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Exposure Control Plan

Introduction

The primary purpose of the DCPS Exposure Control Plan is to provide protection to all human health within the school system, pursuant to, the US Department of Labor, Occupational Safety and Health Administration (OSHA) Occupational Exposure to Bloodborne Pathogens (BBP) standards and DC government solid waste management rules. Additionally, the plan is designed to ensure that schools comply with the DC Department of Health (DOH) Universal Precautions Standards and public health practices.

The Exposure Control Plan includes a model that was established by the State of North Carolina’s Franklin County School System. The District decided to use the Franklin County exposure control model because it meets the requirements of OSHA BBP and hazard communication standards.

The OSHA BBP standard protects employees who work in occupations where they are at risk of exposure to blood or other potentially infectious materials. The OSHA hazard communication standard protects employees who may be exposed to hazardous chemicals.5 The primary purpose of the BBP standards is to eliminate or minimize on-the-job exposure to blood and other potentially infectious materials, which could result in the transmission of BBPs and lead to disease or death. The major pathogens are the Hepatitis B Virus (HBV), Hepatitis C Virus (HCV), and the Human Immunodeficiency Virus (HIV).6 The DC government waste management rules determine proper disposal methods of items that are contaminated with blood and other potentially infectious materials.

Policy

The District is committed to providing a safe and healthy work environment for all staff and students. In pursuit of this goal, the following exposure control plan (ECP) is provided to eliminate or minimize occupational exposure to BBPs in accordance with OSHA standard 29 CFR 1910.1030, Occupational Exposure to Bloodborne Pathogens.

The policy applies to all school employees and students. For the purpose of this plan, occupational exposure means any reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials that may result from the performance of an employee's assigned work duties.

Authorities

  • Department of Labor, OSHA Occupational Exposure to Bloodborne Pathogens Standard (29 CFR 1910.1030) provides provisions to employers to eliminate or minimize occupational exposure to BBPs in the work environment.
  • DC Law 17-009, Public Education Reform Amendment Act of 2007. Sections 105, 106 grants the Chancellor authority to direct and supervise the administration of DC Public Schools.
  • Preventive Health Services Administration Act of 1985 (DC Official Code 7-131 et seq.) authorizes the Mayor, in consultation with the DOH Director, to control the spread of a communicable disease, including the authority to order examination, treatment isolation, or quarantine of a person or persons.
  • DC Law 3-20, Immunization Of School Students Act of 1979, describes immunization and medical exemption requirements.
  • Title 22 DCMR Public Health and Medicine provides direction for human health best practices concerning management of infectious and communicable diseases. Title 22 also provides policy direction concerning management of infectious and hazardous waste.
  • Title 5 DCMR Section 1023 sets forth provisions for the protection of employees’ health information.
  • Provisions for the protection of student health information are included in Chapter 24, Title 5 DCMR and the Family Educational Rights and Privacy Act (FERPA) (20 U.S 123g; 34 CFR 99).
  • DC Law 12-263, Human Right Genetic Information Amendment Act of 2004, includes provisions that allow an employer to obtain genetic information about an employee to potentially toxic substances in the workplace, provided that the employee provides, in writing, his or her informed consent, and the genetic information is provided to the employee in writing as soon as it is available, and the genetic information is not disclosed to any other person.
  • DC Law 1-134, District of Columbia Solid Waste Regulations of 1997, provides for the safe management and disposal of infectious and hazardous waste.

Program Administration

The Chancellor will appoint the Chief Business Officer as the lead school official to ensure that:

  • All elements of the Exposure Control Plan (ECP) are met.
  • Contents of the ECP are conveyed to employees.
  • Policies and procedures are in place for employees not complying with the ECP.
  • The BBP Standards Committee is appointed.
  • BBP Program Coordinator is assigned to monitor implementation of the DCPS Exposure Control Plan.

The BBP Program Coordinator will ensure that:

  • Appropriate housekeeping standards are developed and met for the cleaning and decontamination of work areas where there is potential for exposure to BBP.
  • Appropriate personal protective equipment (PPE) is readily accessible at auxiliary sites.
  • Contaminated waste disposal standards are met.
  • Blood spill cleanup kits and antiseptic towelettes are available in school vehicles and buses.
  • Incident and BBP Surveillance and Monitoring Forms are developed and placed in all schools.
  • Mandatory BBP training is conducted and that all employees attend.
  • Employees are identified as being at-risk for occupational exposure and at-risk employees attend the Required BBP training sessions.
  • Appropriate PPE is available in accessible locations.
  • Outdated BBP supplies are replaced (e.g., in cleanup/hygiene stations, in the main office). Employees comply with the ECP and address noncompliance issues.
  • A copy of the Exposure Control Plan is readily accessible in the main office at each school and reception desk.
  • Updates of the ECP occur when information is received from the BBP Program Coordinator and revisions are communicated to employees.
  • The annual Bloodborne Pathogens Surveillance and Monitoring Form for the workplace is completed in accordance with program guidelines.
  • The DCPS Incident Report and Bloodborne Pathogens Exposure Report forms are completed when indicated and assistance is provided to employees.
  • BBP Program Coordinator is immediately notified when an occupational exposure incident occurs. Circumstances surrounding exposure incidents are evaluated and administrators initiate corrective actions to prevent future incidents.
  • All work sites are maintained in a clean and sanitary condition.
  • The ECP is developed, implemented, reviewed, and updated in conformity with applicable District and Federal OSHA regulations and waste management laws.
  • An updated copy of the ECP is given to each principal. Plan recipients should place the document in accessible areas located in the main office and in the reception area of each auxiliary site.
  • The work environment is evaluated, identifying actual and potential hazards for exposure to BBPs, jobs having collateral risk, and at-risk job categories.
  • Employee Exposure Determination Questionnaires are reviewed to identify at-risk employees.
  • Appropriate measures to protect employees from occupational exposure are developed and specified in the ECP and the information is conveyed to employees during BBP training sessions.
  • These measures must include use of hand washing techniques, universal precautions, labels with the biohazard warning symbol, work practice controls, personal protective equipment, housekeeping standards, methods for handling contaminated laundry, and methods for disposing of contaminated waste and contaminated sharps.
  • The BBP Program Coordinator will assess and at least annually document in the master copy of the ECP the availability of safer personal protective devices.
  • The Hepatitis B vaccination series is offered to at-risk employees.
  • The BBP Program Coordinator will coordinate with the DOH concerning the administration of the Hepatitis B vaccine for employees accepting the series.
  • The BBP Program Coordinator will maintain Hepatitis B vaccination records of at-risk employees.
  • Review the DCPS Incident Report, DCPS Bloodborne Pathogens Exposure Report, and DCPS Bloodborne Pathogens Source Incident Report forms in accordance with program guidelines.
  • Develop Corrective Action Plans (CAP) and complete followup and documentation for occupational exposure incidents. Post-exposure medical evaluations and followup procedures are followed.
  • Establish and confidentially maintain medical records systems.
  • Ensure the completion of BBP training classes and maintain records at a central office for a three-year period. Current and archived records shall be maintained in a secured area at all times.
  • Document data from nonmanagerial employees potentially exposed to injuries from contaminated sharps in the master copy of the Exposure Control Plan.
  • Also, note recommendations and best management practices (BMP) for more effective engineering and work-practice controls.
  • Complete the Sharps Injury Log and maintain confidentiality.
  • Records shall be retained at a central office for five years. Current and archived records will be maintained in a secured area at all times.
  • Complete the Annual Bloodborne Pathogens Surveillance and Monitoring Form for each school and auxiliary site.
  • Review, file, and institute corrective actions, as required.
  • Convene Bloodborne Pathogens Standards Committee meetings as required.

The BBP Program Coordinator will chair the BBP Standards Committee to ensure that:

  • Mandatory annual BBP training takes place.
  • BBP supplies are available at each school.
  • Coordination occurs with school nurse, ensuring that letters are sent to parents/legal guardians who are providing needle devices for school personnel to use in the care of students.

NOTE this section continues in full with:

  • Plan Exposure Control
  • Exposure Determination
  • Methods of Compliance and Safe Work Practices
  • Hepatitis B Vaccination Post-Exposure Evaluation and Followup
  • Communicating Hazards to Employees
  • Record Keeping and Surveillance
  • Exposure Control Plan Glossary of Terms

See the downloadable version for the full Exposure Control Plan in Word and PDF.