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The purpose of the Bloodborne Pathogens Standard (29 CFR 1910.130) is to "reduce occupational exposure to Hepatitis B virus (HBV), Human Immunodeficiency Virus (HIV) and other Bloodborne Pathogens" that employees may encounter and be exposed to in their workplace.
Bloodborne Pathogen: Pathogenic microorganisms that are present in human blood and can cause disease in humans.
Exposure: Contact with the eyes, mucous membranes, skin or parenteral contact with blood or other potentially infectious materials.
Parenteral: Taken into the body other than through the digestive tract like intravenous or intramuscular injection.
There are three major "Categories of Responsibility" that are central to the effective implementation of the exposure plan.
The Program Coordinator
Owner, managers, forepersons and Emergency Response Team
3.1 Program Coordinator
The Program Coordinator is responsible for overall management 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 typically include, but are not limited to:
Overall responsibility of implementing the Bloodborne Procedures for the entire facility.
Working with management and employees to develop and administer any additional Bloodborne Pathogens related policies and practices needed to support and effect the implementation of this plan.
Looking for ways to improve, revise or update the Exposure Control Plan as necessary.
Knowing current legal requirements concerning Bloodborne Pathogens.
Acting as facility liaison during OSHA inspections.
Conducting periodic facility audits to maintain an up-to-date Bloodborne Procedures.
The Program Coordinator is 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 Program Coordinator:
Maintaining an up-to-date list of facility personnel requirement training, in conjunction with facility management.
Developing suitable education and training programs.
Preparing periodic training documentation such as "Sign-in-Sheets", quizzes, etc.
Periodically reviewing the training programs with the Owner, Department Managers, Forepersons, Emergency Response Team, and employees to include appropriate new information.
3.1.2 Production Managers and Supervisors
The president, department managers, forepersons and Emergency Response Team are responsible for exposure control in their respective areas. They work directly with the Program Coordinator and the employees to ensure that proper exposure control procedures are followed.
The facilities activities and employees have the most important role, in our Bloodborne
Pathogens compliance program; ultimate execution of our Exposure Control Plan rest in their
hands. In this role employees must do things such as:
Know which tasks they perform that have the potential to create exposure to Bloodborne Pathogens.
Attend the Bloodborne Pathogens training sessions.
Plan and conduct all operations in accordance with the work practice controls.
Develop and maintain good personal hygiene habits.
Dano's Manufacturing believes there are a number of general principles that should be followed when working with Bloodborne Pathogens:
The risk of exposure to Bloodborne Pathogens should never be underestimated.
It is prudent to eradicate all exposure to Bloodborne Pathogens.
The facility shall institute as many administrative and engineering controls as possible to eliminate or minimize employee exposure to Bloodborne pathogens.
4.1. Availability of the Exposure Control Plan to Employees
Dano's Properties Bloodborne Pathogen Work Procedures is available on the company's electronic network. Employees are advised of this availability during their training 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 also be updated whenever the following circumstances occur:
Whenever new or modified tasks and procedures are implemented which affect occupational exposure of our employees.
Whenever a new position entails possible exposure to Bloodborne Pathogens.
4.2 Exposure Determination
One of the keys to implementing a successful Bloodborne Pathogens Control Plan is to identify exposure situations employees may encounter. Helping with this, Dano's Manufacturing have prepared the following lists:
Job classification where some employees may affect employee's exposure to bloodborne pathogens.
Whenever a new job position entails possible exposure to Bloodborne Pathogens.
The Program Coordinator will work with the President, Managers, Forepersons, and Emergency Response Team to revise and update these lists, procedures, and classifications when changed.
4.3 Job Classifications Where Some Employees May Have a Greater Likelihood of 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
4.4 Work Activities Involving Potential Exposure to Bloodborne Pathogens
Below are listed the tasks and procedures in the facility where employees may come into contact with human blood or other potentially infectious material, resulting possible exposure to Bloodborne Pathogens.
Tasks/Procedures Job Classifications
First Aid & CPR See 4.3
Even though many employees may be trained in CPR and/or First Aid, only designated employees (see 4.3) should respond in an emergency situation.
4.5 Methods of Compliance
The following four items are standardized across all aspects of Dano's Manufacturing:
The use of "Universal Precautions"
Establishing appropriate Engineering Controls.
Implementing Appropriate Work Practices.
Using necessary Personal Protective Equipment
4.5.1 Universal Precautions
As a result of practicing "Universal Precautions," Dano's Manufacturing shall treat all human blood and body fluids if they are known to be infectious for HIV, Hepatitis B and other Bloodborne Pathogens.
4.5.2 Engineering Controls
One of the key aspects the Bloodborne Pathogen plan is the use of Engineering Controls to eliminate or minimize employee exposure to Bloodborne Pathogens. As a result, the employees listed in 4.3 will utilize cleaning, maintenance, and other equipment designed to prevent contact with blood or other potentially infectious materials.
The Program Coordinator periodically works with the president, department managers, forepersons and the Emergency Response Team to advise the facility where engineering controls can be implemented or updated.
4.5.3 Work Practice Controls
In addition to engineering controls, the facility uses a number of work practice controls to help eliminate or minimize exposure to Bloodborne Pathogens
The Program Coordinator is responsible for overseeing the implementation of work practice controls. This person works in conjunction with the owner, managers, forepersons, and the Emergency Response Team.
Employees shall wash their hands immediately, or as soon as feasible, after removal of contaminated gloves or other personal protective equipment.
Following any contact of body areas with blood or any other infectious materials, employees shall wash all exposed body surfaces with soap and water. Eyes or other areas of the body where soap itself could itself be deleterious shall at a minimum, be flush with water.
Appropriate biohazard warning labels is attached to any contaminated equipment.
Information regarding the remaining contamination is conveyed to affected employee, equipment manufacturer, and equipment service representative prior to handling, servicing, or shipping.
4.5.4 Contaminated Needles and Sharp Containers
Contaminated needles and other contaminated sharps will not be bent, recapped, removed, sheared, or purposely broken. Under no circumstances that contaminated needles and sharps be picked up by the hands. Toggles in the first aide cabinet shall be used to hold and move contaminated needles and sharps.
The sharps are to be place immediately, or as soon as possible or after use into appropriate sharps containers. The sharps containers are puncture resistant labeled with a biohazard label and are leak proof.
Sharp containers are located in each department.
Department Forearm is responsible for removing sharps from containers and contacting the Program Coordinator for proper disposal.
When a new employee comes to the facility or an employee changes jobs within the facility, the follow process takes place to ensure that they are trained in the appropriate work practice controls:.
The employee's job classification and the tasks that they will perform are checked against the job classifications and task list which w e have identified in our Bloodborne Pathogen Plan as those in which occupational exposure occurs.
If the employee is transferring from one job to another with our facility, the job classification and tasks pertaining to their previous positions are also checked against this list.
Based on this "cross-checking" the new job classification tasks which will bring the employee into occupational exposure situation are identified.
The employee is then trained by the facility Program Coordinator or another instruction regarding any work practice controls that the employee is not experienced.
4.5.5 Personal Protective Equipment
Personal Protective Equipment is the employees' "last line of defense" against Bloodborne Pathogens. The facility provides at no cost to the employees the personal protective equipment that is needed to protect workers against Bloodborne Pathogen exposure. This equipment includes but not limited to:
The Safety Program Coordinator is working with the president, managers and forepersons and is responsible for ensuring that all departments and work areas have appropriate personal protective equipment available to all employees.
The employees are trained regarding the use of the appropriate personal protective equipment for their job classifications and tasks they perform. Additional training is provided if an employee takes a new position or if new job functions are added to their position.
Determining whether additional training is needed, the employees' previous job classification and tasks are compared to those for any new job or function undertaken. Any needed training is provided by their manager or foreperson working with the facility's Program Coordinator.
Ensuring personal protective equipment is not contaminated and is in the appropriate condition to protect employees from potential exposures; the facility adheres to the following practices:
All personal protective equipment is inspected periodically and repaired or replace as need to maintain its effectiveness.
Reusable personal protective equipment is cleaned laundered and decontaminated as needed.
Single-use personal protective equipment or equipment that cannot be decontaminated will be disposed of into a disposable biohazard container.
Making sure that this protective equipment is used as effectively as possible, the employees adhere to the following practices when using their personal protective equipment:
All potentially contaminated personal protective equipment is removed prior to leaving a work area.
Gloves are worn in the following circumstances:
- Whenever employees anticipate hand contact with potentially infectious materials
- When handling or touching contaminate items or surfaces.
Disposable gloves are replaced as soon as practical after contamination of they are torn, punctured or otherwise lose their ability to function as an exposure barrier.
Utility gloves are decontaminated for reuse unless they are cracked, peeling torn or exhibit others signs of deterioration at which time they are disposed.
Masks and eye protection (goggles, face shield, etc.) are used splashed or sprays may generate droplets of infectious materials.
Protective clothing (such as a coat) is worn whenever potential exposure to the body is anticipated.
Maintaining the facility in a clean and sanitary condition is an important part of our Bloodborne Pathogens Procedures. We have written a schedule for cleaning and decontamination for the appropriate areas of the facility.
The area to be clean and decontaminated before work leaves for the day.
Day and time of scheduled work.
Any special instructions that is appropriate.
Using this schedule, our cleaning staff employs the following practices:
All equipment and surfaces are clean and decontaminated after contact with blood or other potentially infectious materials:
- Immediately or as soon as feasible when surfaces are contaminated.
- At the end of the work shifts if the surface may have been contaminated during the shift.
Protective coverings (such as plastic trash bags or wrap, aluminum foil or absorbent paper are removed or replaced:
- As soon as it is feasible when overtly contaminated.
- At the end of the work shift if they may have been contaminated using the work shift.
All trash containers, pails, bins and other receptacles intended for use routinely are inspected, cleaned and decontaminated as soon as possible if visibly contaminated.
Potentially contaminated broken glassware is picked up using mechanical means such as dustpan and brush, tongs, forceps, etc.
Dano's Manufacturing carefully handles regulated wastes including bandages and other potentially infectious materials.
The following procedures are used with all of these types of wastes:
They are discarded or bagged in containers that are:
- Puncture resistant if the discarded material have the potential to penetrate the container.
- Leak-proof if the potential for fluid spill or leakage exists.
- Red in color or label with the appropriate biohazard label.
Containers for this regulated waste are placed in appropriate location in our facility within easy access of our employees and as close as possible to the source of the waste.
Waste containers are maintained upright, routinely emptied and not allow to overfill.
Contaminated laundry is handled as little as possible and is not sorted or rinsed. The contaminated laundry will be placed in the area where used. Employees shall not place contaminated laundry with the regular laundry under no circumstances.
Whenever our employees move containers of regulated waste from one area to another area the containers are immediately closed and placed inside an appropriate secondary container if the leakage is possible form the first container.
4.6 Hepatitis B Vaccination
Everyone in our facility recognize threats even with good adherence to all of our exposure prevention practices, implementation of a Hepatitis B Vaccination Program, as well as, set up procedures for post-exposure evaluation and follow-up should exposure to Bloodborne Pathogens occur.
4.6.1 Vaccination Program
Protecting the employees as much as possible from the possibility of Hepatitis B infection, the facility has implemented a vaccination program. This program is available, at no cost to all employees, who have occupational exposure to Bloodborne Pathogens.
The vaccination program consists of a series of three inoculations over a six-month period. During Bloodborne Pathogens training our designated employees for training are educated in Hepatitis B vaccinations, including its safety, risks and effectiveness.
The Program Coordinator is responsible for setting up and operating our vaccination program. Vaccinations are performed under the supervisor of a license physician or other health care professional.
Ensuring all employees are aware of our vaccination is thoroughly discussed in our Bloodborne Pathogens training.
4.6.2 Post-Exposure Evaluation and Follow-Up
If one of our employees is involved in an accident where exposure to Bloodborne Pathogens may have occurred, there are two things that we immediately focus our efforts on:
Investigating the circumstances surrounding the exposure incident.
Making sure that the employees receive medical consultation and treatment if required as expeditiously as possible.
The Program Coordinator investigates every exposure incident that occurs hours after the incident occurs and involves completing an accident form.
In order to make sure that the employees receive the best and most timely treatment if an exposure to Bloodborne Pathogens occurs, the facility has set up a comprehensive post-exposure evaluation and follow-up process. As the first step in this process, we provide an exposure and circumstances under which the exposure incident occurred.
Documentation regarding the routes of exposure and circumstances under which the exposure incident occurred.
Identification of the source individual unless infeasible or prohibited by law.
Next, if possible, we will test the source individual's blood to determine HBV and HIV infectivity. This information will also be made available to the exposed employee. The employee will be made aware of the identity and infectious status of a source individual.
Then the facility collects and test blood of the exposed employee for HBV and HIV status.
Once these procedures have been complete, an appointment is arranged for the exposed employee with qualified healthcare professional to discuss the employee's medical status. This professional is to discuss the employee's medical status. This includes an evaluation of reported illnesses, as well as any recommended treatment.
4.6.3 Information Provided to the Healthcare Professional
Assisting the healthcare professional, we forward a number of comments to them, including the following:
A copy of the Bloodborne Pathogens Standard.
A description of the exposure accident.
The exposed employee's relevant medical records.
Other pertinent information.
4.7 Medical Record Keeping
Making sure that we have as much medical information available to the participating healthcare profession as possible, the facility maintains comprehensive medical records on the employees. The Program Coordinator is responsible for setting up and maintaining these records includes the following information:
Name of the employee.
Social Security Number of the employee.
A copy of the employee's Hepatitis B Vaccination Status
-Dates of any vaccinations.
- Medical records relative to the employee's ability to receive vaccination.
Copies of the results of the examination, medical testing, and follow-up procedures which took place as a result of an employee's exposure to Bloodborne Pathogens.
As with all information in these areas, we recognize that it is important to keep the information in these medical records confidential. We will not disclose or report this information to anyone with our employee's written consent except as required by law. These requirements will be implemented and updated.
4.7 Labels and Signs
One of the most obvious warnings of possible exposure to Bloodborne Pathogens is biohazard labels. Because of this, the facility has implemented a comprehensive biohazard warning labeling program in our facility. The Program Coordinator is responsible for setting up and maintaining this program in the facility.
The following items in our facility have been labeled:
Containers of regulated waste.
Contaminated equipment will have labels affixed to the contaminated equipment. The facility also indicates which portions of the equipment are contaminated.
We recognize that biohazards signs must be posted at entrances to HBV and HIV research laboratories and production facilities. However, we do not have these types of operations in our facility, so we are not affected by these special signage requirements.
4.7 Information and Training
Well informed and educated employees are important when attempting to eliminate or minimize the employee's exposure to Bloodborne Pathogens. All employees who have the potential for exposure to Bloodborne Pathogens are put through a comprehensive training program and furnished with as much information as possible.
This program was established so employees will receive the required training to keep their knowledge current. Additionally all new employees, as well as employees changing jobs or job function will be given any additional training to their new position requires at the time for their new job assignment.
The Program Coordinator is responsible for seeing that all employees who have potential exposure to Bloodborne Pathogens receive this training.
4.8 Training Topics
The topics covered in the training program will include, but are not limited to the following:
The Bloodborne Pathogen standard itself.
The epidemiology and symptoms of Bloodborne Pathogens.
The modes of transmission for Bloodborne Pathogens.
Our facility's exposure control plan and where employees can obtain a copy.
Appropriate methods for recognizing tasks and other activities that may involve exposure blood or other potentially infectious materials.
A preview of the use and limitation of methods that will prevent or reduce exposure, including:
- Engineering controls
- Work Practice Controls
Selection and use of personal protective equipment including:
- Types available
- Proper use
- Location within the facility
Visual warning of biohazards within the facility including labels, signs and "color-coded" containers.
Information on Hepatitis B Vaccine, include its:
- Method of administration
- Benefits of vaccination
- Our facility's free vaccination programs
Actions to take a person to contact in an emergency involving blood or other potentially infectious materials.
The procedures to follow if an exposure incident occur, including incident reporting.
Information on the post-exposure evaluation and follow-up, including medical consultation that our facility will provide.
4.9 Training Methods
The facility's training presentation makes use of several training techniques including, but limited to those checked by below:
Dates of all training sessions.
Contents/summary of the training sessions.
Names and qualification for the instructors.
Names and job titles of employees attending the training sessions.
These training records are available for examination and copying to our employees and their representative as well as OSHA and its representatives.