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Exposure Control Plan

Exposure Control Plan. POLICY.

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Exposure Control Plan

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  1. Exposure Control Plan
  2. POLICY The Bethany Beach Volunteer Fire Company is committed to providing a safe and healthful work environment for our entire staff. In pursuit of this goal, the following exposure control plan (ECP) is provided to eliminate or minimize occupational exposure to blood borne pathogens in accordance with OSHA standards 29 CFR 1910.1030, “Occupational Exposure to Blood borne Pathogens.”
  3. ECP Contents Determination of employee exposure Implementation of various methods of exposure control, including: Universal precautions Engineering and work practice controls Personal protective equipment Housekeeping Laundry Labels Hepatitis B vaccination FLU, TB and H1N1 vaccinations. Post exposure evaluation and follow-up Communication of hazards to members, employees and training Recordkeeping Procedures for evaluating circumstances surrounding exposure incidents
  4. Administration of the Plan The EMS Chief is responsible for implementation of the ECP. The EMS Chief will maintain, review and update the ECP at least annually and whenever necessary to include new or modified tasks and procedures. Those members or 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 ECP. The EMS Chief will provide and maintain all necessary personal protective equipment (PPE), engineering controls (e.g., sharps containers), labels and red bags as required by the standard. The EMS Chief will ensure that adequate supplies of the aforementioned equipment are available in the appropriate sizes. The EMS Chief or his/her designee will be responsible for ensuring that all medical actions required by the standard are performed and that appropriate employee health and OSHA records are maintained. The EMS Chief or his/her designee will be responsible for training, documentation of training and making the written ECP available to members and employees, OSHA and NIOSH representatives.
  5. Employee Exposure Determination Job TitleDepartment/Location Firefighter Emergency Scene (Fire/Rescue/Medical) Handling Regulated Waste/Equipment Inspections Firefighter/EMT Emergency Scene (Fire/Rescue/Medical) Handling Regulated Waste/Equipment Inspections Company Officer Emergency Scene (Fire/Rescue/Medical) Handling Regulated Waste/Equipment Inspections Career FF Emergency Scene (Fire/Rescue/Medical) EMT-Chief Equipment Inspections Part-Time Employee Handling Regulated Waste/Environmental Services
  6. Employee Exposure Determination Cont. Job TitleTask/Procedure General Member/Auxiliary Kitchen Tasks/Fund Raising Events Handling Regulated Waste Environmental Services Fire Police Emergency Scene (Fire/Rescue/Medical) Handling Regulated Waste Junior Member Emergency Scene (Fire/Rescue/Medical) Handling Regulated Waste
  7. Methods of Implementation & Control Universal Precautions Exposure Control Plan Engineering Controls Work Practices Personal Protective Equipment (PPE) Housekeeping Laundry Labels
  8. Universal Precautions All members and employees will utilize universal precautions.
  9. Exposure Control Plan Employees and members covered by the blood borne pathogen standards receive an explanation of this ECP during their initial training session. It will also be reviewed in their annual refresher training. All members and employees can review this plan at any time during their work shift or time spent at the station by contacting a Full Time FF/EMT or the EMS Chief. If requested, we will provide a member or employee with a copy of the ECP free of charge and within 7 days of the request. The EMS Chief is responsible for reviewing and updating the ECP annually or more frequently if necessary to reflect any new or modified tasks and procedures that affect occupational exposure and to reflect new or revised membership or employee classifications with occupational exposure.
  10. Engineering Controls & Work Practices Engineering controls and work practice controls will be used to prevent or minimize exposure to blood borne pathogens. The specific work practice controls used are listed below. Needleless lancets for blood sugar analysis Sharps containers located in each ambulances and first-in medical bags Bio-Hazard trash receptacles located in each ambulance, in the EMS supply room and bio-hazard bags available on each apparatus. Non-latex gloves available on each piece of equipment as well as in areas of medium to high risk of exposure to BBP or OPIM. Commercial washing machine or uniform replacement if needed
  11. Engineering Controls & Work Practices Cont. Sharps disposal containers are inspected and maintained or replaced by the on duty EMS crew every day or whenever necessary to prevent overfilling. This company identifies the need for changes in engineering controls and work place practices through: Review of OSHA Records Incident Reports Employee Interviews Suggestions from members
  12. Engineering Controls & Work Practices Cont. Both front-line workers and management officials/company officers are involved in this process in the following manner: Each official or officer should be educated in the ECP and should ensure that members and employees follow the plan. Each member or employee should be pro-active in the prevention of exposure by following the plan, using the ECP as a resource and contacting management or officers with concerns or suggestions. The EMS Chief is responsible for ensuring that these recommendations are implemented.
  13. Personal Protective Equipment PPE is provided to our members and employees at no cost to them. Training in the use of the appropriate PPE for specific tasks or procedures is by provided by the EMS Chief, Fire Company Training Officer or Field Training Officers. The Types of PPE available to members or employees are as follows: Non Latex Gloves Eye Protection/Face Shields Splash Protection gowns Half Arm tyvek sleeves EMS coats and storm pants for full-time employees shall meet NFPA 1999 (2013 edition) EMS Gear for EMS Only Members shall meet NFPA 1999 (2013 edition) All turn-out gear, helmets, extrication gloves, boots and clothing when ever possible should be specified as meeting or exceeding NFPA 1999 (2013 edition) after 1/1/2014
  14. Personal Protective Equipment Cont. PPE (Gloves, Eye Protection) is located in each ambulance both in the front cab and also in the rear patient compartment. Splash protection is located in the rear patient compartment and also in each of the first in bags. PPE on fire apparatus (Non Latex Gloves) are located in the cab of the apparatus, or have been personally issued (extrication gloves or eye protection) or may be retrieved from the ambulance while on the scene of an emergency response. The Officer in Charge, Crew Leader or Senior Firefighter in charge of a crew shall ensure appropriate PPE is worn by members or employees that are operating where exposure may take place.
  15. Personal Protective Equipment Cont. All members or employees using PPE must observe the following precautions: Wash hands immediately or as soon as feasible after removing gloves or other PPE. Remove PPE after it becomes contaminated and before leaving the work area. Used PPE may be disposed of in an appropriate bio-hazard trash receptacle, or laundered immediately using appropriate level of cleaning solution or may be disposed of in an appropriate bio-hazard container, bag or receptacle. Wear appropriate gloves when it is 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 or contaminated, or if their ability to function as a barrier is compromised.
  16. Personal Protective Equipment Cont. Utility/Extrication 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. Never wash or decontaminate disposable gloves for reuse. Wear appropriate face and eye protection when splashes, sprays, splatters, or droplets of blood or OPIM pose a hazard to the eye, nose, or mouth. 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.
  17. Personal Protective Equipment Cont. The procedure for handling used PPE is as follows: Remove gloves in a manner that protects the wearer from touching the outside contaminated surface. The first glove should be removed by turning itself inside out and grasped in the hand of the second glove. The second glove should be removed in such a manner that it turns itself inside out thus keeping all contaminated surfaces within the second glove which can be disposed of in an appropriate bio-hazards container. If contaminated glasses and or a face shield are being worn, replace gloves with a clean pair, remove the eye protection in such a manner as to protect from further exposure, discard in an appropriate bio-hazard container and then repeat the steps above for removing gloves. Resuscitation equipment, medical supplies and any disposable materials contaminated by any BBP or OPIM should be disposed of immediately in an appropriate bio-hazard container.
  18. Personal Protective Equipment Cont. Contaminated turn-out gear should be removed immediately or as soon as feasible and grossly decontaminated by using copious amounts of water. Gear should then be immediately washed with an approved cleaning solution (Tide®) and at temperatures consist with killing HBV, HCV, HIV other BBP or OPIM.
  19. Housekeeping Regulated waste is placed in containers which are closable, constructed to contain all contents and prevent leakage, appropriately labeled or color coded (see the following section “Labels”), and closed prior to removal to prevent spillage or protrusion of contents during handling. The procedure for handling sharps disposal containers is: Identify that container is 75% or ¾ full. Close the lid to secure the contents of the container. If equipped with a manual safety seal engage the locking mechanism. Using wide medical tape (2” or 3”) wrap the box and lid at least twice from side to side and end to end to assist in securing the lid and locking mechanism. Dispose of the container in an appropriate bio-hazard waste container either at a medical facility prior to returning to station or in the EMS supply room at Station 70 Headquarters.
  20. Housekeeping Cont. The procedure for handling other regulated waste is: Empty all contaminated waste at the conclusion of each call. If you are at a medical facility dispose of the bio-hazard waste in an approved container at the hospital. If the bio-hazard waste is accumulated but transport to a medical facility does not occur (e.g., transfers of care, CPR/DOPA, MVC), than dispose of the bio-hazard waste in the bio-hazard waste container at Station 70 Headquarters in the EMS supply room. Contaminated sharps are discarded immediately or as soon as possible in containers that are closable, puncture-resistant, leak proof on sides and bottom and appropriately labeled or color-coded. Sharps disposal containers are available in each ambulance as well as in each first in bag. Replacement Sharps containers are stored in the EMS Supply Room, Cabinet #2 at Station 70 Headquarters. Broken glassware that may be contaminated is only picked up by using mechanical means, such as brush and dustpan.
  21. Laundry The following contaminated articles will be laundered by this company: Turn-out gear (Hoods, Coats, Pants, Gloves) Personal Uniforms or other PPE capable of being decontaminated The following laundering requirements must be met: Handle contaminated laundry as little as possible, with minimal agitation When transporting contaminated materials to the wash room, use a leak-proof and color-coded container/bag. Wear the following PPE when handling and/or sorting contaminated laundry: Non Latex Gloves Tyvek Sleeves (if appropriate) Eye Protection Splash protection (if appropriate)
  22. Laundry Cont. The washing machine uses only liquid laundry detergent. Tide or Tide HE is recommended for Fire Resistive Clothing/Personal Uniforms as well as using the hottest water allowable as listed in the clothing care tag. Items that may have bleach applied may do so at a range of 1:10 – 1:100 concentrations, but is not necessary or required.
  23. Labels The following labeling methods are used in this facility
  24. LabelsBio-Hazard Trash/Bags/Sharps ContainersRed in Color with the Symbol Below
  25. LabelsChemicalsNFPA 704 multi-color symbol or GHS labeling system affixed to container.
  26. LabelsPoisonsBlack and White with Skull and Crossbones
  27. Labels Cont. The EMS Chief is responsible for ensuring that warning labels are affixed to red bags and are used as required if regulated waste of contaminated equipment is brought into the facility. Employees and members are to notify the EMS Chief if they discover regulated waste containers, refrigerators containing blood or OPIM, contaminated equipment etc., without proper labels.
  28. Hepatitis B Vaccination The EMS Chief or his/her designee will provide training to new members and employees on hepatitis B, Flu and H1N1 vaccinations as well as TB testing, addressing safety, benefits, efficacy, methods of administration and availability.
  29. Hepatitis B Vaccination Cont. The hepatitis B vaccination series, Annual Flu, TB and H1N1 shots are available at no cost after initial employee or member training and within 10 days of initial assignment to all employees and members identified in the exposure determination section of this plan. Hepatitis Vaccination is encouraged unless: 1) documentation exists that the employee or member has previously received the series; 2) antibody testing reveals that the employee is immune; or 3) medical evaluation shows that vaccination is contraindicated. The Flu and H1N1 vaccinations are highly recommended for EMT’s, First Responders, Firefighters and any other member that may be directly exposed to a patient who has an active flu virus. TB testing is mandatory for all EMT’s and First Responders unless the member or employee can document a contraindications for the testing.
  30. Hepatitis B Vaccination Cont. Vaccinations and testing will be provided by Nanticoke Occupational Health or the State of Delaware Health and Social Services Division. The site for where the vaccination will be given varies and will be determined at the time of scheduling. However, if a member or employee declines the vaccination, the member or employee must sign a declination form. Those who decline may request and obtain the vaccination at a later date at no cost. Documentation of refusal of the vaccination is kept in the employee or member file at the BBVFC Headquarters.
  31. Hepatitis B Vaccination Cont. Following the medical evaluation, a copy of the health care professional’s written opinion will be obtained and provided to the employee within 15 days of the completion of the evaluation. It will be limited to whether the employee requires the hepatitis vaccine and whether the vaccine was administered.
  32. Post Exposure Evaluation and Follow Up Should an exposure incident occur, first attempt to contact the EMS CHIEF at the following number(s): (302) 539-7700 ext. 241, (302) 258-5143 (EMS Chief’s Cell), or home number listed on the Company Officer List, if no return call is made within thirty minutes contact any fire line officer for assistance.
  33. Post Exposure Evaluation and Follow Up Cont. An immediately available confidential medical evaluation and follow up will be conducted by an Emergency Room Physician at the closest medical facility. Following initial first aid (clean the wound, flush eyes or other mucous membranes, etc.), the following activities will be performed: Document the route of exposure and how the exposure occurred. Identify and document the source individual (unless the employer can establish that identification is infeasible or prohibited by state or local law). Obtain consent and make arrangements to have the source individual tested as soon as possible to determine HIV, HCV and HBV infectivity; document that the source individual’s test results were conveyed to the employee’s health care provider. If the source individual is already known to be HIV, HCV and/or HBV positive, new testing need not be performed.
  34. Post Exposure Evaluation and Follow Up Cont. Assure that the exposed employee or member is provided with the source individual’s test results and with information about the applicable disclosure laws and regulations concerning the identity and infectious status of the source individual (e.g., laws protecting confidentiality). After obtaining consent, collect exposed employee’s blood as soon as feasible after exposure incident, and test blood for HBV and HIV serological status. If employee does not give consent for HIV serological testing during collection of blood for baseline testing, preserve the baseline blood sample for at least 90 days; if the exposed employee elects to have the baseline sample tested during this wait period, perform testing as soon as feasible. 
  35. Post Exposure Evaluation and Follow Up Cont. ADMINISTRATION OF POST-EXPOSURE EVALUATION AND FOLLOW-UP – The EMS Chief or his/her designee will ensure 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 blood borne pathogens standard.
  36. Post Exposure Evaluation and Follow Up Cont. The EMS Chief or his/her designee ensures that the healthcare 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 Relevant employee medical records, include vaccination status The EMS Chief or his/her designee provides the employee with a copy of the evaluating health care professional’s written opinion within 15 days after completion of the evaluation.
  37. Post Exposure Evaluation and Follow Up Cont. PROCEDURES FOR EVALUATING CIRCUMSTANCES SURROUNDING AN EXPOSURE INCIDENT – The EMS Chief or his/her designee will review the circumstances of all exposure incidents to determine: Were engineering controls in use at the time of the exposure Work place practices followed A description of the device being used (including type and brand) Protective equipment of clothing that was used at the time of the exposure incident (gloves, eye/face shields, etc.) Location of the incident (on scene, in ambulance, at hospital etc.) Procedure being performed when the incident occurred Employee’s training
  38. Post Exposure Evaluation and Follow Up Cont. The EMS Chief will record all percutaneous injuries from contaminated sharps in a Sharps Injury Log. If revisions to the ECP are necessary the EMS Chief or his/her designee will ensure that appropriate changes are made. (Changes may include an evaluation of safer devices, adding employees to the exposure determination list, etc.)
  39. Employee Training All members or employees who have occupational exposure to blood borne pathogens receive initial and annual training conducted by the EMS Chief or his/her designee. The EMS Chief or his/her designee will be a certified instructor, be familiar with DHSS Exposure Policy, the BBVFC Exposure Control Plan and have operational knowledge of the BBVFC Fire/EMS Services.
  40. Employee Training Cont. All members or employees will have an occupational exposure to blood borne pathogens receive training on the epidemiology, symptoms and transmissions of blood borne pathogens diseases. In addition, the training program covers, at a minimum, the following elements: A copy and explanation of the OSHA blood borne pathogen standard An explanation of our ECP and how to obtain a copy An explanation of methods to recognize tasks and other activities that may involve exposure to blood and OPIM, including what constitutes an exposure incident. An explanation of the use and limitations of engineering controls, work practices and PPE. An explanation of the types, uses, location, removal, handling, decontamination, and disposal of PPE
  41. Employee Training Cont. An explanation of the basis for PPE selection Information on the hepatitis B vaccine, including information on its efficacy, safety, method of administration, the benefits of being vaccinated, and that the vaccine will be offered free of charge Information on the appropriate actions to take and persons to contact in an emergency involving blood or OPIM 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. Information on the post-exposure evaluation and follow-up that the employer is required to provide for the employee following an exposure incident. An explanation of the signs and labels and/or color coding required by the standard and used at this facility An opportunity for interactive questions and answers with the person conducting the training session. Training materials for this facility are available at the EMS Chief’s Office.
  42. Recordkeeping Training records are completed for each employee upon completion of training. These documents will be kept for at least three years in the EMS Chief’s office and on the shared network drive. Training records will include: The dates and times of training sessions The contents or a summary of the training sessions The names and qualifications of persons conducting the training The names and job titles of all persons attending the training sessions Employee training records are provided upon request to the employee or the employee’s authorized representative within 14 working days. Such requests should be addressed to the EMS Chief.
  43. Medical Records Medical records are maintained for each employee with occupational exposure in accordance with 29 CFR 1910.1020, “Access to Employee Exposure and Medical Records.” The EMS Chief is responsible for the maintenance of the required medical records. These confidential records are kept in the EMS Chief’s office in an employee health record file for at least the duration of employment plus 30 years. Employee medical records are provided upon request of the employee or to anyone having written consent of the employee within 14 working days. Such requests should be sent to the EMS Chief, C/O Bethany Beach Vol. Fire Co. Inc – P.O. Box 609 Bethany Beach, DE 19930.
  44. OSHA Recordkeeping An exposure incident is evaluated to determine if the case meets OSHA’s Recordkeeping Requirements (29 CFR 1904). This determination and the recording activities are done by the EMS Chief. (See appendix for 29 CFR 1904)
  45. Sharps Injury Log In addition to the (29 CFR 1904) Recordkeeping Requirements, all percutaneous injuries from contaminated sharps are also recorded in a Sharps Injury Log. All incidences must include at least: Date of Injury Type and Brand of the device involved (lancet, syringe, IV catheter, needle) Work area where incident occurred Explanation of how the incident occurred. This log is reviewed as part of the annual program evaluation and maintained for at least five years following the end of the calendar year covered. If a copy is requested by anyone, it must have any personal identifiers removed from the report.
  46. Declination Form Bethany Beach Volunteer Fire Company HEPATITIS B, FLU, and H1N1 VACCINE DECLINATION FORM 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), Flu or the H1N1 infection. I have been given the opportunity to be vaccinated with the hepatitis B, Flu or H1N1 vaccine, at no charge to myself. However, I decline hepatitis B, Flu or H1N1 vaccination at this time. I understand that by declining this vaccine, I continue to be at risk of acquiring hepatitis B, the Flu, H1N1 of other serious diseases. 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, Flu or H1N1 vaccine, I can receive the vaccination(s) at no charge to me. Signed: _____________________________ Date: _________________________ Printed Name: _______________________ Witness:_______________________ EMS Chief:___________________________
  47. Plan Updated This document updated 1/4/2014 EMS Chief Douglas W. Scott
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