Revised 10/2004
Fermilab is committed to providing a safe and healthful work environment for all employees. The following Exposure Control Plan (ECP) is provided to eliminate or minimize occupational exposure to bloodborne pathogens. In addition, the ECP assists the Laboratory to ensure compliance with applicable standards through determination of employee exposure and implementation of various methods of exposure control including the following:
• Universal precautions
• Engineering and work practice controls
• Personal protective equipment
• Housekeeping
• Hepatitis B vaccination
• Post-exposure evaluation and follow-up
• Communication of hazards to employees and training
• Record keeping
• Procedures for evaluating circumstances surrounding an exposure incident
STANDARDS
29 CFR 1910.1030 OSHA Occupational Exposure to Bloodborne Pathogens
29 CFR 1910.20 Access to Employee Exposure and Medical Records
Directorate
Overall responsibility for the ECP rests with the Director's Office. The Director assures that adequate resources are available to carry out the plan as described in this chapter.
Divisions/Sections
Division/Section management is responsible for obtaining and maintaining all necessary personal protective equipment (PPE), engineering controls (e.g., sharps containers), labels, and red bags as required by this plan. In addition, division/section management is responsible for ensuring that the required annual training is conducted by qualified trainers and documented.
The Environmental Safety & Health (ESH) Section – Medical Department
The ESH-Medical Department is responsible for the following:
§ Maintenance of the ECP.
§ Annual review of the ECP (and whenever necessary to include new or modified tasks and procedures),
§ Providing training on the Hepatitis B Vaccination to affected employees,
§ Overseeing the development and updating of the Bloodborne Pathogens lesson plan to be used by division/section personnel to deliver the required training.
§ Ensuring that all required medical actions are performed, and
§ Maintaining employee health records.
The Fermilab Medical Department is located on the Ground Floor of Wilson Hall (X 3232).
Affected Employees
Those employees who are determined to have occupational exposure to blood or Other Potentially Infectious Materials (OPIM) must comply with the procedures and work practices outlined in this plan.
EMPLOYEE EXPOSURE DETERMINATION
The following is a list of Fermilab job classifications, that are deemed to have a potential occupational exposure to bloodborne pathogens:
|
JOB TITLE |
DEPARTMENT/ LOCATION |
|
Physician |
ESH/Medical Office |
|
Nurse I |
ESH/Medical Office |
|
Nurse II |
ESH/ Medical Office |
|
Fire Chief |
ESH/Fire Department |
|
Lieutenant |
ESH/Fire Department |
|
Captain |
ESH/Fire Department |
|
Fire Fighter |
ESH/Fire Department |
|
Security Captain |
ESH/Security Department |
|
Housekeeping Manager |
LS/Accommodations |
|
Day Care Teacher |
LS/Day Care Center |
|
Day Care Attendant |
LS/Day Care Center |
|
Day Care Administrator |
LS/Day Care Center |
|
Lifeguards |
LS/Recreation |
In addition to these employees, it is recognized that all janitorial and housekeeping staff have a potential occupational exposure to bloodborne pathogens. This work is currently carried out by contract service vendors who are responsible for implementation of necessary BBP precautions.
Divisions/Sections may include additional individuals in the plan based on unusual job assignments.
METHODS OF IMPLEMENTATION AND CONTROL
Universal Precautions
According to the concept of “Universal Precautions,” all human blood and certain human body fluids are treated as if known to be infectious for HIV, HBV, and other bloodborne pathogens. All employees will utilize universal precautions.
Employees covered by the BBP standard receive an explanation of this ECP during their initial training session. It is also reviewed in their annual refresher training. All employees have an opportunity to review the plan at any time by contactingthe Fermilab Medical Department, or by logging onto the ESH web page.
The ECP will be reviewed and updated in concert with annual refresher training. This review will include consideration of appropriate commercially-available and effective safer medical devices designed to eliminate or minimize occupational exposure to bloodborne pathogens. Input will be solicited from potentially-exposed non-managerial personnel including those responsible for direct patient care who may be exposed to injuries from contaminated sharps. This solicitation will include the identification, evaluation and selection of effective controls. Documentation of reviews will be maintained with the documentation of training. Training records pertaining to ES&H-related training shall be forwarded to the ES&H Section for filing and maintenance as required by chapter 4010 of this manual.
Engineering Controls and Work Practices
Engineering and work practice controls will be used to prevent or minimize exposure to bloodborne pathogens. Specific controls are listed below.
MEDICAL OFFICE
Gloves for phlebotomy/venipuncture
Gloves for wound care
Gloves for clean-up activities
No pouring off/transfer of serum to 2nd collection tube
No recapping of needles
Appropriate disposal of sharps ASAP
Use of tool/scoop to pick up broken glass
Gloves for clean-up of bodily fluids
DAY CARE CENTER
Gloves for wound care
Gloves for clean-up activity
Appropriate disposal of sharps ASAP
LIFEGUARDS
Gloves for wound care & clean-up activities
FIRE DEPARTMENT
Gloves for wound care
Gloves when starting IVs
Gloves for clean-up activities
Sharps disposal containers are inspected and maintained by the nurses or replaced every three (3) months, or whenever necessary to prevent overfilling. Sharps disposal containers at the Day Care Facility are inspected and maintained by the Day Care Manager and/or teachers, and replaced whenever necessary to prevent overfilling.
Personal Protective Equipment (PPE)
PPE is provided to Fermilabemployees at no cost. PPE available to employeesmay include gloves, eye protection, lab coats, disposable CPR masks, etc.
Training in the use of the appropriate PPE for the tasks employees will perform is provided in the general BBP training program.
MEDICAL OFFICE
|
Location of PPE: |
Storage closet adjacent to Exam Room 2 |
|
Available thru: |
Any member of medical staff |
DAY CARE CENTER
|
Location of PPE: |
Storage Closet at north end of facility. |
|
Available thru: |
Supervisor or staff member. |
FIRE DEPARTMENT
|
Location of PPE: |
On emergency vehicles (squad & engines), in the first aid lockers, |
|
Available thru: |
Supervisor or the duty captain. |
LIFEGUARDS
|
Location of PPE: |
Storage closet |
|
Available thru: |
Supervisor or Lifeguard |
All employees using PPE must observe the following precautions.
1) Wash hands immediately or as soon as feasible after removal of gloves or other PPE.
2) Remove PPE after it becomes contaminated, and before leaving the work area.
3) Used PPE may be disposed of in appropriate containers such as:
a) Red, hard-sided containers with biohazard symbol
b) Red biohazard bags
c) Contaminatedlaundering containers (Red bag, or garbage bag with red biohazard symbol)
d) Areas to be decontaminated (Marked with yellow warning tape)
4) Wear appropriate waterproofgloves (like vinyl, or latex)when it can be reasonably anticipated that there may be hand contact with blood or OPIM, and when handling or touching contaminated items or surfaces; replace gloves if torn, punctured, contaminated, or if their ability to function as a barrier is compromised.
5) Utility gloves may be decontaminated for reuse if their integrity is not compromised; discard utility gloves if they show signs of cracking, peeling, tearing, puncturing, or deterioration.
6) Never wash or decontaminate disposable gloves for reuse.
7) Wear appropriate face and eye protection when splashes, sprays, spatters, or droplets of blood or OPIM pose a hazard to the eye, nose, or mouth.
8) Remove immediately or as soon as feasible any garment contaminated by blood or OPIM, in such a way as to avoid contact with the outer surface.
Housekeeping
Contaminated sharps are discarded immediately, or as soon as possible, using containers that are closable, puncture-resistant, leak proof on sides and bottoms, and labeled or color-coded appropriately. Sharps disposal containers are available in each exam room in the Medical Department, in the storage closet in the Medical Department, and in most classrooms at the Day Care Facility.
Bins and pails (e.g., wash or emesis basins) are cleaned and decontaminated as soon as feasible after visible contamination.
Broken glassware (which may be contaminated) is picked up using mechanical means, such as a brush and dustpan.
All other regulated waste is placed in containers that are closable, constructed to contain all contents and prevent leakage, appropriately labeled or color-coded (see Labels), and closed prior to removal to prevent spillage or protrusion of contents during handling.
Refer to Fermilab Hazardous Waste Disposal Chapter (8021) for the procedures to dispose of sharps containers or other regulated waste. It is available on the ESH web page at
http://www-esh.fnal.gov/FESHM/8000/8021.htm
Laundry
Clothing of affected workers that maybe contaminated with blood or OPIM should be delivered to the Medical Department (see laundry requirements below). All other contaminated clothing (patient/victim, children, other) will be processed on a case-by-case basis in accordance with the laundry requirements provided below or disposed of appropriately. The laundry is picked up and cleaned by a qualified laundry service.
The following laundering requirements must be met.
1. Handle contaminated laundry as little as possible, with minimal agitation.
2. Place wet contaminated laundry in leak-proof, labeled, or color-coded containers before transport.
3. Use red bags or bags with biohazard label affixed to the bag.
4. Wear gloves, gowns, eye protection, face protection, and/or other PPE as indicated when handling and/or sorting contaminated laundry.
5. Maintain the bag of contaminated laundry at a secure location.
6. Arrange to have the contaminated laundry picked up by the qualified laundry service for cleaning or disposed of in accordance with chapter 8021 of this manual.
Labels
The following labeling method(s) are used at Fermilab.
|
EQUIPMENT TO BE LABELED |
LABEL TYPE (size, color, etc.) |
|
§ Bags with laboratory specimens |
Biohazard label |
|
§ Contaminated laundry |
Biohazard label, red bag |
|
§ Contaminated PPE |
Biohazard label, red bag |
|
§ Needle Containers |
Biohazard label, w/ “SHARPS” |
|
§ Small spill clean-up bag |
Biohazard label, red bag |
Persons who are qualified BBP workers or are otherwise assigned to handle biological waste containerswill ensure that warning labels are affixed or red bags are used as required if regulated waste or contaminated equipment is brought into the facility. Employees are to notify their supervisor and/or Senior Safety Officer (SSO) if they discover regulated waste containers, refrigerators containing blood or OPIM, contaminated equipment, etc. without proper labels.
The Medical Department will provide training to affected employees on hepatitis B vaccinations, addressing the safety, benefits, efficacy, methods of administration, and availability.
The hepatitis B vaccination series is available at no cost after training and within 10 days of initial assignment to employees identified in the exposure determination section of this plan. Vaccination is encouraged unless:
1. Documentation exists that the employee has previously received the series,
2. Antibody testing reveals that the employee is immune, or
3. Medical evaluation shows that vaccination is contraindicated.
If an employee chooses to decline vaccination, they must sign a declination form. This form can be found at the end of this chapter (see Appendix A). Employees who initially decline may request the vaccination at a later date and it will be provided at no cost. Documentation declining vaccination is kept in the MedicalDepartment.
Vaccination will be provided by the Medical Department. Following hepatitis B vaccination, the health care professional's written opinion will be limited to whether the employee requires the hepatitis vaccine, and whether the vaccine was administered.
In all situations, medical evaluation within two (2) hours is crucial.
In the event of an EXPOSURE INCIDENT [any incident resulting in direct contact with infectious or potentially infectious material], please follow the directions as noted below.
Confidential medical evaluation and follow-up will be immediately available. This evaluation will be conducted by a licensed medical professional in the Medical Department . Following the initial provision of first aid (clean the wound, flush eyes or other mucous membrane, etc.), the following activities will be performed.
ADMINISTRATION OF POST-EXPOSURE EVALUATION AND FOLLOW-UP
The Medical Department ensures that health care professional(s) responsible for employee's hepatitis B vaccination and post-exposure evaluation and follow-up are given a copy of OSHA's Bloodborne Pathogens Standard (29 CFR 1910.1030).
The Medical Department ensures that the health care professional evaluating an employee after an exposure incident receives the following:
The Medical Department provides the employee with a copy of the evaluating health care professional's written opinion within 15 days after completion of the evaluation.
PROCEDURES FOR EVALUATING THE CIRCUMSTANCES SURROUNDING AN EXPOSURE INCIDENT
The Site Occupational Medicine Director, along with the accident investigation team, will review the circumstances of all exposure incidents to determine:
If it is determined that revisions need to be made, the Site Occupational Medicine Director will ensure that
appropriate changes are made to this ECP. Changes may include an evaluation of
safer devices, adding employees to the exposure determination list, etc.
EMPLOYEE TRAINING
All employees will be provided with instructions on handling blood and body fluids in New Employee Orientation. They will be instructed to not clean up other people’s blood or body fluid.
All employees who have a potential occupational exposure to BBPs must receive initial training conducted by a qualified instructor selected by the division/section with the approval of the Site Occupational Medicine Director. Refresher training is required annually.
The person conducting the training shall be knowledgeable in the subject matter covered by the elements contained in the training program as it relates to the workplace that the training will address. Refresher training is required annually.
All employees who have occupational exposure to bloodborne pathogens receive training on the epidemiology, symptoms, and transmission of bloodborne pathogen diseases. In addition, the training program covers, at a minimum, the following elements:
Class schedules are available on the web at
http://www-esh.fnal.gov/pls/default/esh_home_page.page?this_page=100
RECORDKEEPING
Training Records
Training records are generated for each employee upon completion of training. The training will be documented electronically in the ESH TRAIN database, located on web at http://www-esh.fnal.gov/pls/default/esh_home_page.html
The training records include the following:
Original attendance sheets are kept by the trainer. Copies are sent to the ESH section.
Employee training records are provided upon request to the employee or the employee's authorized representative within 15 working days. Such requests should be addressed to the division/section ES&H safety organization. Program content is available from the Medical Department.
Medical Records
Medical records are maintained for each employee with occupational exposure in accordance with applicable standards. This includes completed copies of the appendices to this chapter. In particular, Appendix C is considered to be the “sharps log.”
Active records are kept in the Fermilab Medical Department.
Archived records are kept at an off site storage facility for thirty years after termination of employment.
Employee medical records are provided upon request of the employee or to anyone having written consent of the employee within 15 working days. Such requests should be sent to:
Fermilab Medical Office
P. O. Box 500 M.S. 204
Batavia, IL 60510
SUBCONTRACTORS
All subcontractors working on Fermilab Property who are exposed to bloodborne pathogens shall comply with all appropriate OSHA standards, including 29 CFR 1910.1030 and 29 CFR 1910.20.

APPENDIX A
HEPATITIS B VACCINE DECLINATION (MANDATORY)
I understand that due to my occupational exposure to blood or other potentially infectious materials I may be at risk of acquiring hepatitis B virus (HBV) infection. I have been given the opportunity to be vaccinated with hepatitis B vaccine, at no charge to myself. However, I decline hepatitis B vaccination at this time. I understand that by declining this vaccine, I continue to be at risk of acquiring hepatitis B, a serious disease. If in the future I continue to have occupational exposure to blood or other potentially infectious materials and I want to be vaccinated with hepatitis B vaccine, I can receive the vaccination series at no charge to me.
Signed: ________________________________ Witness: ______________________
Printed Name: _________________________
Date: __________________________________
APPENDIX B
|
|
Fermi
National Accelerator Laboratory P.O.Box 500 Batavia,
IL• 60510-0500 E-mail: foxen@fnal.gov |
Date:
To: Emergency physician
Re: Post exposure evaluation report for ___________________________ __________
Fermilab Employee ID#
The above individual is being treated initially by you for possible exposure to blood borne pathogens. Our Fermilab medical office will actively monitor follow up care. Please provide us with a copy of records documenting your initial evaluation and treatment. These would include:
Thank you for your help in managing this case.
Sincerely,
John Foxen, MD
Director, Occupational Health
Appendix C Fermilab
Post Exposure Evaluation Report (Questions
1-24 To be completed for each exposure incident)

EMPLOYER INFORMATION
1. Employee Name: __________________________________________________
2. Address: __________________________________________________________
__________________________________________________________
3. Home Telephone Number: __________________________________________
4. Social Security Number: ______-_____-______
5. ID Number: ____________
6. Division/Section: __________________________________________________
7. Job Title: __________________________________________________________
8. Hire Date: _________________________________________________________
9. Duration of current job: _____________________________________________
10. Date and Time of exposure: _________________________________________
11. Date and time of report: ____________________________________________
12. Name of person reported to: _________________________ Div/Sect: ______
13. Location of exposure:
Building ___________________ Dept. _______________ Room ______
14. Employee on duty? YES NO
15. Task being performed: ______________________________________________
16. Precautions taken: _________________________________________________
17. Blood or bodily fluid involved _______________________________________
18. Nature of exposure:
_____ Needlestick injury _____ Non-intact skin
_____ Other sharp instrument injury _____ Human bite
_____ Mucous membrane splash _____ Other_______________
19. Exposure occurred during
_____ Needle recapping _____ Putting needle in box
_____ Handling trash _____ Medication administration
_____ Handling linens Other___________________________
20. Describe exposure/injury: __________________________________________
_____________________________________________________________________
21. Why did exposure occur? __________________________________________
_____________________________________________________________________
22. How could exposure have been prevented? ___________________________
______________________________________________________________________
SOURCE INFORMATION
23. Source patient exposure known? YES NO
24. Source patient: Name ____________________________________________
Social Security Number ____________________________
Date of Birth ______________________________________
Address _________________________________________
_________________________________________
Phone ___________________________________________
Appendix D Worksheet for FNAL
Medical Office Use only
EMPLOYEE EVALUATION
1. Hepatitis B Vaccine History YES NO Date __________
Completed 3 dose series YES NO Date __________
Post vaccination serology YES NO Date __________
Prior Hepatitis serology history YES NO Date __________
Prior HIV serology history YES NO Date __________
2. Post testing
|
Name of test |
Date Sent |
Date Reported |
Results |
|
HIV serology |
|
|
|
|
HbsAG |
|
|
|
HEPAPTITS B VACCINATION EVALUATION
1. Employee has received the Hepatitis B vaccine in the past YES NO
2. If no, does this employee desire the vaccine in the next program YES NO
3. Employee is recommended to have the Hepatitis B Vaccine due
To no contraindications (pregnant, likely to become pregnant in
the near future, nursing) YES NO
4. Treatment given ___________________________________________________________________
5. Employee has been counseled and informed of:
_____ significance of exposure
_____ risk of infection
_____ guidelines of prevention of spread
_____ recommendations of employee’s ability to receive
Hepaptis B vaccine
_________________________________________________________
FNAL Medical office MD or RN Signature and date
_________________________________________________________
Employee signature and date
6. Healthcare professional’s written opinion on exposure provided to employee along with test results needed for further follow-up. YES NO
PHYSICIAN EVALUATION
(To be completed by Fermilab MD)
SOURCE PATIENT:
1. Source patient evaluation:
2. Source patient blood tests:
|
Name of test |
Date Sent |
Date Reported |
Result |
|
HIV Serology |
|
|
|
|
HbsAG |
|
|
|
|
Hepatitis C |
|
|
|
|
RPR |
|
|
|
|
Other |
|
|
|
EXPOSED PATIENT/EMPLOYEE:
1. This exposure is considered:
_____ Non-infectious non-penetrating requires no further follow-up
_____ Potentially infectious, requires follow-up.
2. Recommended employee and source (if source known) be drawn for HIV and Hepatitis B testing with results to be given employee by Medical Office as they are available.YES NO
3. Additional comments:
___________________________________________________
Physician Signature and date