GBGAA-R - Exposure Control Plan
EXPOSURE CONTROL PLAN FOR BLOODBORNE PATHOGENS
In the interest of protecting employee health and safety, the Acton School Department
hereby adopts the Occupational Safety and Health Administration’s 29 CFR Part 1910.1030,
“Occupational Exposure to Bloodborne Pathogens; Final Rule” as part of its safety program.
The Superintendent/designee shall comply with Federal Occupational Safety and Health
Administration (OSHA) Standard (Title 29, Part 1910.1030) to prevent the spread of
bloodborne pathogens and other potentially infectious materials in the workplace. The
Superintendent/designee shall develop a written Exposure Control Plan designed to protect
employees from possible infection caused by contact with bloodborne pathogens as a result of
performing job duties. The bloodborne pathogens include but are not limited to human
immunodeficiency virus (HIV) and hepatitis B virus (HBV).
As part of the Exposure Control Plan, the Superintendent/designee shall determine which
employees could reasonably be expected to have exposure to bloodborne pathogens and other
potentially infectious materials contaminated with blood as a result of performance of job
duties shall participate in in-service education during their work hours and be offered hepatitis B vaccine at no cost.
Any employee not identified as having risk for occupational exposure in the school’s
exposure determination may petition to be included in the in-service education and/or hepatitis
B vaccination program. Any such petition shall be submitted to the Superintendent/designee who will evaluate the request and notify the petitioner of the decision.
The Superintendent/designee may deny a request when there is no reasonable anticipation of
contact with blood or contaminated materials as a result of job duties except when acting as a
Good Samaritan in giving first aid.
If an employee is exposed to the blood or other potentially infectious material contaminated
with blood of another person as a result of performing his/her job duties, the
Superintendent/designee shall, as part of the Exposure Control Plan, put in place a system for
immediate reporting of the exposure incident by an employee. Within 24 hours of the report,
the employee will seek medical attention by a licensed healthcare provider or agency for
which the school unit will provide payment at no cost to the employee. In addition, the school
unit will pay for a confidential medical evaluation and follow-up by a licensed health care
provider or agency at no cost to the employee.
Medical records will be maintained by the school unit for thirty years after the employment of
those employees who report exposure to bloodborne pathogens as a result of performance of
job duties. Further, the medical records will be stored in compliance with federal, state and
local laws regarding privacy and confidentiality of all medical records and any additional legal
protection for information related to HIV infection and AIDS. Records of participation in in-
service programs provided by the school unit for employees will be compiled and maintained
for three years.
Purpose:
In accordance with the OSHA Bloodborne Pathogens Standard, 29 CFR 1910.1030
the following exposure control plan has been developed.
Scope:
This plan is to cover all Acton School Department employees who could be
“reasonably anticipated,” as the result of performing their job duties, to be exposed to
blood and other potentially infectious materials.
Infectious materials include semen, vaginal secretions, cerebrospinal fluid, pleural fluid,
pericardial fluid, amniotic fluid, saliva in dental procedures, and body fluid visibly
contaminated with blood, and all body fluids in situations where it is difficult or
impossible to differentiate between body fluids. They also include any unfixed tissue or
organ other than intact skin from a human (living or dead) and human
immunodeficiency virus (HIV) containing culture medium or other solutions as well as
blood, organs, or other tissues from experimental animals infected with HIV or HBV.
Exposure Control Plan:
A. Identify job classifications for Acton faculty, staff and administration where
occupational exposure to blood occurs without regard to personal protective
clothing or equipment.
B. Identify tasks associated with the above classifications. Task defined: Any
activity which involves the handling of or possibility of handling of blood or
other potentially infectious materials as described above.
Exposure determination:
OSHA requires employers to perform an exposure determination identifying which
employees may incur occupational exposure to blood or other potentially infectious materials. The exposure determination is made without regard to the use of
personal protective equipment (i.e., employees are considered to be exposed even if
they wear personal protective equipment). This exposure determination is required to
list all job classifications in which all employees may be expected to incur such
occupational exposure, regardless of frequency. Within this school unit the following
job classifications are in this category:
Classification I Tasks and Procedures
School Nurses First Aid, Care of the sick, Decontamination of the
environment, ADL’s
In addition, OSHA requires a listing of job classifications in which some employees
may have occupational exposure. Since not all the employees in these categories would
be expected to incur exposure to blood or other potentially infectious materials, tasks or
procedures that would cause these employees to have occupational exposure are also
required to be listed.
Classification II Tasks and Procedures
Athletic Trainers and/or any First Aid, Care of the sick,
other school employee whose Decontamination of the environment
job description requires them
to administer first aid.
Employee Awareness:
This plan will be accessible to Acton School Department employees through the
following means:
A. Copies of the plan are to be posted in all school facilities where there are
employees in the identified classifications.
B. Copies of the plan will be sent to all administrative personnel for insertion into the
policy book.
C. Training of employees will be done on a yearly basis.
Annual Review and Update:
At the end of each school year, the policy/plan is to be analyzed and updated. The
review will be conducted by Acton School Department health personnel, a
representative from personnel, the Superintendent and a representative of
the Safety Committee. The updated plan will be distributed to those indicated in the
previous section.
Implementation Schedule and Methodology:
OSHA requires that this plan also include a schedule and method of implementation for
the various requirements of the standard. The following complies with this requirement.
A. Compliance Methods
Universal precautions will be observed in this school unit to prevent contact with
blood or other potentially infectious materials. “Universal Precautions” is an
approach of infection control. The concept of universal precautions is that all
human blood and body fluids are treated as if known to contain disease-causing
germs (pathogens). It is not always possible to know when blood or body fluids
are infectious; therefore, all body fluids shall be handled as if infectious. All
employees shall routinely observe the following universal precautions to prevent
and reduce the spread of infectious disease.
B. Personal Protective Equipment
All personal protective equipment used in the school unit will be provided
without cost to employees. Personal protective equipment will be considered
appropriate only if it does not permit blood and other potentially infectious
materials to pass through or reach the employee’s clothing, skin, eyes, mouth or
other mucous membranes.
Gloves shall be worn where it is reasonably anticipated that employees will have
hand contact with blood, other potentially infectious material, non-intact skin,
and mucous membranes. Gloves will be used for the following procedures:
administering first aid, housekeeping tasks, nursing procedures (e.g.,
catheterization, suctioning, assisting an incontinent student, etc.). Gloves will be
available from health/nurse’s offices and custodial areas.
Wear disposable waterproof gloves whenever you expect to come into direct
contact with blood, other body fluids containing blood, or contaminated items
and surfaces. This applies to incidents including, but not limited to, caring for
nose bleeds or cuts, cleaning up spills, or handling clothing soiled by blood or
body fluids containing blood. Do not reuse gloves. After each use, remove
gloves without touching the outside and dispose of them in a lined waste
container.
C. Engineering controls
1. Sharps containers—located in appropriate health/nurse’s offices. These
containers will be examined and maintained on a regular schedule. When
sharps containers are full, the school nurse will be responsible for making
arrangements to having them transported to a licensed biomedical waste
facility. School nurses will inspect sharps containers with each use.
Contaminated needles and other contaminated sharps will not be bent,
recapped, or removed.
2. Handwashing facilities are available to employees who incur exposure to
blood or other potentially infectious materials. OSHA requires that these
facilities are readily accessible after incurring exposure. Within this school
unit handwashing facilities are located in most bathrooms, in most
custodial areas, in kitchen areas, in some classrooms, and in the
health/nurse’s offices.
After removal of personal protective gloves, employees shall wash hands
and any other potentially contaminated skin area with soap and water
immediately or as soon as feasible. All staff should routinely observe the
following universal precautions to prevent and reduce spread of infectious
disease:
a. Wash your hands and any other contacted skin surface thoroughly
for 15 to 30 seconds with dispensable soap and warm running
water, rinse under running water and dry thoroughly with
disposable paper towel.
1) Immediately after any accidental contact with blood, body
fluids, or drainage from wounds with soiled garments,
objects or surfaces;
2) Immediately after removing gloves or other protective
equipment or clothing;
3) Before assisting others with eating and drinking as well as
eating or drinking yourself;
4) Before handling food, cleaning utensils or kitchen
equipment; and
5) Before and after diapering and assisting with toileting, as
well as toileting yourself.
When running water is not available, use antiseptic hand cleanser
and clean towels or antiseptic towelettes and use soap and
running water as soon as feasible.
b. Clean surfaces and equipment contaminated with blood with soap
and water and disinfect them promptly with a fresh germicide (ten
parts water to one part bleach) or other disinfectant. While
cleaning, wear disposable gloves and use disposable towels
whenever possible. Rinse mops or other reusable items in the
disinfectant and dry thoroughly.
c. Properly dispose of contaminated material and label them as
biohazards.
1) Place blood, body fluids, gloves, bloody dressings and
other materials soaked with blood into appropriately labeled
plastic bags or lined waste containers. Sharp disposable
objects shall be disposed of in leak-proof, puncture-proof
containers.
2) Bag soiled towels and other laundry and send it home.
3) Dispose of urine, vomit, or feces in the sewer system.
d. Do not care for others’ injuries if you have any bleeding or oozing
wounds or skin conditions yourself.
e. Use a mouthpiece, resuscitation bag or other ventilation device
when readily available when it is necessary to provide
mouth-to-mouth resuscitation.
f. Immediately report any incident of accidental exposure to blood or
first-aid incident that involved direct contact with blood in
accordance with school unit policies about accident reporting and
exposure.
D. Housekeeping/Decontamination of Environment
The following school facilities will be cleaned daily and after each body fluid
spill: all bathrooms; all health/nurse’s offices; all administrative areas; all daily
use sink areas; and all water fountains.
Decontamination will be accomplished by utilizing the following materials:
A bleach solution: (1 part bleach to 10 parts water) (1:10 mixed when
needed and not allowed to stand longer than 24 hours) or Germicide.
All contaminated work surfaces will be decontaminated after completion of
procedures, immediately after any spill of blood or other potentially infectious
materials, and at the end of the work shift. All equipment (e.g., mops, brushes,
dust pans) used in cleaning up potentially contaminated materials will be
decontaminated immediately. All mops, brushes, bins, pails, cans and similar
receptacles shall be inspected regularly and by custodians on a daily basis.
Plastic bags in waste receptacles located in health/nurse’s offices and all
bathrooms will be changed daily.
Any broken glassware which may be contaminated will not be picked up directly
with the hands. The following procedures will be used: brush and dustpan will
be used to assist picking up contaminated glass. Potentially contaminated glass
will be placed in a puncture-proof biohazard container.
Handle contaminated laundry in areas of use. Always use appropriate personal
protective equipment when handling contaminated laundry. Before transporting,
place contaminated laundry in a leak proof plastic bag and send it home.
E. Hepatitis B Vaccine
All employees who may have occupational exposure to
blood or other potentially infectious material (classification I and II) will be offered
the Hepatitis B vaccine at no cost to the employee.
Employees must sign the Bloodborne Pathogen Mandatory Declaration Statement indicating their consent, declination, or provide previous proof of vaccination. Employees who initially decline the vaccine but who later wish to have it may have the vaccine
provided at no cost.
The vaccine will be offered yearly.
First read: October 10, 2024