OSHA Manual

The Brooklyn College Emergency Medical Squad is committed to providing a safe and healthful work environment for our entire staff. In pursuit of this endeavor, the following Exposure Control Plan (ECP) is provided to eliminate or minimize occupational exposure to blood-borne pathogens in accordance with OSHA Blood-borne Pathogens Standard, Title 29 Code of Federal Regulations 1910.1030.

The ECP is a key document to assist our squad in implementing and ensuring compliance with this standard, thereby protecting our volunteers. This ECP includes:

  • members' exposure determination,
  • the procedures for evaluating the circumstances surrounding an exposure incident, and
  • the schedule and method of implementing the specific sections of the standard, including:
    • methods of compliance
    • Hepatitis B vaccination and post exposure follow-up
    • training and communication of hazards to members
    • record keeping

Program Administration

The administrator and chief of operations are responsible for the implementation of the ECP. They will maintain and update the written ECP at least annually and whenever necessary to include new and modified tasks and procedures. Members who are reasonably anticipated to have contact with exposure to blood and other potentially infected materials are required to comply with the procedures and work practices outlined in this ECP. The house officer will have the responsibility for written housekeeping protocols and will ensure that effective disinfectants are purchased. The administrator will be responsible for training, documentation of training, and making the written ECP available to members, OSHA and NIOSH representatives. The equipment officer will maintain and provide all necessary personal protective equipment (PPE), sharps containers, labels and red bags as required by the standard. He or she will ensure that adequate supplies of the aforementioned equipment are available.

Member Exposure Determination

As part of the exposure determination section of our ECP, the following is a list of job classifications where squad members may have an occupational exposure:

  • crew chief
  • crew chief in training
  • attendant
  • attendant in training
  • driver
  • driver in training
  • dispatchers and dispatchers in training who may assist at the scene of an emergency call or may assist in the cleaning of the office

All exposure determinations for A and B were made without regard to the use of PPE.

Methods of Implementation and Control

As of March 6, 1992, all members will utilize Universal Precautions. Universal Precautions is an infection-control method that requires members to assume that all human blood and specified human body fluids are infectious for HIV, HBV and other blood-borne pathogens and must be treated accordingly.

Exposure Control Plan (ECP)

Members covered by the Blood-borne Pathogens Standard will receive an explanation of this ECP during their training sessions. It will also be reviewed in their annual refresher training. All members will have the opportunity to review this plan at any time during their work shift by contacting the administrator or chief of operations. A copy of the plan will be made available free of charge and within 15 days of the request.

The administrator and chief of operations will also be responsible for reviewing and updating the ECP annually or sooner if necessary to reflect any new or modified tasks and procedures which affect occupational exposure and to reflect new or revised employee positions with occupational exposure.

Engineering Controls and Work Practices

Engineering controls and work practice controls will be used to prevent or minimize exposure to blood-borne pathogens. The specific engineering controls and workplace controls we will use are:

  • Gloves shall be worn in all instances where there is the potential for contact with a patient's body fluids.
  • Face shields, goggles, gowns or other protective gear shall be used where there is the potential for splashing or splattering.

Engineering controls (sharp's containers, etc.) will be inspected once a week by the equipment officer.

Work Practice Controls

Work practice controls include, but are not limited to:

  • Providing readily accessible hand-washing facilities
  • Washing hands immediately or as soon as feasible after removal of gloves
  • Providing interim hand-washing measures at locations where hand-washing facilities are not available (Members can later wash their hands with soap and water as soon as feasible.)
  • Washing body parts as soon as feasible after contact with blood or other potentially infectious materials occurs
  • Prohibiting the recapping or bending of needles
  • Proper labeling
  • Proper equipment decontamination
  • Prohibiting eating, drinking, smoking, applying cosmetics or lip balm, and handling of contact lenses in patient care areas where there is a likelihood of occupational exposure
  • Prohibiting of food or drink from being kept in refrigerators, freezers, shelves, cabinets or on countertops or bench tops where blood or other potentially infectious materials are present
  • Examining equipment that may become contaminated with blood or other body fluids prior to servicing or shipping and decontaminate such equipment as necessary

Personal Protective Equipment (PPE)

PPE must also be used if occupational exposure remains after instituting engineering and work practice controls, or controls are not feasible. The training officer in the use of PPE will provide training. Appropriate equipment/Universal Precautions are required in the following tasks:

  • Patient care
  • Cleaning of equipment, ffice, or ambulance after exposure to a patient's body fluid

As a general rule, all members using PPE must observe the following precautions:

  • Wash hands immediately or as soon as feasible after removal of gloves or other PPE.
  • Place all used PPE in the appropriate container.
  • Replace gloves if torn, punctured or contaminated, or if their ability to function as a barrier is compromised.
  • Flush exposed mucous membranes with water as soon as feasible.
  • Work gloves may be decontaminated for re-use. Never wash or decontaminate disposable gloves.
  • Wear appropriate face and eye protection such as a mask with glasses with solid side shields or a chin-length face shield when splashes, splatters or droplets of blood or other body fluids pose a hazard to the eyes, nose or mouth.
  • If a garment is penetrated by blood or other body fluid, the garment(s) must be removed as soon as feasible. If a pullover garment becomes minimally contaminated, members should be trained to remove the pullover in such a way as to avoid contact with outer surface by rolling up the garment as it is pulled toward the head for removal.
  • Repairing and/or replacing the PPE will be at no cost to members.

Training

All members who have reasonably anticipated having occupational exposure to blood-borne pathogens will receive training by the administrator or training officer. The trainer will provide training on the epidemiology of blood-borne pathogen diseases. OSHA regulations on "Workers Exposure to AIDS and Hepatitis B" will be included in all training. In addition, training will include the following materials:

  • A copy and explanation of the standard
  • Modes of transmission of blood-borne pathogens
  • Our exposure control plan and how to obtain a copy
  • Methods to recognize exposure tasks and other activities that may involve exposure to blood
  • Use and limitations of Engineering Controls, Work Practices and PPE
  • PPE — types, use, location, removal, handling, decontamination and disposal
  • PPE — basis for selection
  • Hepatitis B vaccine — offered free of charge. Training will be given prior to vaccination on its safety, effectiveness, benefits and method of administration.
  • Exposure incident procedures
  • Post-exposure evaluation and follow-up
  • Signs, labeling and color-coding
  • Question and answer session

A Member Education and Training Record will be completed for each employee upon completion of training. This document will be kept with the membership records in 1407 Boylan Hall.

Hepatitis B Vaccination

The administrator or training officer will provide information on the  Hepatitis B vaccination (HBV), addressing its safety, benefits, efficacy, methods of administration and availability. The HBV series will be made available at no cost to members who have occupational exposure to blood or other potentially infectious materials.

The following members are exempt from receiving the HBV:

  • Members who have previously received the series
  • Those whose antibody testing reveals that he she is immune
  • Members with medical reasons preventing taking the vaccination
  • Any member who chooses not to participate

All members are strongly encouraged to receive the HBV series. However, if any member chooses to decline the HB vaccine, that member must sign a statement to this effect. Members who decline may request and obtain the vaccination at a latter date at no cost. Documentation of refusal of the HBV series will be kept in 1407 Boylan Hall with the members' other records.

Failure to complete the HB Vaccination Series

Any member who begins but fails to complete the HB Vaccination series will be entitled to restart the series at cost to the member.

Post-exposure Evaluation and Follow-up Procedures for Reporting, Documenting and Evaluating the Exposure

Should an exposure incident occur, contact the administrator or chief of operations immediately. Each exposure must be documented by the member on an Exposure Report Form. An immediately available confidential medical evaluation and follow up will be conducted by a hospital emergency department. The following steps will be taken:

  1. Document the routes of exposure and how exposure occurred.
  2. Identify and document the source individual, unless the squad can establish that identification is unfeasible or prohibited by state or local law.
  3. Obtain consent and test source individual's blood as soon as possible to determine HIV or HBV infectivity and document the source's blood test results. If the source individual is known to be infected with either HIV or HBV, testing need not be repeated.
  4. Provide the exposed employee with the source individual's test results and information about applicable disclosure laws and regulations concerning the source identity and infectious state.
  5. After obtaining consent, collect exposed member's blood as soon as feasible after the exposure incident and test blood for HBV and HIV serological status.

If the member does not give consent for HIV serological testing during the collection of blood for baseline testing, preserve the blood for at least 90 days

If, during this time the exposed member elects to have the baseline blood tested, testing must be performed as soon as feasible

The administrator will review the circumstances of the exposure incident to determine if procedures, protocols and/or training need to be revised.

Health Care Professionals

The administrator will ensure that health care professionals responsible for members' HB vaccination and post-exposure evaluation and follow up be given a copy of the OSHA Blood-borne Standard. The administrator will also ensure that the health care professional evaluating an employee after an exposure incident receives the following:

  • A description of the employee's job duties relevant to the exposure incident
  • Route(s) of exposure
  • Circumstances of exposure
  • If possible, results of the source individual's blood test as well as relevant member medical records, including vaccination status
  • Healthcare professional's written opinion

The administrator will provide the member with a copy of the evaluating health care professional's written opinion within 15 days after completion of the evaluation. For HB vaccinations, the health care professional's written opinion will be limited to whether the member requires or has received HB vaccinations. The written opinion for post-exposure evaluation and follow-up will be limited to whether or not the member has been informed of the results of the medical evaluation and any medical conditions that may require further evaluation and treatment. All other diagnoses must remain confidential and not be included in the written report to our squad.

Record Keeping

Medical Records

Medical records are maintained for each member with occupational exposure in accordance with 29 CFR 1910.20. The administrator is responsible for maintenance of the medical records. In addition to the requirements of 29 CFR 1910.20, the medical records will include:

  • The name and Social Security number of the member
  • A copy of the member's HB vaccinations and any medical records relative to the employee's ability to receive vaccination
  • A copy of all results of examinations, medical testing and follow-up procedures as required by the standard
  • A copy of all health care professional's written opinion(s) as required by the standard

All member medical records will be kept confidential and will not be disclosed or reported without the employee's express written consent to any person within or outside the college except as required by the standard or as may be required by law. Member medical records shall be maintained for at least the duration of membership plus 30 years, in accordance with the standard. Members' medical record shall be provided upon request of the member or to anyone with written consent of the member within 15 working days.

Training Records

The training officer or administrator will maintain blood-borne pathogen-training records. The training record shall include:

  • dates of the training session,
  • contents or a summary of the training sessions,
  • names and qualifications of persons conducting the training sessions, and
  • names and job tittles of all persons attending the training sessions.

Training records will be maintained for a minimum of three years from the date on which the training occurred. Members' training records will be provided upon request to the member or the member's authorized representative within 15 working days.

Transfer of Records

If BC-EMS and Brooklyn College cease to exist, the squad shall notify the director of the National Institute for Occupational Safety and Health (NIOSH) at least three months prior to scheduled record disposal and prepare to transmit them to the director.

Appendix

What is HB virus?

Hepatitis B virus is a potentially life-threatening blood-borne pathogen. The Centers for Disease Control estimates there are approximately 280,000 infections each year in the United States.

Approximately 8,700 health care workers each year contract hepatitis B, and about 200 will die as a result. In addition, some who contract hepatitis B will become carriers, passing the disease on to others. Carriers also face a significantly higher risk for other liver ailments, which can be fatal, including cirrhosis of the liver and primary liver cancer.

Hepatitis B virus infection is transmitted through exposure to blood and other infectious body fluids and fissures. Anyone with occupational exposure to blood is at risk of contracting the infection.

Employers must provide engineering controls; workers must use work practices and protective clothing and equipment to prevent exposure to potentially infectious materials. However, the best defense against hepatitis B is vaccination.

Who needs vaccination?

The new OSHA standard covering blood-borne pathogens requires employers to offer the three-injection vaccination series free to all employees who are exposed to blood or other potentially infectious materials as part of their job duties. This includes health care workers, emergency responders, morticians, first-aid personnel, law enforcement officers, correctional facilities staff and launderers.

The vaccination must be offered within 10 days of initial assignment to a job where exposure to blood or other potentially infectious materials can be "reasonably anticipated." The requirements for vaccinations of those already on the job take effect July 6, 1992.

What does vaccination involve?

The hepatitis B vaccination is a noninfectious, yeast-based vaccine given in three injections in the arm. It is prepared from recombinant yeast cultures, rather than human blood or plasma. Thus, there is no risk of contamination from other blood-borne pathogens nor is there any chance of developing the virus from the vaccine.

The second injection should be given one month after the first, and the third injection six months after the initial dose. More than 90 percent of those vaccinated will develop immunity to the hepatitis B virus. To ensure immunity, it is important for individuals to receive all three injections. At this point it is unclear how long the immunity lasts, so booster shots may be required at some point in the future.

The vaccine causes no harm to those who are already immune or to those who may be virus carriers. Although employees may opt to have their blood tested for antibodies to determine need for the vaccine, employers may not make such screening a condition of receiving vaccination, nor are employers required to provide prescreening.

Each employee should receive counseling from a health care professional when vaccination is offered. This discussion will help an employee determine whether inoculation is necessary.

What if I decline vaccination?

Workers who decide to decline vaccination must complete a declination form. Employers must keep these forms on file so that they know the vaccination status of everyone who is exposed to blood. At any time after a worker initially declines to receive the vaccine, he or she may opt to take it.

What if I am exposed but have not yet been vaccinated?

If a worker experiences an exposure incident, such as a needle stick or a blood splash in the eye, he or she must receive confidential medical evaluation from a licensed health care professional with appropriate follow-up. To the extent possible by law, the employer is to determine the source individual for the hepatitis B virus as well as human immunodeficiency virus (HIV) infectivity. The worker's blood will also be screened if be or she agrees.

The health care professional is to follow the guidelines of the U.S. Public Health Service in providing treatment. This would include hepatitis B vaccination. The health care professional must give a written opinion on whether or not vaccination is recommended and whether the employee received it. Only this information is reported to the employer. Employee medical records must remain confidential. HIV or HB virus status must not be reported to the employer.