BLOODBORNE PATHOGENS EXPOSURE CONTROL PLAN

This Bloodborne Pathogens (BBP) Exposure Control Plan (Plan) is established to eliminate or minimize employee occupational exposure to Bloodborne Pathogens (BBP) and Other Potentially Infectious Materials (OPIM) in accordance with OSHA Standard 29 CFR 1910.1030. The College is committed to providing a safe and healthy environment for its faculty, staff, student employees, visitors, and campus community.

This plan applies to college employees who may reasonably anticipate occupational exposure to human blood, blood components, human tissue, or human body fluids during the performance of their assigned job duties. Compliance with this plan is mandatory across all academic departments, athletic facilities, health services, research laboratories, and operational units.

2.1 Environmental Health & Safety (EHS) Department

• Management, implementation, and annual review of the Plan.
• Maintains program documentation, including training logs and biohazard disposal records.
• Assists departments in conducting hazard assessments and selecting appropriate Personal Protective Equipment (PPE).
• Identify covered job classifications and personnel within their operational areas.
• Works with Departments to recommend required PPE, engineering controls, and disposal supplies at no cost to employees.
• Enforce compliance with universal/standard precautions and campus work practice controls identified in the Plan.

2.2 Human Resources

• Assists the EHS department in launching the annual training program for covered employees.
• Coordinates with the College’s health plan and local providers to provide options for where an employee may obtain the Hepatitis B vaccine.
• Ensures post-exposure evaluation and medical follow-up procedures (see 6.2 Post-Exposure Medical Protocol) are fully accessible.

2.3 Employee Responsibilities

Employees whose position may put them at risk of exposure to bloodborne pathogens must:

• Comply strictly with all work practices, standard precautions, and safety guidelines outlined in this Plan.
• Properly utilize, maintain, and dispose of required PPE.
• Report all occupational exposure incidents, injuries, or unsafe conditions immediately to their direct supervisor and EHS.
• Participate in required annual BBP training.

OSHA 29 CFR 1910.1030 requires employers to perform an exposure determination without regard to the use of personal protective equipment. EHS is responsible for this. The exposure determination categorizes job positions into two distinct groups based on potential occupational exposure:

Category A: Job Classifications in which ALL Identified Employees have Occupational Exposure

Category B: Job Classifications in which SOME Employees have Occupational Exposure

4.1 Universal / Standard Precautions

All college personnel shall observe Universal / Standard Precautions. Under Universal Precautions, all human blood and certain human body fluids are treated as if known to be infectious for Human Immunodeficiency Virus (HIV), Hepatitis B Virus (HBV), Hepatitis C Virus (HCV), and other bloodborne pathogens, regardless of perceived risk or patient status.

4.2 Engineering and Work Practice Controls

Hierarchy of Controls engineering and work practice controls shall be used to eliminate or minimize employee exposure. Where occupational exposure remains after implementation of engineering controls, personal protective equipment shall be utilized.

• Sharps Disposal Containers: Puncture-resistant, rigid, leak-proof on sides and bottom, and labeled with the biohazard symbol or color-coded red. Located immediately accessible in the health center, athletic training, and research labs.
• Needleless Systems & Engineered Sharps: Safer medical devices including retractable needles, shielded scalpels, and self-sheathing lancets shall be evaluated and utilized across clinical and research settings.
• Prohibited Work Practices: Shearing, breaking, bending, or recapping needles by hand is strictly prohibited. Eating, drinking, applying cosmetics/lip balm, or handling contact lenses is prohibited in work areas where BBP exposure is possible.
• Handwashing Facilities: Adequate handwashing facilities equipped with soap, running water, and disposable towels are provided near exposure areas. Employees must wash hands immediately after removing gloves or after contact with blood/OPIM.
• Glassware & Contaminated Items: Broken glassware that may be contaminated shall not be picked up directly with hands. Mechanical means such as a brush and dustpan, tongs, or forceps must be used.

4.3 Personal Protective Equipment (PPE)

When occupational exposure remains after engineering controls, the College provides appropriate PPE at no cost to employees. PPE selection is based on the anticipated exposure task:

4.4 Housekeeping & Biohazard Waste Management

All equipment, environmental surfaces, and work areas shall be cleaned and decontaminated immediately after contact with blood or OPIM. Decontamination must be performed using an EPA-registered tuberculocidal disinfectant or a freshly prepared solution of 1:10 household bleach (0.5% sodium hypochlorite).

Regulated biohazardous waste must be placed in closeable, leak-proof containers or red bags marked with the standard biohazard symbol. Disposal of biohazard waste bags and filled sharps containers is managed by licensed medical waste vendors contracted through EHS.

In compliance with 29 CFR 1910.1030(f), the Hepatitis B vaccination series is offered at NO COST to all employees who have been identified as having potential occupational exposure to blood or OPIM.

5.1 Vaccination Offer & Protocol

• Timing: The vaccine series is offered within 10 working days of an employee's initial assignment to a position with exposure risk.
• Prerequisites: The vaccination offer occurs AFTER the employee receives required BBP training and BEFORE performing tasks with exposure risk.
• Administration: Administered through Human Resources.

5.2 Vaccine Declination & Future Acceptance

Employees who decline the Hepatitis B vaccination must sign the mandatory OSHA Vaccine Declination Form (see Appendix A). If an employee initially declines but later decides to accept the vaccination while still in a covered position, the College will provide the vaccine series at no cost within 10 working days of the request.

An exposure incident is defined as a specific eye, mouth, other mucous membrane, non-intact skin, or parenteral contact with blood or OPIM. Following an exposure incident, immediate action and confidential medical evaluation are required.

6.1 Immediate First Aid Response

1. Wash needle sticks and cuts with soap and water for at least 5 minutes.

2. Flush splash exposures to eyes, nose, or mouth with copious amounts of clean water or saline for 15 minutes.

3. Report the incident immediately to Campus Safety, your supervisor and the EHS Department.

6.2 Post-Exposure Medical Protocol

The College provides an immediate, confidential medical evaluation and follow-up at no cost to the employee through a designated emergency medical provider (Ellis Works). The evaluation includes:

• Documentation of the route(s) of exposure and circumstances surrounding the incident.
• Identification and testing of the source individual's blood for HBV, HCV, and HIV (where consent is obtained or permitted by law).
• Collection and testing of the exposed employee's blood for HBV, HCV, and HIV serological status (with employee consent).
• Post-exposure prophylaxis (PEP) when medically indicated, as recommended by current U.S. Public Health Service guidelines.
• Counseling regarding risk reduction, disease transmission, and psychological support.
• Evaluation of reported illness during the post-exposure follow-up period.

All employees with occupational exposure must participate in a comprehensive training program provided at no cost during working hours. Training occurs early in one’s appointment to a new role and at least annually thereafter.

7.1 Training Content & Format

The training curriculum covers, at a minimum:

• An accessible copy and explanation of OSHA 29 CFR 1910.1030 and this Exposure Control Plan.
• Epidemiology, modes of transmission, and symptoms of bloodborne diseases (HBV, HCV, HIV).
• Explanation of exposure control methods, engineering controls, PPE selection, and work practices.
• Information on the Hepatitis B vaccine, efficacy, safety, administration, and free availability.
• Emergency procedures involving blood/body fluids and post-exposure evaluation protocols.
• Biohazard labeling, color-coding system, and waste disposal protocols.
• An opportunity for follow up questions with EHS.

The on-line safety training module is located in Workday. For employees required to complete the course, it will be assigned on an annual basis and available in the My Learning folder.

7.2 Hazard Communication & Warning Signs

Warning labels featuring the universal biohazard symbol and the word 'BIOHAZARD' in fluorescent orange or orange-red shall be affixed to containers of regulated biohazard waste, refrigerators/freezers holding blood/OPIM, and biohazard transport bags.

8.1 Record Retention Requirements

8.2 Annual Plan Review

This Exposure Control Plan will be reviewed and updated annually by EHS, or whenever changes in positions, procedures, or technology affect occupational exposure.

Hepatitis B Vaccine Election Form

In accordance with OSHA 29 CFR 1910.1030(h)(5), the College maintains this Sharps Injury Log to record all percutaneous injuries from contaminated sharps. This log is maintained confidentially and reviewed annually during the Exposure Control Plan evaluation.