Exposure Control Plan for Bloodborne Pathogens

I. Exposure Determination

• A. Category I: Personnel who come in direct contact with bloodborne pathogens through blood and body fluids in the performance of their job for which precautions must be taken. Category I includes school nurses and custodians.
• B. Category II: Personnel who participate in activities without contact with blood and bodily fluids but exposure to bloodborne pathogens may occur in certain situations. Category II includes school staff including coaches, athletic trainers, physical education teachers, OT, PT, paraeducators, special education staff working in behavioral programs, security staff, principals and those staff certified in first aid. 
• C. Category III: Personnel performing tasks that do not entail predictable or unpredictable exposure to bloodborne pathogens and low risk of work exposure. Category III includes remaining school staff and those employees working outside of school buildings. 

II. Methods of Compliance

All employees of the Newtown Public Schools will practice universal precautions as recommended by the Centers for Disease Control (CDC). Universal precautions require that all employees assume that all blood and other potentially infectious materials (as defined by OSHA) are infectious and are to be handled according to Newtown Public Schools Exposure Control Plan for Bloodborne Pathogens.

• A. Avoid direct contact with blood or other bodily fluids including potentially infectious materials; use gloves.
• B. Protective gloves will be worn if you have any open wounds on your hands. If there is any doubt in your mind regarding some contact with blood or body fluids; use gloves.
• C. If you become contaminated, wash that area immediately with antiseptic soap and water for at least 20 seconds.
• D. If clothing becomes contaminated with blood or body fluids, it should be placed in a bag labeled “biologically contaminated” and placed in a contaminated container for discarding or sent home with the student or staff member when appropriate. 
• E. Any areas of the school which may become contaminated will be washed with an appropriate disinfectant solution; rubber gloves, sanitary suit, face and eye protection, and long handled scrub utensils should be used.
• F. All locker rooms, restrooms, and nurses’ offices will be cleaned daily using disinfectant. Custodial staff members are required to wear rubber gloves and use scrubbing utensils during these cleaning procedures at these locations.
• G. When a spill occurs, the building administrator or his/her designee will limit access to areas of potential exposure and notify the staff and students. The custodial staff will be notified to immediately clean the area.

III. Preventive Measures

The Superintendent or his/her designee shall use engineering and work practice controls to eliminate or minimize employee exposure, and shall regularly examine and update controls to ensure their effectiveness.

IV. Hepatitis B Vaccination

• A. The hepatitis B vaccination series shall be made available at no cost to all Category I employees. The hepatitis B vaccination shall be made available after an employee with Category I risk of occupational exposure has received the required training and within 10 working days of initial assignment, unless the employee has previously received the complete hepatitis B vaccination series, or antibody testing has indicated that the employee is immune, or vaccination is contraindicated by medical reasons.
• B. Employees who decline to accept the vaccination shall indicate such on Form I.

V. Training for Exposure Control

Each year, all district employees will be required to complete a Vector Solutions/Safe Schools training module, relating to precautions, risks, and actions to take if contaminated by blood or other body fluids. This training module includes the following information:  

1. A general explanation of the epidemiology and symptoms of bloodborne diseases;
2. An explanation of the modes of transmission of bloodborne pathogens;
3. An explanation of the employer’s exposure control plan and the means by which the employee can obtain a copy of the written plan;
4. An explanation of the appropriate methods for recognizing tasks and other activities that may involve exposure to blood and other potentially infectious materials;
5. An explanation of the use and limitations of methods that will prevent or reduce exposure including appropriate engineering and work practices controls, and personal protective equipment;
6. Information on the types, proper use, location, removal, handling, decontamination, and disposal of personal protective equipment;
7. An explanation of the basis for selection of personal protective equipment;
8. Information on the hepatitis B vaccine, including information on its efficacy, safety, method of administration, the benefits of being vaccinated, and that the vaccine and vaccination will be offered free of charge;
9. Information on the appropriate actions to take and persons to contact in an emergency involving blood or other potentially infectious materials;
10. An explanation of the procedure to follow if an exposure incident occurs, including the method of reporting the incident and the medical follow-up that will be made available;
11. Information on the post-exposure evaluation and follow-up that the employer is required to provide for the employee following an exposure incident;
12. Direction to employees to have any remaining questions answered by the school nurse.

VI. Reporting Incidents

• A. All exposure incidents shall be reported as soon as possible to the school nurse and to the building administrator.
• B. All at risk personnel who come in contact with blood and body fluids in the performance of their duties will take steps to safeguard their health.

VII. Post-Exposure Evaluation and Follow-up

Following a report of an exposure incident, the Superintendent or his/her designee shall immediately make available to the exposed employee, at no cost, a confidential medical evaluation, post-exposure evaluation, and follow-up. He or she shall at a minimum:

1. Document the route(s) of exposure and the circumstances under which the exposure incident occurred;
2. Identify and document the source individual, unless that identification is infeasible or prohibited by law;
3. Provide for the collection and testing of the employee’s blood for Hepatitis B, Hepatitis C, and HIV serological status;
4. Provide for post-exposure prophylaxis, when medically indicated as recommended by the U.S. Public Health Service;
5. The Superintendent or designee shall provide the health care professional with a copy of the OSHA regulation; a description of the employee’s duties as they relate to the exposure incident; documentation of the route(s) of exposure and circumstances under which exposure occurred; results of the source individual’s blood testing, if available; including vaccination status and any medical records maintained by the district relevant to the appropriate treatment of the employee;
6. The district shall maintain the confidentiality of the affected employee and the exposure source during all phases of the post-exposure evaluation.

VIII. Records

• A. A confidential medical record will be kept for all employees with occupational exposure to a bloodborne pathogen, and not disclosed or reported without the employee’s written consent to any person within or outside the workplace except as required by law.
• B. Upon request by an employee, or a designated representative with the employee’s written consent, the Superintendent or designee shall provide access to a record in a reasonable time, place and manner, no later than 15 days after the request is made.
• C. Records shall be maintained as follows:

1. Medical records shall be maintained for the duration of employment plus 30 years.
2. Training records shall be maintained for three years from the date of training.
3. The sharps injury log shall be maintained five years from the date the exposure incident occurred.
4. Exposure records shall be maintained for 30 years.
5. Each analysis using medical or exposure records shall be maintained for at least 30 years.