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Welcome to the BWC sample policy template page! After downloading this sample, please remove the language on this page. Replace the Ohio Bureau of Workers’ Compensation (BWC) logo with your company logo and implement an effective date with management approval signature. This is a general guidance document to help your organization develop a written safety policy. Some items in this guide will not apply to your workplace. Please reference any applicable standard(s) to ensure you meet all requirements. For added convenience there is a document at the end of this template with resource links. This sample written program has example language, but you must change it so that it is site-specific and meets expectations of your organization. Delete the DSH Helper Comments after creating your policy. For ease of use, every sample provided by BWC follows this format: A. Program Administration B. Program Specific Elements C. Information and Training D. Program Evaluation and Updates Attachments How to use this template: 1) Save this template and name it for your own reference. 2) Make this template specific to your organization by changing all text in red throughout the template. 3) Review with all persons involved with safety and compliance in your organization. 4) Edit the document to add, remove, or adjust language to ensure it is specific to your organization. 5) Review again with all persons involved with safety and compliance in your organization. 6) Finalize the document. 7) Prepare training based on your new or updated policy content. 8) Conduct and document training (general and specific) as required by standard and policy. SUBJECT: Bloodborne Pathogen Policy Template PAGE OF . SUPERSEDES: EFFECTIVE DATE: 1-7-2021 SAMPLE APPROVED BY:

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Page 1: SUBJECT:PAGE OF · Web viewThe Standard covers part-time, temporary, contract and per diem employees. Describe how you meet the provisions of the standard for these employees in your

Welcome to the BWC sample policy template page! After downloading this sample, please remove the language on this page. Replace the Ohio Bureau of Workers’ Compensation (BWC) logo with your company logo and implement an effective date with management approval signature.

This is a general guidance document to help your organization develop a written safety policy. Some items in this guide will not apply to your workplace. Please reference any applicable standard(s) to ensure you meet all requirements. For added convenience there is a document at the end of this template with resource links. This sample written program has example language, but you must change it so that it is site-specific and meets expectations of your organization. Delete the DSH Helper Comments after creating your policy.

For ease of use, every sample provided by BWC follows this format: A. Program Administration B. Program Specific Elements C. Information and Training D. Program Evaluation and Updates Attachments How to use this template:1) Save this template and name it for your own reference. 2) Make this template specific to your organization by changing all text in red throughout the template. 3) Review with all persons involved with safety and compliance in your organization. 4) Edit the document to add, remove, or adjust language to ensure it is specific to your organization.5) Review again with all persons involved with safety and compliance in your organization.6) Finalize the document.7) Prepare training based on your new or updated policy content.8) Conduct and document training (general and specific) as required by standard and policy.9) Schedule and document policy reviews and updates (if any).10) Retrain when there are any changes within the organization, updates to policy, deficiencies, or

employee needs.

For further assistance with development of this and other policies and programs, please contact your local Safety Consultant, or call 1-800-644-6292. Your workers’ compensation policy includes a wide range of services for all industries including Safety Consultations, Safety Education & Training, and the BWC Safety & Video Library at no additional cost.

The Ohio Bureau of Workers’ Compensation (BWC) provides this document to assist you in your risk reduction efforts. This document may not address all the actions necessary to ensure compliance with federal, state or local laws, regulations, codes, and standards. Use of the information in this document does not guarantee you have satisfied all legal obligations.

BWC does not make any representation or warranty, express or implied, that your workplace is safe, free of occupational hazards or in compliance with all applicable laws, regulations, codes, or standards. BWC encourages you to conduct periodic workplace inspections and review written programs regularly.  BWC does not endorse any specific companies or products mentioned for illustrative purposes in the document.

SUBJECT:Bloodborne PathogenPolicy Template

PAGE OF .

SUPERSEDES:

EFFECTIVE DATE:1-7-2021

SAMPLE APPROVED BY:

Page 2: SUBJECT:PAGE OF · Web viewThe Standard covers part-time, temporary, contract and per diem employees. Describe how you meet the provisions of the standard for these employees in your

Bloodborne Pathogen Program

PURPOSE – 1910.1030

This is Employer Name Exposure Control Plan to reduce workplace exposure to bloodborne pathogens. This program explains how we use a combination of engineering and work practice controls, personal protective clothing and equipment, training, medical surveillance, Hepatitis B vaccinations, signs, labels, and other methods. We use the Occupational Safety and Health Administration (OSHA) Bloodborne Pathogens standard to develop this Exposure Control Plan.

SCOPE – 1910.1030(a) *Attachment A

This policy applies to employees who are likely to contact blood or other potentially infectious materials (OPIM) while at work. Attachment A contains definitions of terms used in the document. This policy supplies guidance and understanding in the following:

A. Program AdministrationB. Program Specific Elements

1. Employee Exposure Determination2. Methods of Compliance3. Hepatitis B Vaccination4. Exposure Incidents5. Medical records

C. Information and TrainingD. Program Evaluation & Updates Attachments

A. PROGRAM ADMINISTRATION & RESPONSIBILITIES

1. Job Title (e.g. Safety Director/HR Manager) manages the Exposure Control Plan for Employer Name by:

a. Naming all potentially exposed employees.b. Determining and ensuring implementation of universal precautions, engineering

controls, personal protective equipment, and housekeeping.c. Developing and documenting training. d. Evaluating post exposure response for compliance. e. Implementing corrective actions when needed. f. Evaluating/reviewing the program annually.g. Maintaining medical records.

2. Supervisors help Job Title with identifying exposure, maintaining supplies, ensuring performance of housekeeping, and evaluating post exposure response, and implementing corrective actions when needed. Supervisors maintain program specifics in their work areas and ensure employees follow the program and the training they receive.

3. Safety Team helps Job Title with the yearly program evaluation and training.

DSH Assistant, 06/30/20,
Aside from healthcare workers, this policy may cover employees expected to give basic first aid, custodial staff, teachers, coaches, and others.
DSH Assistant, 06/30/20,
Responsibilities under this program may include; safety personnel, maintenance personnel, managers, supervisors, human resources personnel, employees, safety teams, and contractors/visitors or others.
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4. Employees determined to have occupational exposure to blood or OPIM must comply with procedures and work practices outlined in this exposure control plan.

B. PROGRAM SPECIFIC ELEMENTS 1910.1030(c)-(f) *Attachment B

1. Employee Exposure Determination 1910.1030(c)(2)

The Job Title performed a first evaluation of occupational exposures at Employer Name. The Job Title reviews this evaluation yearly and when a change in process or procedure occurs. To see job titles and tasks with exposure, see Attachment B.

2. Methods of Compliance 1910.1030(d)

Employees observe universal precautions to prevent contact with blood or OPIM. Employees treat all human blood or OPIM as if known to be infectious for Human Immunodeficiency Virus (HIV), Hepatitis B Virus (HBV), and other bloodborne pathogens.

a. Engineering and Work Practice Controls 1910.1030(d)(2)

All employees follow engineering and work practice controls to eliminate or minimize exposure to employees at this facility.

Example: Place sharps in designated containers in the first aid room.Example: Use tongs or brooms and dustpans to pick up contaminated sharp objects like broken glass.Example: Apply absorbent compound to any bodily fluid before cleaning it up.

Employees place all waste, sharps, and other contaminated items in a bag or container that has a biohazard label or is red in color. Labels are orange or orange-red and have the biohazard symbol and the word BIOHAZARD clearly printed on them. Wherever this policy says, “labeled or color-coded,” it means labeled with biohazard labels or made of a material that is red. Job Title is responsible for examining and maintaining or replacing the engineering controls on a time period (e.g. weekly, monthly) basis to ensure their effectiveness.

b. Personal Protective Equipment (PPE) 1910.1030(d)(3)

Employer Name supplies PPE to employees who have occupational exposure. Job Title inventories PPE supplies weekly to assure availability. PPE is stored (location). Employees using PPE follow these rules:

i. Wash hands at once or as soon as possible after removing gloves/PPE (1910.1030(d)(2)(v).

DSH Assistant, 06/30/20,
If you have any, list specific work practices, special tools to use, and techniques that you will use to reduce the amount of blood produced during procedures, the amount of spattering during procedures, etc.
DSH Assistant, 06/30/20,
Engineering controls are things that isolate or remove hazards. In the case of BBP, this includes sharps containers, absorbent compounds, and specially designed needles that prevent unintentional contact.
DSH Assistant, 08/07/20,
See 1910.1030(b) - definition of "Bloodborne Pathogens"
DSH Assistant, 06/30/20,
The Standard covers part-time, temporary, contract and per diem employees. Describe how you meet the provisions of the standard for these employees in your ECP.
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ii. Remove PPE after it becomes contaminated and before leaving the work area.iii. Place used PPE in biohazard bags and then in regular trash if under 50 lb. per

month.iv. Wear correct gloves when there may be hand contact with blood or OPIM, when

touching contaminated items or surfaces; replace gloves if torn, punctured or contaminated.

v. Never wash or decontaminate disposable gloves for reuse. vi. Wear proper face and eye protection when splashes, sprays, spatters, or droplets

of blood or OPIM pose a hazard to the eye, nose, or mouth.vii. Remove at once or as soon as feasible any garment contaminated by blood or

OPIM, while avoiding contact with the outer surface.

All employees wear the PPE in Attachment B while performing listed job tasks.

c. Housekeeping 1910.1030(d)(4) *Attachment C

Job Title cleans and decontaminates this facility according to the schedule in Attachment C. Job Title cleans and decontaminates all first aid equipment and contaminated work surfaces, including trash cans, at the completion of first aid or as soon as possible. Job Title examines and decontaminates all equipment or parts that have or may have become contaminated with blood or OPIM.

i. Regulated Waste Disposal 1910.1030(d)(4)(iii)

Employees place regulated waste in containers that are closable, constructed to hold all contents and prevent leakage, appropriately labeled or color-coded, and closed prior to removal to prevent spillage or protrusion of contents during handling. Job Title disposes of all wastes following guidelines from the Ohio EPA and the local health authority.

ii. Contaminated Sharps 1910.1030(d)(2)(viii) *Attachment A

Employees place contaminated sharps at once or as soon as possible in containers that are closable, puncture-resistant, leak proof on sides and bottoms, and appropriately labeled or color-coded. Employees only pick up these sharps using mechanical means, such as a brush and dustpan. See definition of contaminated sharps in Attachment A.

iii. Needles & Other Medical Sharps

Employees avoid contact with needles and other medical sharps during use, cleanup, and disposal to prevent accidental cuts and punctures.

o Employees do not bend, recap, remove, shear, purposely break, or touch with the hands any contaminated needles or other contaminated sharps.

o Sharps containers must be puncture resistant, leakproof on the sides and bottom, and labeled or color-coded.

DSH Assistant, 06/30/20,
Include this section if you are an employer who supplies medical treatment or testing on site. Remove this section if you do not perform medical procedures beyond first aid at your facility.Medical sharps include scalpels, lancets, angiocaths, etc.
DSH Assistant, 06/30/20,
“Sharps” may include metal parts, nails, broken glass, needles found during housekeeping or maintenance, or anything else that could puncture the skin of an employee. Consider the sharp object a “contaminated sharp” when blood of one person is on it and handle accordingly.
DSH Assistant, 08/07/20,
Based on your work activities, schedules may not be required unless there has been an incident involving blood or OPIM causing contamination. Hazard assessments will aid in determining the need for scheduled cleanings.
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o Immediately or as soon as possible, place contaminated needles or other disposable contaminated sharps in the SHARPS container in the first aid room for disposal.

o Sharps disposal containers are available at location (must be easily accessible and as close as possible to the immediate area).

o Employees decontaminate reusable medical sharps (like tweezers) before placing them back in service.

iv. Laundry – 1910.1030(d)(4)(iv)

Employees handle laundry contaminated with blood or OPIM as little as possible. Employees place contaminated laundry in labeled or color-coded bags. These bags are in the first aid room.

v. Work Area Restrictions

There is a possibility of exposure to blood or OPIM in the first aid room. Employees do not eat, drink, apply cosmetics or lip balm, smoke, or handle contact lenses in this area. Employees do not keep food and beverages on shelves, cabinets, or counter tops in this area.

3. Hepatitis B Vaccination - 1910.1030(f) *Attachments B and D

Job Title provides training to employees on hepatitis B vaccinations. Offer the hepatitis B vaccination series to employees listed in Attachment B at no cost and within 10 days of initial assignment. Encourage vaccination unless: 1) records show that the employee has previously received the series, 2) antibody testing reveals that the employee is immune, or 3) medical evaluation shows that vaccination is contraindicated.

If an employee chooses not to receive the vaccination, the employee must sign a declination form Attachment D. Employees may choose to receive it later at no cost. (Health care Professional who handles this part of the plan) supplies the vaccination at (location).

4. Exposure Incidents *Attachments E and F

a. If there is an exposure incident, contact Job Title.b. Perform initial first aid, such as cleaning the wound, flushing eyes or other mucous

membranes, etc. The supervisor immediately sends the exposed employee for a confidential medical evaluation and follow-up by (Licensed health care professional) following the steps in Attachment F.

c. Job Title gives the health-care professional(s) responsible for employee's hepatitis B vaccination and post-exposure evaluation and follow-up a copy of OSHA's bloodborne pathogens standard.

d. Job Title ensures that the health-care professional evaluating an employee after an exposure incident receives:

DSH Assistant, 08/07/20,
Consider this a function of human resources.
DSH Assistant, 06/30/20,
Include this section if you are an employer who has a designated first aid or procedure room. Remove this section if there is no such designated area.
DSH Assistant, 06/30/20,
If you use an outside laundry service, make sure your contract with them states that they use universal precautions, and that they are aware of the possibility of blood in your laundry and the meaning of your labeled or color-coded bags.
DSH Assistant, 06/30/20,
Include this section if you are an employer who uses linens, such as nursing homes or salons. Omit this section if no linens or laundering takes place at your facility.
Harden, Erik, 12/14/20,
Not sure how this got all mashed together.
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i. A description of the employee's job duties relevant to the exposure incident.ii. Route(s) of exposure.

iii. Circumstances of exposure.iv. If possible, results of the source individual's blood test.v. Relevant employee medical records, including vaccination status.

e. The exposed employee and the Job Title complete the exposure incident report in Attachment E.

f. Job Title provides the employee with a copy of the evaluating health-care professional's written opinion within 15 days after completion of the evaluation.

g. The Job Title assesses every exposure incident for:i. Proper reporting of the exposure incident.

ii. Effectiveness of work practices.iii. Effectiveness, availability, and use of engineering controls, and PPE.iv. effectiveness and use of housekeeping and decontamination protocols; andv. Use of post exposure protocols.

h. During this assessment, the Job Title, and the Safety Team look for opportunities for improvement to this Exposure Control Plan. The regular program reviews will include these opportunities for improvement.

5. Medical Records *Attachment G

a. Job Title maintains medical records confidentially in accordance with 1910.1020 for at least the length of employment plus 30 years. Job Title provides medical records within 15 working days to any employee requesting his/her medical records.

b. OSHA and Public Employer Risk Reduction Program (PERRP) Recordkeeping.Job Title evaluates each exposure incident to determine if the case meets OSHA's Recordkeeping Requirements 1904 If so, record the incident on the OSHA injury/illness log.

c. Employers must complete the “Sharps Injury Form Needlestick Report SH-12” (see appendix G) when a contaminated needle or sharp injures an employee. Employers must maintain these records and produce them when required.

C. INFORMATION & TRAINING – 1910.1030(g)(2)

1. Training Frequency – 1910.1030(g)(2)(ii)

Employees with occupational exposure to blood or OPIM receive training:a. At the time of first assignment.b. Within 365 days of last training.c. If procedures change; and/ord. if there is a deficiency in performance.

2. Training content – 1910.1030(g)(2)(vii)

DSH Assistant, 06/30/20,
BBP, as with most areas, should include general training on the topic, the standard, hazards, and correction methods. The training should then focus on company-specific training and specific hazard training for those employees who are in direct contact, including emergency responders. Trainers should always try to include as much hands-on training as possible. Finally, we recommend that you use a documented assessment. The assessment helps determine if the employees understand the training and adds evidence that the employee received training.
DSH Assistant, 06/30/20,
The BBP standard does not explicitly state this as do some other standards, however, an employer should consider retraining employees when they see a deficiency.
DSH Assistant, 06/30/20,
Training must be – 1910.1030(g)(2)(vi)Tailored to the education and literacy level of the employee; In the appropriate language of employees; During the normal work shift
DSH Assistant, 08/07/20,
Ensure proper recording of exposure incidents. See 1010.1030(h)(5)(i) regarding injuries resulting from contaminated sharps.
DSH Assistant, 06/30/20,
PERRP reporting/recordkeeping is specific to public employers in Ohio. Remove this section for all other employers.
DSH Assistant, 08/07/20,
Refer to 1910.1020, Employee exposure and medical records. Work with human resources and others as needed.
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a. Access to a copy of the standard and explanation of its contentsb. Epidemiology and symptoms of bloodborne diseasesc. Modes of transmission of bloodborne pathogensd. An explanation of this Exposure Control Plan and the method for obtaining a copye. Methods of recognizing tasks that may involve exposuref. Use and limitations of methods to reduce exposure, for example engineering

controls, work practices, and PPEg. Information on the types, use, location, removal, handling, decontamination, and

disposal of PPEh. An explanation of the basis for choice of PPEi. Information on the Hepatitis B vaccination, including efficacy, safety, methods of

administration, benefits, and that it is free of chargej. Actions to take and persons to contact in an emergency involving blood or other

potentially infectious materialsk. Procedures to follow if an exposure incident occurs, including the method

of reporting and medical follow-upl. Information on the evaluation and follow-up required after an employee exposure

incidentm. Biohazard signs, labels, and/or color-coding systems used; andn. An opportunity for interactive questions and answers with the person conducting

the training session

3. Training Records – 1910.1030(h)(2) *Attachment H

a. Job Title documents all training.b. Job Title keeps all training records for three years from the date of the training.c. Training records include:

i. Dates of the training session.ii. Contents or a summary of the training sessions.

iii. Names and qualifications of trainers.iv. Names and job titles of attendees.

D. PROGRAM EVALUATION & UPDATES 1910.1030(c)(1)(iv)

Employer Name conducts time reviews of the written Exposure Control Plan for compliance with federal regulations and our internal requirements to assure quality and effectiveness.

The updated plan:1. Reflects new or modified tasks and procedures.2. Documents considerations and implementation of safer devices/procedures that will

eliminate or minimize exposure.3. Solicits, receives, and documents input from employees involved in job tasks who

are potentially exposed.

DSH Assistant, 06/30/20,
Getting input on the plan and procedures from frontline employees is a terrific way to get current ideas, find areas that are working, find the areas of opportunity, and get employee buy-in. We recommend that you consider this in other safety programs as well.
DSH Assistant, 06/30/20,
The person conducting the training must be knowledgeable in the subject matter as it relates to the workplace. Individuals from a variety of sectors and workplaces can do general BBP training, but a trainer needs to have knowledge on the specific tasks and procedures the employees perform. Employee training and information requirements can be satisfied through activities such as formal classroom training, handouts, signs and placards, periodic safety meetings, and hands-on exercises. Include a description of the training format in the record (e.g., written, visual presentation using slides, verbal).
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The Job Title keeps the findings of the review and the plans to correct deficiencies in the program.

ATTACHMENTS

Included here are forms, definitions, inventory, logs, maps, training documents, policy review signoffs, action plans, sample docs, corrective action, etc.

Attachment A – DefinitionsAttachment B – Exposure DeterminationAttachment C – Cleaning Schedule Attachment D – Hepatitis B Consent/Declination FormAttachment E – Exposure Incident ReportAttachment F – Exposure Follow-upAttachment G – PERRP Sharps Injury Form SH-12 (Public Employers)Attachment H – Training LogBLOODBORNE PATHOGEN RESOURCES