Bloodborne Pathogen Standard.
The cause, effect, and symptoms of Bloodborne Pathogens.
Transmission modes for Bloodborne Pathogens.
Where to obtain copies a written copy of Bloodborne Pathogen procedures.
Activities that may heighten the ability of exposure to Bloodborne Pathogens.
Applications and the shortcomings of methods that will reduce exposure:
- Engineering Controls
- Work Practice Controls
Personal protective equipment includes:
- Location with the facility
- Type and proper usage
- Disposal and Removal
- Properly handling
- Decontamination procedures and equipment
Visual aids of biohazards including signs, labels and color-coded containers.
Hepatitis B Vaccine pertinent information:
- Beneficial change
- Administration method
- Vaccination advantages
- The facility's free vaccination programs
Time is of the essence and emergency actions are taken when any employee or contractor comes in contact with "blood or potentially infectious materials." (OSHA Standards for the General Industry, 2000, p. 587)
Incident reporting and explanation of this procedure to employees.
Evaluation of post-exposure and follow-up information through medical professionals at no cost to the employee.
4.10.2 Training Methods
The facility's training includes:
Session components and summary.
Names and certifications of instructors.
Employees' position and names that attended training.
Dates of all training sessions
The training records are available for employees, employees' representatives, OSHA, and OSHA's representatives.
Plan Date Reviewed: 8/6/2010
Next Review Date: 8/6/2011
Hepatitis B Vaccine Declination Form
"I understand that due to my occupational exposure to blood or other potential infectious materials I may be at risk of acquiring hepatitis B virus (HBV) infection. I have been given the opportunity to be vaccinated with hepatitis B vaccine, at no charge to myself. However, I decline hepatitis B vaccination at this time. I understand that by declining this vaccine. I continue to be at risk of acquiring hepatitis B, a serious disease. If in the future I continue to have occupational exposure to blood or other potentially infectious materials and I want to be vaccinated with hepatitis B vaccine, I can receive the vaccination series at no charge to me." (OSHA Standards for the General Industry, 2000, p. 594)
Employee Signature: ______________________ Date: ___________________
Coordinator Signature: _____________________ Date: ___________________
Dano's Manufacturing Training Notification Form