Exposure Control Plan for Occupational Exposure to Bloodborne Pathogens and Airborne Pathogens/Tuberculosis

INTRODUCTION

The State Board of the Technical College System of Georgia (SBTCSG), along with its technical colleges and work units, is committed to providing a safe and healthful environment for its employees, students, volunteers, visitors, vendors and contractors. SBTCSG Policy 3.4.1. Emergency Preparedness, Health, Safety and Security compels technical colleges and work units to eliminate or minimize exposure to bloodborne and airborne pathogens in accordance with OSHA Standard 29 CFR 1910.1030, “Occupational Exposure to Bloodborne Pathogens” as well as Centers for Disease Control (CDC) “Guidelines for Preventing the Transmission of Mycobacterium tuberculosis in Health-Care Facilities, 2005.” In pursuit of this goal, the Exposure Control Plan (ECP) is maintained, reviewed, exercised and updated at least annually to ensure compliance and protection for employees and students.

This Exposure Control Plan includes:

clarification of program administration
determination of employee and student exposure
implementation of various methods of exposure control

standard precautions
engineering and administrative controls
personal protective equipment (PPE)
housekeeping
laundry
labeling

vaccination for hepatitis B
evaluation and follow-up following exposure to bloodborne/airborne pathogens (tuberculosis)
evaluation of circumstances surrounding exposure incidents
communication of hazards and training and

recordkeeping

I. PROGRAM ADMINISTRATION

Allison Patnode serves as the Exposure Control Coordinator (ECC) and is responsible for the implementation, maintenance, review, and updating of the Exposure Control Plan (ECP).The ECC will be responsible for ensuring that all required medical actions are performed and that appropriate health records are maintained.Further, the ECC will be responsible for training, documentation of training as well as making the written ECP available to employees, students, and any compliance representatives.
Contact Information for Exposure Control Coordinator

Allison Patnode (apatnode@gntc.edu)

Office Phone - 706-295-6881

Mobile Phone – 706-639-7677
Those employees and students who are determined to be at risk for occupational exposure to blood, other potentially infectious materials (OPIM) as well as at risk for exposure to airborne pathogens/tuberculosis must comply with the procedures and work practices outlined in this ECP.
Georgia Northwestern Technical College is responsible for the implementation, documentation, review, and training/record keeping of standard precautions with respect to the areas of personal protective equipment (PPE), decontamination, engineering controls (e.g., sharps containers), administrative controls, housekeeping, laundry, and labeling and containers as required as assigned to designees.Further, adequate supplies of the aforementioned equipment will be available in the appropriate sizes/fit.
Contact Information for Responsible Person(s) or Department(s) as well as a list of job and/or student program classifications which have potential for occupational exposure, please see Appendix A.
GNTC contracts with Stericycle to remove “Sharps” utilized in training for all listed programs under “C” above. The contract for this service is kept in Administrative Services office on Floyd County Campus.
Georgia Northwestern Technical College (GNTC) engages in the following training, drills, and exercises regarding exposure control: Training, drills, and exercises are provided to academic programs and employee groups that have potential for occupational exposure.These activities consist of annually viewing training videos under the supervision of an individual licensed or credentialed in a healthcare profession and annual retraining in the methods used to reduce exposure when Bloodborne or airborne pathogens are present. Such activities include the use of Engineering controls, PPE, and proper hand washing techniques. Those employees not in category I or II will be encouraged, but not required, to view an online presentation on Bloodborne Pathogens and Airborne Pathogens. Each Program/Work Area is responsible for maintain and sharing these records with Human Resources and or the Exposure Control Officer. Appendix B at the end of this documents lists the planned training for all affected areas.
The protocol for annual review of the GNTC ECP is that the ECC prepares the annual Exposure Control Plan in accordance with guidance from the TCSG representative for Exposure Control and submits it for approval prior to dissemination to all affected Academic Programs and employee areas within the college. If needed updated information will be provided in a timely fashion to all affected areas within the college should new information become available.

II. EXPOSURE DETERMINATION

Employees/or students are identified as having occupational exposure to bloodborne/airborne pathogens based on the tasks or activities in which they engage. These tasks or activities are placed into categories as defined by the 1987 joint advisory notice by the U.S. Department of Labor and the U.S. Department of Health and Human Services. The relative risk posed by these tasks or activities, as well as the measures taken to reduce or eliminate risk of occupational exposure are also determined by the category.

Category I: A task or activity in which direct contact or exposure to blood, other potentially infectious materials, or airborne pathogens (tuberculosis) is expected and to which standard precautions apply.

Category II: A task or activity performed without exposure to blood or other potentially infectious materials, or airborne pathogens (tuberculosis) and to which standard precautions apply, but exposure to another person’s blood or to OPIM might occur as an abnormal event or an emergency or may be required to perform unplanned Category I tasks or activities.

Category III: A task or activity that does not entail normal or abnormal exposure to blood or other potentially infectious materials, or airborne pathogens (tuberculosis) and to which standard precautions do not apply.

Employees or students who engage in tasks or activities which are designated as Category I or II, as well as their occupational area, are considered to be “covered” by the parameters of the ECP, including part-time, temporary, contract and per-diem employees.

The following is a list of job and/or student program classifications which have Category I or II occupational exposure. Included is a list of the tasks or activities or groups of closely related tasks or activities in which occupational exposure may occur for these individuals.

Job/Program Title	Occupational/Program Area	Task/Activity
Early Childhood Care & Education	Public Service	Category II
Criminal Justice and POST Training	Public Service	Category II
Maintenance/Custodial	Facilities Department	Category II
Campus Police	Facilities Department	Category II
Associate Degree Nursing	Nursing & Health Sciences	Category I
Central Sterile Processing	Health Sciences Division	Category I
Certified Nurse Assistant	Nursing & Health Sciences	Category I
Dental Assisting	Health Sciences Division	Category I
EMT/Paramedic Technology	Health Sciences Division	Category I
Medical Assistant	Health Sciences Division	Category I
Patient Care Assistant	Health Sciences Division	Category I
Phlebotomy Technician	Health Sciences Division	Category I
Practical Nursing	Nursing & Health Sciences	Category I
Radiologic Technology	Health Sciences Division	Category I
Surgical Technology	Health Sciences Division	Category I
Ultrasound Programs	Health Sciences Division	Category I

III. IMPLEMENTATION OF METHODS OF EXPOSURE CONTROL

Standard Precautions: All covered employees and covered students will use standard precautions as indicated by the task or activity.
Exposure Control Plan:

All covered employees and covered students will receive an explanation of this ECP during their initial training or academic experience, as well as a review on an annual basis. All covered employees and covered students can review this ECP at any time while performing these tasks or activities by contacting Allison Patnode. If requested, a hard copy of this ECP will be provided free of charge within 3 business days of request.
The ECC will review and update the ECP annually, or more frequently if necessary to reflect any new or modified tasks or activities that affect occupational exposure and to reflect new or revised employee classifications or instructional programs with potential for occupational

IV. PERSONAL PROTECTIVE EQUIPMENT

Follow standard precautions with regard to personal protective equipment for identified Category I and II tasks. The individuals identified in I. C. are responsible for implementing and documenting the following:

Appropriate personal protective equipment (PPE) is provided to covered employees at no cost and available to covered students at the student’s expense. Training/recording keeping in the use of PPE for specific tasks is provided by those individuals designated in Appendix A.
All covered employees and covered students 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 designated biohazard trash containers.
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.
Utility gloves may be decontaminated for reuse if their integrity is not compromised. Utility gloves should be discarded 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, spatters, 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.

C.The protocol for handling used PPE is as follows: All contaminated PPE collected from biohazard trash containers will be stored in designated areas to be picked up as needed by a contracted disposal service.

V. DECOMTAMINATION

Follow standard precautions with regard to decontamination for identified Category I and II tasks. The individuals identified in I. C. are responsible for implementing and documenting the following:

Individuals listed in Appendix A are responsible for training/record keeping for decontamination.
For each category I and II task document the decontamination method required.

VI. Engineering and Administrative Controls:

Follow standard precautions with regard to engineering and administrative controls for identified Category I and II tasks. The individuals identified in I. C. are responsible for implementing and documenting the following:

Specific engineering and administrative controls for specified tasks or activities are developed and implemented to reduce or eliminate occupational exposure by relevant programs as listed in Appendix A.
Protocol and documentation of the inspection, maintenance and replacement of sharps disposal containers is determined and documented by each program as listed in Appendix A.
The processes for assessing the need for revising engineering and administrative controls, procedures, or products, and the individuals/groups involved include but is not limited to programmatic advisory committee groups, ECP committee, Academic Leadership Team, and included college departments.

VII. HOUSEKEEPING

Follow standard precautions with regard to housekeeping for identified Category I and II tasks. The individuals identified in I. C. are responsible for implementing and documenting the following:

Regulated waste is placed in containers which are closable, constructed to contain all contents and prevent leakage, appropriately labeled or color-coded, and closed prior to removal to prevent spillage or protrusion of contents during handling.
The protocol for handling sharps disposal containers is that they will be stored in designated areas to be picked up on an as needed basis with a contracted disposal service.
The protocol for handling other regulated waste is that it will be stored in designated areas to be picked up on an as needed basis with a contracted disposal service.
Contaminated sharps are discarded immediately or as soon as possible in containers that are closable, puncture-resistant, leak proof on sides and bottoms, and appropriately labeled or color-coded. Sharps disposal containers are available at must be easily accessible and as close as feasible to the immediate area where sharps are used.
Bins and pails (e.g., wash or emesis basins) are cleaned and decontaminated as soon as feasible after visible contamination.
Broken glassware that may be contaminated is only picked up using mechanical means, such as a brush and dustpan.

VIII. LAUNDRY

Follow standard precautions with regard to laundry for identified Category I and II tasks. The individuals identified in I. C. are responsible for implementing and documenting the following:

Contaminated articles will be laundered or sent for laundering on an as needed basis as designated by each program director or college department included in the ECP.
The following laundering requirements must be met (document procedures):

Handle contaminated laundry as little as possible, with minimal agitation.
Place wet contaminated laundry in leak-proof, labeled or color-coded containers before transport. Use either red bags or bags marked with the biohazard symbol for this purpose.
Wear the following PPE when handling and/or sorting contaminated laundry as recommended following standard precautions.

IX. LABELING AND CONTAINERS

Follow standard precautions with regard to labeling and containers for identified Category I and II tasks. The individuals identified in I. C. are responsible for implementing and documenting the following:

The following labeling methods are used in this facility:
Equipment to be Labeled Label Type (size, color)

specimens, contaminated laundry, red bag, biohazard label

Sharps Containers
The persons listed in Appendix A are responsible for ensuring that warning labels are affixed or red bags are used as required if regulated waste or contaminated equipment is brought into or out of the facility. Employees and students are to notify their instructor or supervisor if they discover regulated waste containers, refrigerators containing blood or OPIM, contaminated equipment, etc. without proper labels. The supervisor should work with the Exposure Control Coordinator to take corrective action.

X.VACCINATION FOR HEPATITIS B

Allison Patnode will ensure training is provided to covered employees on hepatitis B vaccinations, addressing safety, benefits, efficacy, methods of administration, and availability. All program directors listed in Appendix A will ensure that the same content training is provided to covered students.
The hepatitis B vaccination series is available at no cost after initial covered employee training and within 10 days of initial assignment to all covered employees identified in the exposure determination section of this plan. The hepatitis B vaccination series is available to covered students at cost after initial covered student training and within 10 days of initial assignment to all covered students identified in the exposure determination section of this plan.
Vaccination may be precluded in the following circumstances: 1) documentation exists that the covered employee or covered student has previously received the series; 2) antibody testing reveals that the employee is immune; 3) medical evaluation shows that vaccination is contraindicated; or (4) following the medical evaluation, a copy of the health care professional’s written opinion will be obtained and provided to the covered employee or student within 15 days of the completion of the evaluation. It will be limited to whether the covered employee or covered student requires the hepatitis B vaccine and whether the vaccine was administered.
However, if a covered employee or covered student declines the vaccination, the covered employee or covered student must sign a declination form. Covered employees or covered students who decline may request and obtain the vaccination at a later date at no cost to covered employees or at cost to covered students. Documentation of refusal of the vaccination is kept in the medical records of the individual.
Vaccination will be provided by specified local county health departments, clinics, or medical offices as determined by the Human Resources Department for employees and by the medical provider chose by them for students.

XI. POST-EXPOSURE FOLLOW-UP

Should an exposure incident occur, contact Allison Patnode at 706-378-1754
An immediate available confidential medical evaluation and follow-up will be conducted and documented by a licensed health care professional. Following initial first aid (clean the wound, flush eyes or other mucous membrane, etc.), the following activities will be performed:

Document the routes 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).
For blood or OPIM exposure:

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/student’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.
Exposure involving a known HIV positive source should be considered a medical emergency and post-exposure prophylaxis (PEP) should be initiated within 2 hours of exposure, per CDC recommendations.
Assure that the exposed employee/student is provided with the source individual’s test results and with information about 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/student’s blood as soon as feasible after exposure incident, and test blood for HBV and HIV serological status.
If the employee/student 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 waiting period, perform testing as soon as feasible.

4. For airborne pathogen (tuberculosis):

Immediately after the exposure of a covered employee or covered student, the responsible supervisor, the technical college or work unit Exposure Control Coordinator (ECC) and the authorized contact person at the clinical or work site shall be notified and should receive documentation in writing. Documentation of the incident is to be prepared the day of the exposure; on an Exposure Incident Report and Follow-Up Form for Exposure to Bloodborne/Airborne Pathogens (Tuberculosis); promulgated within 24 hours of the incident; and recorded in the Exposure Log.
The exposed covered employee/student is to be counseled immediately after the incident and referred to his or her family physician or health department to begin follow-up and appropriate therapy. Baseline testing should be performed as soon as possible after the incident. The technical college or work unit is responsible for the cost of a post-exposure follow-up for both covered employees and covered students.
Any covered employee or covered student with a positive tuberculin skin test upon repeat testing, or post-exposure should be clinically evaluated for active tuberculosis. If active tuberculosis is diagnosed, appropriate therapy should be initiated according to CDC Guidelines or established medical protocol.

XII. ADMINISTRATION OF POST-EXPOSURE EVALUATION AND FOLLOW-UP

A. Allison Patnode ensures that those individuals designated in Appendix A responsible for the covered employee or student hepatitis B vaccination and post-exposure

B. The individuals designated in Appendix A will ensure that the health care professional evaluating a covered employee or student after an exposure incident receives the following:

a description of the covered employee’s or covered student’s tasks or activities relevant to the exposure incident
route(s) of exposure
circumstances of exposure
if possible, results of the source individual’s blood test
relevant covered employee or covered student medical records, including vaccination status

C. During the period of the 2019-2020 HCCP the following incidents surrounding exposure control occurred: Sharps injuries_5_; Other exposure to Bloodborne Pathogens _1___; Airborne Pathogen exposure _4 TB___.

XIII. PROCEDURES FOR EVALUATING THE CIRCUMSTANCES SURROUNDING AN EXPOSURE INCIDENT

A. The individuals designated in Appendix A will review the circumstances of all exposure incidents to determine:

engineering controls in use at the time
administrative practices followed
a description of the device being used (including type and brand)
protective equipment or clothing that was used at the time of the exposure incident (gloves, eye shields, etc.)
location of the incident (O.R., E.R., patient room, etc.)
procedure being performed when the incident occurred
training records of covered employee or student

B. The individuals designated in Appendix A will submit documentation to the Exposure Control Coordinator to record all percutaneous injuries from contaminated sharps in a Sharps Injury Log.

C. If revisions to this ECP are necessary, the Exposure Control Coordinator will ensure that appropriate changes are made. (Changes may include an evaluation of safer devices, adding individuals/occupational areas to the exposure determination list, etc.).

XIV. COMMUNICATION OF HAZARDS AND TRAINING

A. All covered employees and covered students 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:

a copy and explanation of OSHA’s bloodborne pathogen standard
a copy and explanation of the ECP;
an explanation of the 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;
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 to covered employees and at cost to covered students;
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/college is required to provide for the covered employee or covered student following an exposure incident;
an explanation of the signs and labels and/or color coding required by the standard and used at this facility;
and an opportunity for interactive questions and answers with the person conducting the training session.

B. Training materials are available from the Exposure Control Coordinator or their designee.

XV. RECORDKEEPING

A. Training Records

Training records are completed for each covered employee and covered student upon completion of training. These documents will be kept for at least three years in an ECP folder located in Human Resources for all employees and in designated folders in student files for program applicable student records maintained by respective program directors.
The training records include:
1. the dates of the training sessions
2. the contents or a summary of the training sessions
3. the names and qualifications of persons conducting the training
4. the names and job titles/department of all persons attending the training sessions
Training records are provided upon request to the covered employee or covered student or the authorized representative of the employee or student within 15 working days. Such requests should be addressed to the Exposure Control Coordinator, Allison Patnode.

B. Medical Records

Medical records are maintained for each covered employee or covered student in accordance with 29 CFR 1910.1020, “Access to Employee Exposure and Medical Records.”
Human Resources is responsible for maintenance of the required medical records. These confidential records are kept in the department of Human Resources at respective campuses for at least the duration of employment or attendance plus 30 years. Student medical records will be maintained by the respective program directors in the programs attended by said students for at least the duration of three years.
Covered employee or covered student medical records are provided upon request of the employee or student or to anyone having written consent of the employee or student within 3 working days. Student requests should be sent to the respective program director. Employee requests should be sent to Human Resources.

C. 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 the Exposure Control Coordinator, Allison Patnode.

D. 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 the injury; Type and brand of the device involved (syringe, suture needle); Department or work area where the incident occurred explanation of how the incident occurred.
The Sharps Injury 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 redacted from the report. The sharps injury reports are to be reviewed annually by program directors specified in Appendix A.

Appendix A

Job/Program Title	Task/Activity	Responsible Person	Contact Info
Early Childhood Care & Education	Category II	Laverne Pruitt	706-764-3848
Criminal Justice	Category II	Tyler Gayan	706-378-1706
POST Training	Category II	Jim Pledger	706-378-1735
Maintenance/Custodial	Category II	Jeff Agan	706-295-6974
Campus Police	Category II	Chad Cardin	706-295-6552
Associate Degree Nursing	Category I	Brooke Askew	706-764-3532
Practical Nursing/Patient Care Assisting/Certified Nurse Assistant	Category I	Brooke Askew	706-295-6968
Dental Assisting	Category I	Allison Patnode	706-378-1754
EMT/Paramedic Technology	Category I	Nina Piatt	706-295-6886
Medical Assistant	Category I	Jennifer Stephenson	706-295-6479
Phlebotomy Technician	Category I	Allison Patnode	706-378-1754
Radiologic Technology/Mammography	Category I	Susan Wheat	706-295-6955
Respiratory Care	Category I	Zenia Bratton	706-295-6910
Surgical Technology/Central Sterile Processing	Category I	Michael Barrett	706-764-3721
Ultrasound Programs	Category I	Nina Madden	706-295-5860

APPENDIX B
EXPOSURE CONTROL PLAN TRAINING LIST

Program/Work Area	Trainer	Date	Training Topic
Early Childhood Care & Education	Laverne Pruitt	Fall and Spring Semester - ECCE 1105	OSHA’s Blood borne Pathogens Standard Protecting yourself from Aids and Hepatitis; CPR and First Aid Training
Criminal Justice	Tyler Gayan Tony Adams	CRJU 1062 or CRJU 1072 (offered alternately each Fall semester). FOSC 2010 – Fall semester FOSC 2011 – Spring semester	Blood Borne and Airborne Pathogens
POST Training	James Pledger	Summer Semester, LETA 1010	Blood Borne Pathogens Standards. Hepatitis and Aids; CPR and 1st Aid
Maintenance/Custodial	Jeff Agan	Fall Semester	Blood Borne Pathogens -Hazard Communication Standard
Security	Chad Cardin	Fall Semester	Blood Borne Pathogens -Hazard Communication Standard
Associate Degree Nursing	Lauren Elsberry	Fall Semester RNSG 1112 Nursing Fundamentals	Blood Borne and Airborne Pathogens Medical Asepsis and Infection Control
Practical Nursing/CNA	Nicole Sheridan	Spring/Fall every year – PNSG 2030 Nursing Fundamentals	Medical Asepsis and Infection Control
Dental Assisting	Allison Patnode - GCC	First Semester of program DENA 1050	Blood Borne Pathogens -Hazard Communication Standard
EMT/Paramedic	Nina Piatt EMT/Paramedic	First Semester of Each Program (EMSP 1110 –EMT EMSP 2110 - Paramedic)	Blood Borne and Airborne Pathogens
Medical Assisting	Jennifer Stephenson	Every Fall Semester in MAST 1080	Blood borne and Airborne Pathogens
Phlebotomy Technician	Allison Patnode	PHLT 1030 Fall and Spring Semester	Blood Borne and Airborne Pathogens
Radiologic Technology	Susan Wheat	Every Fall Semester in RADT 1010	Blood borne and Airborne Pathogens
Respiratory Care	Zenia Bratton	Summer Semester; RESP 1120	Blood Borne and Airborne Pathogens
Surgical Technology Central Sterile Processing	Michael Barrett	Each Spring SURG 1010	Blood Borne and Airborne Pathogens
Ultrasound Programs	Nina Madden	Each Fall	Blood Borne and Airborne Pathogens

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