In accordance with the Occupational Safety Health Administration (OSHA) Bloodborne Pathogens Standard, 29 CFR 1910.1030, the following Exposure Control Plan has been developed to document measures used to protect Brockport Athletic Training employees/students from the health hazards associated with occupational exposure to pathogenic organisms present in blood or other bodily fluids.
OSHA requires employers to perform an exposure determination concerning which students/employees may incur occupational exposure to blood or other potentially infectious materials (OPIM). The OSHA Bloodborne Pathogens standard applies to employees/students with occupational exposure to human blood, blood products and other potentially infectious materials. Under the standard, occupational exposure is defined as reasonably anticipated skin, eye, mucous membrane, or parenteral contact with blood or OPIM that results in the performance of an employee’s duties. According to the OSHA standard, blood and OPIMs include:
- Human blood, human blood components, and products made from human blood;
- The following human body fluids: semen; vaginal secretions; cerebrospinal fluid; synovial fluid; pleural fluid; pericardial fluid; peritoneal fluid; amniotic fluid; saliva in dental procedures; any body fluid that is visibly contaminated with blood; all body fluids in situations where it is difficult or impossible to differentiate between body fluids;
- Any unfixed tissue or organ (other than intact skin) from a human, living or dead; and
- Human Immunodeficiency Virus (HIV)-containing cell or tissue cultures, organ cultures, and HIV- or hepatitis B Virus (HBV)-containing culture medium or other solutions; and blood, organs, or other tissues from experimental animals infected with HIV or HBV.
The exposure determination is made without regard to frequency of exposure or the use of personal protective equipment (i.e., employees are considered to be exposed even if they wear personal protective equipment). This exposure determination affects all full-time athletic trainers on staff and athletic training students at SUNY Brockport working directly with SUNY Brockport athletes or athletes participating on the University campus as part of a program sponsored by or hosted by SUNY Brockport. This also covers athletic training students who are completing a required clinical experience at an off-campus affiliated clinical site.
The job classifications and associated tasks for these categories are as follows:
- Athletic Training Staff members will be expected to provide emergency treatment for life-threatening emergencies, including administering mouth-to-mouth resuscitation and controlling bleeding occurring due to participation in athletics. Also, the staff member may be involved in assisting the team physician with suturing, draining blisters, applying band-aids, or shaving calluses.
- Athletic Training Students will often be required to perform the same tasks when the situation requires.
Implementation Schedule and Methodology
OSHA also requires that this plan include a schedule and method of implementation for the various requirements of the standard. The following complies with this requirement:
Universal Precautions will be observed at this facility in order to prevent contact with blood, blood products, or other potentially infectious materials. All blood, blood product, or other potentially infectious material will be treated as if known to be infectious regardless of the perceived status of the source or source individual.
Engineering and work practice controls will be used to eliminate or minimize exposure to employees at this facility. Where occupational exposure remains after institution of these controls, personal protective equipment shall also be used. (All staff and athletic training students will use personal protective equipment in dealing with any potentially infectious material). At this
facility, sharps containers, waste disposable bags, and clearly marked biohazardous waste containers will be used as engineering controls.
The above controls will be examined and maintained on a regular basis, with attention given to the contents of the engineering controls to insure removal once the containers reach ½ to ¾ of capacity.
Hand washing facilities are also available to the employees who incur exposure to blood or other potentially infectious materials. OSHA requires that these facilities be readily accessible after incurring exposure. At this facility there are two-hand washing facilities located in the athletic training clinic, in each athletic locker room and in each of the public restrooms. As an alternative a personal antimicrobial wipe is stored in each athletic training student’s fanny pack, or athletic training kit on the site. If this alternate method is used, the hands are to be washed with soap and running water as soon as feasible following an exposure.
After proper removal and disposal of personal protective gloves or other personal protective equipment, staff and athletic training student shall wash their hands or any other potentially contaminated skin area immediately or as soon as feasible with soap and water. If staff and athletic training student incur exposure to their skin or mucous membranes, then those areas shall be washed or flushed with water as appropriated or as soon as feasible following contact.
Needles and Sharps Handling Practices
Contaminated needles and other contaminated sharps objects will not be bent, recapped, removed, sheared, or purposely broken. Following usage needles or other contaminated sharps objects will be disposed of in a clearly marked biohazardous, sharps container. OSHA allows for one exception to the rule governing the disposal of needles, if the procedure requires that the contaminated needle be recapped or removed and no alternative is feasible, and the action is required by the medical procedure. If such an action is required, then the recapping or removal of the needle must be done by the use of a mechanical device or a one handed technique. Shearing or breaking of used needles is prohibited at Brockport. Any broken glass involved in an accident and visible contaminated with blood will be handled as a contaminated sharp. At this facility, recapping or removal is only permitted while assisting the team physician in a procedure necessitating this act.
Containers for Reusable Sharps
Contaminated sharps that are not reusable are to be placed immediately, or as soon as possible after use, into appropriated sharps containers. At this facility, the sharps containers are puncture resistant, closable, labeled with a biohazard label, and are leak-proof. The sharps container is located in the office of the Head Athletic Trainer.
Work Area Restrictions
In work areas where there is a reasonable likelihood of exposure to blood or other potentially infectious materials, staff and athletic training students are not to eat, drink, apply cosmetics or lip balm, smoke, or handle contact lenses. Food and beverages are not to be kept or placed on treatment tables, taping tables or countertops when blood or other potentially infectious materials are likely to be present. All procedures will be conducted in a manner that will minimize splashing, spraying, splattering, and generation of droplets of blood or other potentially infectious materials.
Specimens of blood or other potentially infectious materials, such as urine, will be placed in a container that prevents leakage during the collection, handling, processing, storage, and transport of the specimens. The container used for this purpose will be labeled or color-coded in accordance with the requirements of OSHA standards. It should be noted that this standard provides exemption for specimens from the labeling/color coding requirements of the standard, provided the facility uses Universal Precautions in the handling of all specimens and the containers are recognizable as container specimens. This exemption only applies while the specimens remain in the facility. If outside contamination of the primary container occurs, the primary container shall be placed within a secondary container that prevents leakage during the handling, processing, storage, transport, and/or shipping of the specimen.
Equipment that has become contaminated with blood or other potentially infectious materials shall be examined before servicing or shipping and shall be decontaminated as necessary unless the decontamination of the equipment is not feasible.
Personal Protective Equipment
All personal protective equipment used at the facility will be provided without cost to the staff and athletic training students. Personal protective equipment will be chosen based on the anticipated exposure to blood or other potentially infectious materials. The protective equipment will be considered appropriate only if it does not permit blood or other potentially infectious materials to pass through or reach a staff or students’ clothing, skin, eyes, mouth, or other mucous membranes under normal conditions of use and for the duration of time that the protective equipment will be used. The protective equipment necessary for the athletic training room primarily consists of vinyl gloves. These gloves will be stored on the counter in all athletic training rooms, in all the athletic
training kits, the first aid shelves in the taping tables, and in individual fanny packs used by the staff and athletic training students.
There is also other protective equipment made available to everyone at no cost to the staff, and students. They are listed below:
Personal Protective Equipment
- One-way Pocket masks
- Examination Gloves
- Protective eyewear
- Face shield
- Protective Gowns
All personal protective equipment will be cleaned, laundered, and disposed of by the University at no cost to the staff and students. The University, at no cost to the staff and students, will make all repairs and replacements.
All garments that are penetrated by blood shall be removed immediately or as soon as feasible. All personal protective equipment will be removed before leaving the work area.
Gloves shall be worn where it is reasonably anticipated that staff and athletic training students will have hand contact with blood, other potentially infectious materials, non-intact skin, and mucous membranes. Gloves will be used for the following procedures:
- Applying bandages
- Applying wound closures
- Draining blisters
- Shaving calluses
- Cleaning open wounds
- Handling urine specimens
- Cleaning evaluation tables
- Cleaning spills of potentially infected materials
- Evaluating oral/dental injuries or conditions
- Applying direct pressure to open wounds
- Handling/changing wound dressings
Disposable gloves used at the facility are not to be washed or decontaminated for re-use. They are to be replaced as soon as practical when they become contaminated or as soon as feasible when or if they are torn, punctured, or when their ability to function as a barrier is compromised.
The facility will be cleaned and decontaminated daily when used by athletes. Decontamination will also take place after any blood or other potentially infectious material has been exposed in the athletic training room. These decontamination products are stored in or on the first aid cabinets of the training rooms.
Regulated Waste Disposal
All contaminated sharps shall be discarded as soon as feasible in sharps containers located in the facility. Sharps containers are located in all athletic training rooms. Regulated waste other than sharps shall be placed in appropriate containers with color-coded waste bags. Such containers are located in the Athletic Training Rooms.
Laundry contaminated with blood or other potentially infectious materials will be handled as little as possible. Such laundry will be placed in appropriately marked bags where it is used. This laundry will not be sorted or rinsed in the area of use. It will then be removed by the individual responsible for laundry using personal protective equipment, and washed separately in bleach. All staff that handles contaminated laundry will use personal protective equipment to prevent contact with blood or other potentially infectious materials.
Communication of Hazards
Hazards related to bloodborne pathogens are communicated through warning labels, as well as through training for employees/students with occupational exposure. Warning labels are required on containers of regulated medical waste, refrigerators and freezers containing blood or other potentially infectious material, and other containers used to store, transport, or ship blood or OPIM. The labels include the biohazard symbol and the word “biohazard”. Red bags or red containers may be substituted for labels.
Post-Exposure and Follow-up
When a staff member or athletic training student incurs an exposure incident, it should be reported to the Program Director, Clinical Education Coordinator and/or Preceptor. The student health center or local hospital will evaluate the individual. In the event that a student incurs an exposure incident at an off-campus affiliated site, that student should report to the nearest Emergency Department or their Primary Care Physician. All individuals who incur an exposure will be offered post “exposure evaluation and follow-up” in accordance with OSHA standard. The follow-up will include the following:
- Written documentation of the route of exposure and the circumstances related to the incident as soon as feasible following exposure. This is to be returned to the Program Director or Clinical Education Coordinator.
- For puncture injuries or cuts from sharps, expose, express (encourage bleeding if the wound is small) and thoroughly wash the wound area with soap and water for 15 minutes. If soap and water are not available, then an antiseptic (solution, wipe, spray) should be used.
- Wash any area exposed to blood or OPIM with tepid water and soap for at least 5 minutes. Alcohol-based hand rinses, gels, foams (containing 60+% alcohol) should be used on intact skin when water is not available.
- If splashes are to the eyes, irrigate eyes with clean water or commercially available eyewash solution for 15 minutes.
- If possible, the identification of the source individual and if possible the status of the source individual. The blood of the source individual will be tested after consent is obtained for HIV/HBV infection.
- Results of testing of the source individual will be made available to the exposed staff or athletic training student with the exposed individual informed about the applicable laws and regulations concerning disclosure of the identity and infection of the source individual.
- The individual will be offered the option of having their blood collected for testing of the individuals HIV/HBV serological status.
- The Program Director will be designated to assure that the policy outlined above is effectively carried out as well as to maintain records related to this policy.
Once these procedures have been completed, an appointment with a qualified healthcare professional is arranged for the exposed student to discuss the student’s medical status. This includes an evaluation of any reported illness, as well as any recommended treatment.
Training for all staff and athletic training students will be conducted annually and before initial assignment to tasks where occupational exposure may occur. Training for staff and students will include the following:
- The OSHA Standard for Bloodborne Pathogens.
- Epidemiology and symptomatology of bloodborne disease.
- Modes of transmission of bloodborne pathogens.
- The exposure plan (i.e. points of the plan, lines of responsibility, how the plan will be implemented, etc.)
- Procedures that might cause exposure to blood or other potentially infectious material at this facility.
- Control methods to be used at the facility to control exposure to blood or other potentially infectious materials.
- Personal protective equipment available at this facility.
- Who should be contacted concerning exposure to blood or other potentially infectious material?
- Post-exposure evaluation and follow-up.
- Signs and labels used at the facility.
The Athletic Training Program Director will maintain all records required by the OSHA standard. The athletic training faculty/preceptors will be responsible for conducting the training to the athletic trainer students during orientation. All staff and students will receive annual refresher training within one year of the individual’s previous training. The OSHA Standard for Bloodborne Pathogens and the outline for the training material will be kept in the office of the Program Director and in the policies and procedure manual.