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Bloodborne Pathogens Section V

V - METHODS OF COMPLIANCE

            A.   The following areas must be addressed in order to effectively eliminate or minimize exposure to bloodborne pathogens in County facilities:

                        1.   The use of universal precautions;

                        2.   Establishing appropriate engineering controls;

                        3.   Implementing appropriate work practice controls;

                        4.   Using necessary personal protective equipment; and                        

                        5.   Implementing appropriate housekeeping procedures.

            B.   Each of these areas is reviewed with employees during their bloodborne pathogens related training (see the "Information and Training" section of this Plain for additional information).   By rigorously following the requirements of OSHA's Bloodborne Pathogens Standard in these five areas, employees' occupational exposure to bloodborne pathogens will be eliminated or minimized as much as possible.

                        1.   Universal Precautions:

                        The County practices universal precautions; therefore, we treat all human blood and bodily fluids as if they are known to be infectious for HBV, HCV, HIV and other bloodborne pathogens.   Examples of bodily fluids include, but are not limited to: vomitus, vaginal secretions, semen and stool.

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

                        2.   Engineering Controls:

                        One of the key aspects of our ECP 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 Risk Manager shall periodically work with department managers and supervisors to review tasks and procedures performed in our facility where engineering controls can be implemented or updated.   Each department head or designated employee shall inspect on a regular basis engineering control equipment for proper function and needed repair or replacement to ensure their effectiveness.

                        Engineering controls in our facility include, but are not limited to:

                                    a.   Hand washing facilities (or antiseptic hand cleanser and towels or antiseptic towelettes), which are readily accessible to all employees who have potential for exposure;

                                    b.   Needle devices that effectively reduce the risk of an exposure incident;

                                    c.   Containers for contaminated sharps which have the following characteristics                        

                                                i)   Puncture-resistant

                                                ii)  Color-coded or labeled with a biohazard warning label; and

                                                iii) Leak-proof on the side and bottom.

                                    d.    Specimen containers which are:

                                                i)   Leak-proof

                                                ii)  Color-coded or labeled with a biohazard warning label; and

                                                iii) Puncture-resistant, if necessary.

                      3.   Work Practice Controls:

                      In addition to engineering controls, the County uses a number of work practice controls to help eliminate or minimize employee exposure to bloodborne pathogens.   Many of these work practice controls have been in effect for some time.

                                  a.   Each department head or designated employee is responsible for overseeing the implementation of the following work practice controls within their department:

                                             i) Employees wash their hands immediately, or as soon as feasible, after removal of potentially contaminated gloves or other personal protective equipment;           

                                             ii) Following any contact of body areas with blood or any other infectious materials, employees wash their hands and any other exposed skin with soap and water as soon as possible. They also flush exposed mucous membranes with water;

                                             iii) Contaminated needles and other contaminated sharps are not bent, recapped or removed unless it can be demonstrated that there is no feasible alternative or the action is required by specific medical procedure.            In the two situations above, the recapping or needle removal is accomplished through the use of a medical device or a one-handed technique.

                                             iv) Contaminated reusable sharps are placed in appropriate containers immediately, or as soon as possible, after use;

                                             v) Eating, drinking, smoking, applying cosmetics or lip balm and handling contact lenses is prohibited in work areas where there is potential for exposure to bloodborne pathogens;

                                             vi) Food and drink is not kept in refrigerators, freezers, on countertops or in other storage areas where blood or other potentially infectious materials are present;

                                             vii) Mouth pipetting/suctioning of blood or other infectious materials is prohibited;

                                             viii) Specimens of blood or other potentially infectious materials are placed in designated leak-proof containers, appropriately labeled, for handling and storage;

                                             ix) If outside contamination of a primary specimen container occurs, that container is placed within a second leak-proof container, appropriately labeled, for handling and storage.   (If the specimen can puncture the primary container, the secondary container must be puncture-resistant as well);              

                                             x) Equipment which becomes contaminated is examined prior to servicing or shipping and decontaminated as necessary (unless it can be demonstrated that decontamination is not feasible);

                                             xi) An appropriate biohazard warning label is attached to any contaminated equipment, identifying the contaminated equipment, and identifying the contaminated portions; and

                                             xii) Information regarding the remaining contamination is conveyed to all affected employees, the equipment manufacturer and the equipment service representative prior to handling, servicing or shipping.

                                  b.   When a new employee comes to the County, or an employee changes jobs, the following process takes place to ensure that they are trained in the appropriate work practice controls:

                                             i) The employee's job classification and the tasks and procedures that they will perform are checked against the Job Classifications and Task Lists which have been identified in the ECP as those in which occupational exposure occurs;

                                             ii) If the employee is transferring from one job to another, the job classifications and tasks/procedures pertaining to their previous position are also checked against these lists;

                                             iii) Based on this "cross-checking" the new job classifications and/or tasks and procedures which will bring the employee into occupational exposure situations are identified; and

                                             iv) The employee is then trained by the facility training coordinator or another instructor regarding any work practice controls that the employee is not experienced with.

                      4.   Personal Protective Equipment:

                                  a.   Personal protective equipment is the "last line of defense" against bloodborne pathogens.   Because of this, the County provides (at no cost to our employees) the personal protective equipment they need to protect themselves against such exposure.   This equipment includes, but is not limited to:

        • Gloves
        • Eye protection
        • Goggles
        • Face shields/masks
        • Mouthpieces
        • Resuscitation bags, pocket masks or other ventilation devices
        • Hypoallergenic gloves, glove liners and similar alternatives are readily available to employees who are allergic to the gloves our facility normally uses.

                                  b.   Each department head or designated employee is responsible for ensuring that all work areas in their department have appropriate personal protective equipment for their job classifications and tasks or procedures they perform.   Additional training is provided, when necessary, if an employee takes a new position or new job functions are added to their current position.

                                        To determine whether additional training is needed, the employee's previous job classification and tasks are compared to those for any new job or function they undertake.   Any needed training is provided by their department manager or supervisor working with the County's training coordinator.

                                  c.   To ensure that personal protective equipment is not contaminated and is in the appropriate condition to protect employees from potential exposure, the County adheres to the following practices.

                                             i) All personal protective equipment is inspected periodically and repaired or replaced as needed to maintain its effectiveness;

                                             ii) Reusable personal protective equipment is cleaned, laundered and decontaminated as needed.

                                             iii) Single-use personal protective equipment (or equipment that cannot, for whatever reason, be decontaminated) is disposed of.

                                  d.   To make sure that this equipment is used as effectively as possible, our employees adhere to the following practices when using their personal protective equipment:

                                             i) Any garments penetrated by blood or other infectious materials are removed immediately, or as soon as feasible;

                                             ii) All personal protective equipment is removed prior to leaving a work area;

                                             iii) Gloves are worn in the following circumstances:

  • Whenever employees anticipate hand contact with potentially infectious materials;
  • When handling or touching contaminated items or surfaces.

                                             iv)   Disposable gloves are replaced as soon as practical after contamination or if they are torn, punctured or otherwise lose their ability to function as an "exposure barrier";

                                             v) Disposable (single use) gloves shall not be washed or decontaminated for reuse;

                                             vi) Utility gloves are decontaminated for reuse unless they are cracked, peeling, torn or exhibit other signs of deterioration, at which time they are disposed of;

                                             vii) Masks and eye protection (such as goggles, face shields, etc.) are used whenever splashes or spray may generate droplets of infectious materials; and

                                             viii) Protective clothing (such as gowns and aprons) shall be worn whenever potential exposure to the body is anticipated.

                      5.   Housekeeping:

                                  a.   Maintaining the County in a clean and sanitary condition is an important part of our ECP.   To facilitate this, the County has set up a written schedule for cleaning and the method of decontamination based upon the location within the facility, type of surface to be cleaned, type of soil present and tasks or procedures being performed in the area.   This schedule is attached as Exhibit "E."

                                  b.   Using this schedule, our janitorial/cleaning staff employs the following practices:

                                             i) All equipment and surfaces are cleaned and decontaminated after contact with blood or other potentially infectious materials;

                                             ii) After the completion of medical procedures;

                                             iii) Immediately (or as soon as feasible) when surfaces are overtly contaminated;

                                             iv) After any spill of blood or infectious material;

                                             v) At the end of the work shift if the surface may have been contaminated during that shift';

                                             vi) Protective covering 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 work shift if they may have become contaminated during the shift;

                                             vii) All pails, bins, and other receptacles intended for reuse which have a reasonable likelihood of becoming contaminated with blood or other potentially infectious materials are routinely inspected, cleaned and decontaminated on a regularly scheduled basis and are decontaminated immediately, or as soon as feasible, upon visible contamination.

                                             viii) Potentially contaminated broken glassware shall not be picked up by the hands and is to be picked up using mechanical means (such as dustpan and brush, tongs, forceps, etc.); and

                                             ix) Contaminated reusable sharps are stored in containers that do no require "hand processing."

                      The Deputy Director Building Services   is responsible for setting up the cleaning and decontamination schedule and making sure it is carried out within County facilities.

                                  c.   The County is also dedicated to carefully handling regulated waste (waste which contains recognizable fluid blood, fluid blood products, containers or equipment containing blood that is fluid).   The following procedures are used with all of these type of waste:

                                             i) They are discarded or bagged in containers that are:

          • Closable;
          • Puncture-resistant if the discarded materials have the potential to penetrate the container;
          • Leak proof if the potential for fluid spill or leakage exists;
          • Red in color or labeled with the appropriate biohazard warning label.

                                  d.   Containers for this regulated waste are placed in appropriate locations in our facility within easy access of our employees as close as possible to the sources of the waste.

                                  e.   Waste containers are maintained upright, routinely replaced and not allowed to overfill.

                                  f.   Laundry, which has been soiled with blood or other potentially infectious materials, is handled as little as possible and is not sorted or rinsed where it is used.   Contaminated laundry shall be placed and transported in appropriately labeled or color-coded containers.   Any employee handling contaminated laundry shall wear protective gloves and other appropriate personal protective equipment.

                                  g.   Whenever employees move containers of regulated waste from one area to another, the containers are immediately closed and placed inside an appropriate secondary container if leakage is possible from the first container.

                                  h.   Each department head or designated employee is responsible for coordinating with the Deputy Director Building Services for the collection and handling of our facility's contaminated waste.

 

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Copyright © 2001 County of Inyo
Last Updated: October 8, 2005 December 12, 2006