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Grand Coulee, WA Exposure Control Plan

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EXPOSURE CONTROL PLAN
CITY OF GRAND COULEE

INDEX

SECTION 1...................................................C2

PURPOSE................................................C2

SECTION 2...................................................C3-C5

PROGRAM MANAGEMENT.....................................C3

EXPOSURE CONTROL OFFICER...............................C3-C4

DEPARTMENT SUPERVISOR..................................C4

EDUCATION/TRAINING COORDINATOR.........................C4

EMPLOYEES..............................................C5

AVAILABILITY OF PLAN TO EMPLOYEES...................C5

REVIEW AND UPDATE OF PLAN..............................C6

SECTION 3...................................................C6-C9

EXPOSURE DETERMINATION.................................C6

JOB CLASSIFICATION FOR EXPOSURE........................C7-C9

SECTION 4...................................................C10-C16

COMPLIANCE METHODS.....................................C10

UNIVERSAL PRECAUTIONS..................................C10

ENGINEERING CONTROLS...................................C11

WORK PRACTICE CONTROLS.................................C12-C13

PERSONAL PROTECTIVE EQUIPMENT..........................C13-C15

HOUSE KEEPING..........................................C15-C16

SECTION 5...................................................C17-20

VACCINATION PROGRAM....................................C17

POST EXPOSURE EVALUATION...............................C17-C19

INFORMATION PROVIDED TO HEALTH PROFESSIONALS...........C19

HEALTH CARE'S WRITTEN OPINIONS.........................C19

MEDICAL RECORD KEEPING.................................C20

SECTION 6...................................................C21

LABELS AND SIGNS.......................................C21

SECTION 7...................................................C22-C23

INFORMATION AND TRAINING...............................C22-C23

SECTION ONE

PURPOSE:

One of the major goals of the Occupational Safety and Health Administration (OSHA) or WISHA is to regulate facilities where work is carried out...to promote safe work practices in an effort to minimize the incidence of illness and injury experienced by employees. Relative to this goal, OSHA has enacted the Bloodborne Pathogens Standard, codified as 29 CFR 1910.1030. The purpose of the Bloodborne Pathogens Standard (BPS) is to "reduce occupational exposure to Hepatitis B Virus (HBV), Human Immunodeficiency Virus (HIV) and other bloodborne pathogens" that employees may encounter in their work place.

THE CITY OF GRAND COULEE believes that there are a number of "good general principles" that should be followed when working with bloodborne pathogens. These include that:

1. It is prudent to minimize all exposure to bloodborne pathogens.

2. Risk of exposure to bloodborne pathogens should never be underestimated.

3. Our facility should institute as many work practice and engineering controls as possible to eliminate or minimize employee exposure to bloodborne pathogens.

We have implemented the Exposure Control Plan to meet the letter and intent of the OSHA/WISHA Bloodborne Pathogens Standard. The objective of this plan is twofold:

1. To protect our employees from the health hazards associated with bloodborne pathogens.

2. To provide appropriate treatment and counseling should an employee be exposed to bloodborne pathogens.

PAGE C2

SECTION TWO

GENERAL PROGRAM MANAGEMENT:

A. RESPONSIBLE PERSONS:

There are four major "Categories of Responsibility" that are central to the effective implementation of our Exposure Control Plan. These are:

1. The "Exposure Control Officer".

2. Department Supervisors.

3. Education/Training Instructors.

4. Employees of the City of Grand Coulee.

The following sections define the roles played by each of these groups in carrying out the plan. (Throughout this written plan, employees, or other persons, with specific responsibilities are identified. In the event of any changes, the DEPT. SUPERVISORS FOR THE CITY OF GRAND COULEE should be notified.)

EXPOSURE CONTROL OFFICER:

The Exposure Control Officer" will be responsible for overall management and support of our facility's Bloodborne Pathogens Compliance Program. Activities which are delegated to the Exposure Control Officer typically include, but are not limited to:

1. Overall responsibility for implementing the Exposure Control Plan for the entire Grand Coulee Department.

2. Working with management and other employees to develop and administer and any additional bloodborne pathogens related policies and practices needed to support the effective implementation of this plan.

3. Looking for ways to improve the Exposure Control Plan, as well as to advise and update the plan when necessary.

4. Collecting and maintaining a suitable reference library on the Bloodborne Pathogens Standard and bloodborne pathogens safety and health information.

5. Knowing current legal requirements concerning bloodborne pathogens.

6. Acting as facility liaison during OSHA/WISHA inspections.

PAGE C3

EXPOSURE CONTROL OFFICER:(con't)

7. Conducting periodic facility audits to maintain an up-to- date Exposure Control Plan.

It has been determined that the Exposure Control Officer will require assistance in fulfilling their responsibilities. To assist that person in carrying out the duties, an Exposure Control Committee, may be implemented.

THE EXPOSURE CONTROL OFFICER AND/OR EXPOSURE CONTROL COMMITTEE SHALL BE APPOINTED BY THE MAYOR FOR THE CITY OF GRAND COULEE

DEPARTMENT SUPERVISOR:

The Department Supervisors are responsible for exposure control in their respective areas. They work directly with the Exposure Control Officer and the employees of the City of Grand Coulee to ensure that proper exposure control procedures are followed.

THE DEPARTMENT SUPERVISORS SHALL BE THE CITY FOREMAN, POLICE CHIEF, AND THE CITY CLERK, OR SHALL BE APPOINTED BY THE MAYOR OF THE CITY OF GRAND COULEE.

EDUCATION/TRAINING COORDINATOR:

The Education/Training Coordinator will be responsible for providing information and training to all employees who have the potential for exposure to bloodborne pathogens. Activities falling under the direction of the Coordinator include:

1. Maintaining an up-to-date list of facility personnel requiring training (in conjunction with facility management).

2. Developing suitable education/training programs.

3. Scheduling periodic training seminars for employees.

4. Maintaining appropriate training documentation such as "Sign-in Sheets", Quizzes, etc.

5. Periodically reviewing the training programs with the Exposure Control Officer, Department Supervisors to include appropriate information.

THE EDUCATION/TRAINING COORDINATOR SHALL BE APPOINTED BY THE MAYOR OF GRAND COULEE.

PAGE C4

EMPLOYEES:

As with all Department activities, our employees have the most important role in our bloodborne pathogens compliance program, for the ultimate execution of much of our Exposure Control Plan rests in their hands. In this role they must do things such as:

1. Know what tasks they perform that have occupational exposure.

2. Attend the bloodborne pathogens training sessions.

3. Plan and conduct all operations in accordance with our work practice controls.

4. Develop good personal hygiene habits.

B. AVAILABILITY OF THE EXPOSURE CONTROL PLAN TO EMPLOYEES:

To help them with their efforts, our facility's Exposure Control Plan is available to our employees at any time. Employees are advised of this availability during their education/training sessions. Copies of the Exposure Control Plan are kept in the following locations:

1. Each employee of the Grand Coulee Police Department shall be issued a copy, to be kept in their Procedure Manual.

2. The Chief of Police shall maintain a copy, to be kept in his office.

3. A copy shall be kept in the computer memory files, under Word Perfect, MANUAL3

4. All other city employees shall be issued a copy.

C. REVIEW AND UPDATE OF THE PLAN:

The Department recognizes that it is important to keep the Exposure Control Plan up-to-date. To ensure this, the plan will be reviewed and updated under the following circumstances:

1. Annually, on or before January 30th of each year.

2. Whenever new or modified tasks and procedures are

implemented which affect occupational exposure of our

employees.

3. Whenever our employees' jobs are revised such that new

instances of occupational exposure may occur.

4. Whenever we establish new functional positions within our

facility that may involve exposure to bloodborne

pathogens.

PAGE C5

SECTION THREE

EXPOSURE DETERMINATION

One of the keys to implementing a successful Exposure Control Plan is to identify exposure situations employees may encounter. To facilitate this in our facility, we have prepared the following lists:

1. Job classifications in which all employees have occupational exposure to bloodborne pathogens.

2. Job classifications in which some employees have occupational exposure to bloodborne pathogens.

3. Tasks and procedures in which occupational exposure to bloodborne pathogens occur.

The initial lists were compiled on or before March 1, 1993

THE DEPARTMENT SUPERVISORS will revise and update these lists as our tasks, procedures, and classifications change.

PAGE C6

JOB CLASSIFICATIONS IN WHICH ALL EMPLOYEES HAVE EXPOSURE TO BLOODBORNE PATHOGENS

Below are listed job classifications in our facility where all employees may come into contact with human blood or other potentially infectious materials, which may result in possible exposure to bloodborne pathogens:

JOB TITLE DEPARTMENT/LOCATION

CHIEF OF POLICE G. C. POLICE DEPT.

REGULAR POLICE OFFICERS G. C. POLICE DEPT.

RESERVE POLICE OFFICERS G. C. POLICE DEPT.

FEMALE MATRONS G. C. POLICE DEPT.

ANIMAL CONTROL OFFICER G. C. POLICE DEPT.

BLOODBORNE CLEANUP PERSON G. C. POLICE DEPT.

UTILITY FOREMAN CITY OF GRAND COULEE

TREATMENT PLANT OPERATOR CITY OF GRAND COULEE

TREATMENT PLANT ASSISTANT CITY OF GRAND COULEE

UTILITY WORKER CITY OF GRAND COULEE

TEMPORARY WORKERS CITY OF GRAND COULEE

PART TIME EMPLOYEES CITY OF GRAND COULEE

CITY CLERKS CITY OF GRAND COULEE

PAGE C7

JOB CLASSIFICATIONS IN WHICH SOME EMPLOYEES HAVE EXPOSURE TO BLOODBORNE PATHOGENS

Below are listed the job classifications in our facility where some employees may come into contact with human blood potentially infectious materials which may result in possible exposure to bloodborne pathogens:

NONE AT THIS TIME

PAGE C8

WORK ACTIVITIES INVOLVING POTENTIAL EXPOSURE TO BLOODBORNE PATHOGENS

Below are listed the tasks and procedures in our facility which employees may come into contact with human blood or other potentially infectious materials, which may result in exposure to bloodborne pathogens:

TASK/PROCEDURE JOB CLASSIFICATION DEPT. LOCATION

HANDLING OF SUSPECTS OFFICERS AND MATRONS GRAND COULEE PD

VICTIM AID IN ACCIDENTS OFFICERS AND MATRONS GRAND COULEE PD

HANDLING OF CONTAMINATED OFFICERS AND MATRONS GRAND COULEE PD

MATERIALS

HANDLING OF DECEASED OFFICERS AND MATRONS GRAND COULEE PD

PERSONS

ANIMAL HANDLING/ OFFICERS AND ANIMAL

ANIMAL BITES CONTROL OFFICER GRAND COULEE PD

CLEAN UP OF BLOOD/ BLOOD BORNE CLEANUP GRAND COULEE PD

OTHER PATHOGENS PERSON

HANDLING OF CITY OF GRAND

CONTAMINATED MATERIALS ALL CITY EMPLOYEES COULEE

WORKING IN WASTE ALL CITY CREW CITY OF GRAND

WATER EMPLOYEES COULEE

CLEAN UP OF SHARPS ALL CITY EMPLOYEES CITY OF GRAND

AND DISPOSAL COULEE

*** NOTE *** FOR THE PURPOSE OF RECORDING GRAND COULEE PD WOULD INCLUDE ANY AREA OF COVERAGE BY THIS DEPARTMENT.

ALSO THE CITY OF GRAND COULEE WOULD INCLUDE THE WASTE WATER TREATMENT PLANT, PUMP HOUSES AND INCLUSIVE OF CITY BOUNDARIES.

PAGE C9

SECTION FOUR

METHODS OF COMPLIANCE

We understand that there are a number of areas that must be addressed in order to effectively eliminate or minimize exposure to bloodborne pathogens in our facility or working areas. The first five areas we deal with in our plan are:

1. The use of Universal Precautions.

2. Establishing appropriate Engineering Controls.

3. Implementing appropriate Work Practice Controls.

4. Using necessary Personal Protective Equipment.

5. Implementing appropriate Housekeeping Procedures.

Each of these areas is reviewed with the employees during their bloodborne pathogens related training (see the "Information and Training" section of this plan for additional information). By rigorously following the requirements of OSHA's Bloodborne Pathogens Standard in these five areas, we feel that we will eliminate or minimize our employees' occupational exposure to bloodborne pathogens as much as is possible.

A. UNIVERSAL PRECAUTIONS:

In our facility we have begun the practice of "Universal Precautions" on March 1, 1993 . As a result, we treat all human blood and body fluids such as semen and vaginal secretions as if they are known to be infectious for HBV, HIV and other bloodborne pathogens.

In circumstances where it is difficult or impossible to differentiate between body fluid types, we assume all body fluids to be potentially infectious.

The DEPARTMENT SUPERVISORS are responsible for overseeing our Universal Precautions Program.

PAGE C10

B. ENGINEERING CONTROLS:

One of the key aspects to our Exposure Control Plan is the use of Engineering Controls to eliminate or minimize employee exposure to bloodborne pathogens. As a result, employees use cleaning and maintenance and other equipment that is designed to prevent contact with blood or other potentially infectious materials.

The DEPARTMENT SUPERVISORS will periodically works with department staff to review tasks and procedures performed in our facility where engineering controls can be implemented or updated. As part of this effort, a facility survey was completed on March 1, 1993 identifying three things:

1. Operations where engineering controls are currently employed.

2. Operations where engineering controls can be updated.

3. Operations currently not employing engineering controls, but where engineering controls could be beneficial.

Each of these lists is reexamined during our annual Exposure Control Plan review and opportunities for new or improved engineering controls are identified. Any existing engineering control equipment is also reviewed for proper function and needed repair or replacement every 12 months, in conjunction with the department.

In addition to the engineering controls, the following are to be used throughout our facility and day to day practices or as we may encounter within our working conditions:

1. Handwashing facilities (or antiseptic hand cleansers and towels or antiseptic towelettes), which are readily accessible to all employees.

2. Containers for contaminated sharps (needles, razor blades, glass) having the following characteristics:

A. Puncture-resistant

B. Color-coded or labeled with a biohazard warning label

C. Leak-proof on the sides and bottom

3. Specimen containers which are:

A. Leak-proof

B. Puncture-resistance, if necessary

C. Color-coded or labeled with a bio-hazard warning label

PAGE C11

C. WORK PRACTICE CONTROLS:

In addition to engineering controls, our facility uses a number of Work Practice Controls to help eliminate or minimize employee exposure to bloodborne pathogens. Many of these Work Practice Controls have been in effect for some time. Any controls that we are using for the first time will be fully implemented before

May 1, 1993.

The persons in our work areas who are responsible for overseeing the implementation of these Work Practice Controls is the DEPARTMENT SUPERVISORS. They will work in conjunction with other personnel to effect this implementation.

Our facility has adopted the following Work Practice Controls as part of our Bloodborne Pathogens Compliance Program:

1. Employees wash their hands immediately, or as soon as feasible, after removal of potentially contaminated gloves or other personal protective equipment.

2. Following any contact of body areas with blood or any other infectious materials, employees wash their hands and any other exposed skin with soap and water as soon as possible. They also flush mucous membranes with water.

3. Contaminated needles and other contaminated sharps are not bent, recapped or removed unless:

A. It can be demonstrated that there is no feasible alternative.

B. The action is required by specific medical procedure or to be used as evidence in a crime.

C. In the situations above the recapping or needle removal is done by the use of a medical devise or a one-handed method.

4. Contaminated sharps are placed in appropriate containers immediately, or as soon as possible.

5. Eating, drinking smoking, applying cosmetics or lip balm and handling contact lens' is prohibited in work areas where there is potential for exposure to bloodborne pathogens.

6. Food and drink is not to be kept in refrigerators, freezers, on countertops or in other storage areas where blood or other potentially infectious materials are present.

PAGE C12

7. All procedures involving blood or other infectious materials minimize splashing or other actions generating droplets of these materials.

8. Specimens of blood or other materials are placed in designated leak-proof containers, appropriately labeled, for handling and storage.

9. If outside contamination of a primary specimen container occurs, that container is placed within a second leak- proof container, appropriately labeled, for handling and storage. If the specimen can puncture the primary container, the secondary container must be puncture- resistant as well.

10. Equipment which becomes contaminated is examined prior to servicing or shipping, and decontaminated as necessary.

A. An appropriate biohazard warning label is attached to any contaminated equipment, identifying the contaminated portions.

B. Information regarding the remaining contamination is conveyed to all infected employees, the equipment manufacture and the equipment service representative prior to handling, servicing or shipping.

When a new employee comes to our facility then that employee will be trained by the Training Coordinator or other instructor regarding any work practice controls that the employee is not experienced with.

D. PERSONAL PROTECTIVE EQUIPMENT:

Personal Protective Equipment is our employees' "last line of defense" against bloodborne pathogens. Because of this, our facility provides (at no cost to our employees) the Personal Protective Equipment that they need to protect themselves against such exposure. This list includes, but is not limited to:

GLOVES WASHING/DECONTAMINATION

SAFETY GLASSES/GOGGLES MATERIALS

SHARPS CONTAINERS CONTAMINATION CONTAINERS

FACE SHIELDS/POCKET MASKS (COLOR CODED)

GOWNS/COVERALLS

The Department Supervisors, are responsible for ensuring that all work areas have appropriate personal protective equipment available to employees.

PAGE C13

Our employees are trained regarding the use of the appropriate personal protective equipment for their job classifications and tasks/procedures they perform. Initial training about personal protective equipment was completed in our facility on or before

Jan. 30, 1994 . Additional training is provided, when necessary.

To ensure that personal protective equipment is not contaminated and is in the appropriate condition to protect employees from potential exposure, our facility adheres to the following practices:

1. All personal protective equipment is inspected periodically and repaired or replaced as needed to maintain its effectiveness.

2. Reusable personal protective equipment is cleaned, laundered and decontaminated as needed.

3. Single-use personal protective equipment, (or other equipment that cannot be decontaminated) is disposed of, by forwarding that equipment to Coulee Community Hospital.

To make sure that this equipment is used as effectively as possible, our employees adhere to the following practices when using their personal protective equipment:

1. Any garments penetrated by blood or other infectious materials are removed immediately, or as soon as is feasible.

2. All potentially contaminated personal protective equipment is removed prior to leaving the work area.

3. Gloves are worn in the following circumstances:

- Whenever employees anticipate hand contact with potentially infectious materials.

- When handling or touching contaminated items or surfaces.

4. Disposable gloves are replaced as soon as practical after contamination or if they are worn, punctured or otherwise lose their ability to function as an "exposure barrier".

5. Utility gloves are decontaminated for reuse unless they are cracked, peeling, torn or exhibit other signs of deterioration, at which time they are disposed of.

PAGE C14

6. Masks and eye protection (such as goggles, face shields, etc.) are used whenever splashes or sprays may generate droplets of infectious materials.

7. Protective clothing (such as coats) is worn whenever potential exposure to the body is anticipated.

E. HOUSEKEEPING:

Maintaining our facility in a clean and sanitary condition is an important part of our Bloodborne Pathogens Compliance Program. To facilitate this, we have set up a written schedule for cleaning and decontamination of the appropriate areas of the facility. The schedules provides the following information:

-The area to be cleaned/decontaminated.

-Cleansers and disinfectants to be used.

-Any special instructions that are appropriate.

Using this schedule, our janitorial/cleaning staff, regular staff employs the following practices:

1. All equipment and surfaces are cleaned/decontaminated after contact with blood or other potentially infectious materials:

-Immediately (or as soon as feasible) when surfaces are overtly contaminated.

-After any spill of blood or infectious materials.

-At the end of the work shift if the surface may have been contaminated during that shift.

2. Protective coverings (such as plastic trash bags or wrap, aluminum foil or absorbent paper) are removed and replaced:

-As soon as it is feasible when overtly contaminated.

-At the end of the work shift if they may have been contaminated during that shift.

3. All trash containers, pails, bins, receptacles intended for use routinely are inspected, cleaned, and decontaminated as soon as possible.

4. Potentially contaminated broken glassware is picked up using mechanical means (dust pan, brush. tongs. etc.).

PAGE C15

DEPARTMENT SUPERVISORS are responsible for setting up our cleaning and decontamination schedule and making sure it is carried out within our facility.

We are also very careful in our facility in handling regulated waste (including used bandages, feminine hygiene products and other potentially infectious materials). Starting on or before Jan. 1, 1994 the following procedures are used with all of these types of wastes:

1. They are discarded or "bagged" in containers that are:

-Closeable.

-Puncture-resistant if the discarded materials have the potential to penetrate the container.

-Leak-proof if the potential for fluid spill or leakage exists.

-Red in color or labeled with the appropriate biohazard warning label.

2. Containers for this regulated waste are placed in appropriate locations in our facility within easy access of our employees and as close as possible to the sources of the waste.

3. Waste containers are maintained upright, routinely replaced and not allowed to overfill.

4. Contaminated laundry is handled as little as possible and is not sorted or rinsed where it is used.

5. Whenever our employees move containers of regulated waste from one area to another the containers are immediately closed and placed inside an appropriate secondary container if leakage is possible from the first container.

COULEE COMMUNITY HOSPITAL, GRAND COULEE is responsible for the collection and handling of our facility's contaminated wastes.

A trained bloodborne pathogen person shall collect and dispose of materials.

PAGE C16

SECTION V

HEPATITIS B VACCINATION, POST-EXPOSURE EVALUATION AND FOLLOW-UP:

Everyone in our facility recognizes that even with good adherence to all of our exposure prevention practices,exposure incidents can occur. As a result, we have implemented a Hepatitis B Vaccination Program, as well as set up procedures for post-exposure evaluation and follow-up should exposure to bloodborne pathogens occur.

A. VACCINATION PROGRAM:

To protect our employees as much as possible from the possibility of Hepatitis B infection, our facility has implemented a vaccination program. This program is available, at no cost, to all employees who have occupational exposure to bloodborne pathogens.

The vaccination program consists of a series of three inoculations over a six-month period. As part of their bloodborne pathogens training, our employees have received information regarding Hepatitis vaccination, including its safety and effectiveness.

Coulee Community Hospital, Grand Coulee, Wa. is responsible for setting up and operating our vaccination program, which has been in effect since Oct. 1, 1992 .

Vaccinations are performed under the supervision of a licensed physician or other healthcare professional. Employees who have declined to take part in the program are listed as well, and have signed the "Vaccination Declination Form".

To ensure that all employees are aware of our vaccination program, it is thoroughly discussed in the bloodborne pathogens training. We also have posted "Vaccination Program Notices" in prominent places throughout our facility.

B. POST-EXPOSURE EVALUATION AND FOLLOW-UP

If one of our employees is involved in an incident where exposure to bloodborne pathogens may have occurred there are two things that we immediately focus our efforts on:

1. Investigating the circumstances surrounding the exposure incident.

2. Making sure that our employees receive medical consolation and treatment (if required) as expeditiously as possible.

PAGE C17

The Department Supervisors will investigate every exposure incident that occurs in our facility, or while performing our normal duties with the department. This investigation is initiated within 24 hours after the incident occurs and involves gathering the following information.

1. When the incident occurred.

- Date and Time

2. Where the incident occurred

3. What potentially infectious materials were involved in the incident.

- Type of material, blood etc.

4. Source of the material.

5. Under what circumstances the incident occurred.

- Type of work being performed.

6. How the incident was caused.

7. Personal protective equipment being used at the time of the incident.

8. Actions taken as a result of the incident.

- Employee decontamination, cleanup, notifications made.

After this information is gathered it is evaluated, a written summary of the incident and its causes is prepared and recommendations are made for avoiding similar incidents in the future. (See "Incident Investigation Form")

In order to make sure that our employees receive the best and most timely treatment if an exposure to bloodborne pathogens should occur, our facility has set up a comprehensive post-exposure evaluation and follow-up process. We use the "checklist" at the end of this section to verify that all the steps in the process have been taken correctly. This process was implemented on or before

May 1, 1993 and is overseen by The Mayor of Grand Coulee.

We recognize that much of the information involved in this process must remain confidential, and will do everything possible to protect the privacy of the people involved.

As the first step in this process we provide as exposed employee with the following confidential information:

1. Documentation regarding the routes of exposure and circumstances under which the exposure incident occurred.

2. Identification of the source individual (unless infeasible or prohibited by law).

PAGE C18

Next, if possible, we test the source individual's blood to determine HBV and HIV infectivity. This information will also be made available to the exposed employee, if it is obtained. At that time, the employee will be made aware of any applicable laws and regulations concerning disclosure of the identity and infectious status of a source individual.

Finally we collect and test the blood of the exposed employee for HBV and HIV status.

Once these procedures have been completed, an appointment is arranged for the exposed employee with a qualified healthcare professional to discuss the employee's medical status. This includes an evaluation of any reported illnesses, as well as any recommended treatment.

C. INFORMATION PROVIDED TO THE HEALTHCARE PROFESSIONAL:

To assist the healthcare professional we forward a number of documents to them, including the following:

1. A copy of the Bloodborne Pathogens Standard.

2. A description of the exposure incident.

3. The exposed employee's relevant medical records.

4. Other pertinent information.

D. HEALTHCARE PROFESSIONALS WRITTEN OPINION:

After the consultation, the healthcare professional provides our facility with a written opinion evaluating the exposed employee's situation. We, in turn, furnish a copy of this opinion to the exposed employee.

In keeping with this process' emphasis on confidentiality, the written opinion will contain only the following information:

1. Whether Hepatitis B Vaccination is indicated for the employee.

2. Whether the employee has received the Hepatitis B Vaccination.

3. Confirmation that the employee has been informed of the results of the evaluation.

4. Confirmation that the employee has been told about any medical conditions resulting from the exposure incident which require further evaluation or treatment.

All other findings or diagnoses will remain confidential and will not be included in the written report.

PAGE C19

E. MEDICAL RECORDKEEPING:

To make sure that we have as much medical information available to the participating healthcare professional as possible, our facility maintains comprehensive medical records on our employees. The Department Supervisors, are responsible for setting up and maintaining these records, which include the following information:

1. Name of the employee.

2. Social security number of the employee.

3. A copy of the employee's Hepatitis Vaccination status.

-Dates of any vaccinations.

-Medical Records relative to the employee's ability to receive vaccination.

4. Copies of the results of the examinations, medical testing and follow-up procedures which took place as a result of an employee's exposure to bloodborne pathogens.

5. A copy of the information provided to the consulting healthcare professional as a result of any exposure to bloodborne pathogens.

As with all information in these areas, we recognize that it is important to keep the information in these medical records confidential. We will not disclose or report this information to anyone without our employee's consent (except as required by law).

PAGE C20

SECTION VI

LABELS AND SIGNS

For our employees one of the most obvious warnings of possible exposure to bloodborne pathogens are biohazard labels. Because of this, we have implemented a comprehensive biohazard warning labeling program in our facility using labels of the type shown on the following page, or when appropriate, using red "color-coded" containers. The Department Supervisors are responsible for setting up and maintaining this program in our facility.

On or before Oct. 1, 1993 the following items in our facility were labeled:

1. Containers of regulated waste.

2. Sharps disposal containers.

3. Containers used to store, transport or ship blood and other infectious materials.

4. Contaminated equipment

5. Laundry containers.

On labels affixed to contaminated equipment we have also indicated which portions of the equipment are contaminated.

We recognize that biohazard signs must be posted at entrances to HIV and HBV research laboratories and production facilities. However, we do not have these types of operations in our facility, so we are not affected by these special signage requirements.

PAGE C21

SECTION VII

INFORMATION AND TRAINING

Having well informed and educated employees is extremely important when attempting to eliminate or minimize our employees' exposure to bloodborne pathogens. Because of this, all employees who have the potential for exposure to bloodborne pathogen are put through a comprehensive training program and furnished with as much information as possible on this issue.

This program was set up so that employees would receive the required training on or before Jan. 30, 1994 . Employees will be retrained at least annually to keep their knowledge current. Additionally, all new employees, as well as employees changing jobs or job functions, will be given any additional training for their new position.

The Department Supervisors are responsible for seeing that all employees who have potential exposure to bloodborne pathogens receive this training.

A. TRAINING TOPICS:

The topics covered in our training program include, but are not limited to, the following:

1. The Bloodborne Pathogens Standard itself.

2. The epidemiology and systems of bloodborne diseases.

3. The modes of transmission of bloodborne pathogens.

4. Our facility's Exposure Control Plan.

5. Appropriate methods for recognizing tasks and other activities that may involve exposure to blood and other potentially infectious materials.

6. A review of the use and limitations of methods that will prevent or reduce exposure, including:

-Engineering controls.

-Work practice controls.

-Personal protective equipment.

7. Selection and use of personal protective equipment including:

-Types available.

-Proper use.

-Location within our facility.

-Removal.

-Handling.

-Decontamination.

-Disposal.

PAGE C22

8. Visual warnings of biohazard within our facility including labels, signs and "color-coded" containers.

9. Information on the Hepatitis B Vaccine, including its:

-Efficacy.

-Safety.

-Method of Administration.

-Benefits of Vaccination.

-Our facility's free vaccination program.

10. Actions to take and persons to contact in an emergency involving blood or other potentially infectious materials.

11. The procedures to follow if an exposure incident occurs, including incident reporting.

12. Information on the post-exposure evaluation and follow-up, including medical consultation, that our facility will provide.

B. TRAINING METHODS:

Our facility's training presentations make use of several training techniques including, but not limited to:

1. Classroom type atmosphere with personal instruction.

2. Videotape programs.

3. Training manuals/employee handouts.

4. Employee review sessions.

Because we feel that employees need an opportunity to ask questions and interact with their instructors, time is specifically allotted for these activities in each training session.

C. RECORD KEEPING:

To facilitate the training of our employees, as well as to document the training process, we maintain training records containing the following information:

1. Dates of all training sessions.

2. Contents/summary of the training sessions.

3. Names and qualifications of the instructors.

4. Names and job titles of employees attending the training sessions.

We have used the forms on the following pages and/or our computer systems to facilitate this recordkeeping.

These training records are available for examination and copying to our employees and their representatives, as well as OSHA and its representatives.

PAGE C23

EMPLOYEES ELIGIBLE FOR HEPATITIS B VACCINATION

ACCEPTED

EMPLOYEE DEPARTMENT DECLINED/ RECEIVED SUPERVISOR

TEST 1

1. What is a work practice control?

2. List 3 ways that you, as an employee can be exposed to Bloodborne Pathogens?

1.

2.

3.

3. List 5 different modes of transmission for Bloodborne Pathogens?

1.

2.

3.

4.

5.

4. What are engineering controls?

5. If you are directly exposed to bloodborne pathogens what steps are taken?

6. List 5 types of personal protective equipment?

1.

2.

3.

4.

5.

7. How often should training for bloodborne occur?

8. What does the term "universal precaution" mean?

9. List 2 methods of compliance to eliminate or minimize exposure to bloodborne pathogens?

1.

2.

CHOOSE 1 OF THE FOLLOWING QUESTIONS THAT WOULD BEST FIT YOUR DEPARTMENT SITUATION.

1. WHAT SHOULD YOU DO IF AFTER AN ARREST IS MADE THERE IS BLOOD ON THE CAR AND/OR IN THE VEHICLE?

2. IN THE CITY OFFICE A PERSON COMES IN, HAS A BLOODY NOSE ALL OVER RECEIPTS ON THE COUNTER AND YOU, WHAT WOULD BE THE PROPER

PROCEDURE TO CLEAN THE MESS?

3. THE CITY CREW IS PLOWING THE ROAD AND RUN OVER TWO DEAF PEOPLE CAUSING BLOOD TO BE SPLATTERED ON THE MACHINERY AND THEMSELVES WHAT SHOULD THEY DO?