Public Safety Exposure Control Plan

INTRODUCTION

The OSHA/VOSH 1910.1030 Bloodborne Pathogens Standard was issued to reduce the occupational transmission of infections caused by microorganisms sometimes found in human blood and certain other potentially infectious materials. Although a variety of harmful microorganisms may be transmitted through contact with infected human blood, Hepatitis B Virus (HBV) and Human Immunodeficiency Virus (HIV) have been shown to be responsible for infecting workers who were exposed to human blood and certain other body fluids containing these viruses, through routes like needlestick injuries and by direct contact of mucous membranes and non-intact skin with contaminated blood/materials, in the course of their work. Occupational transmission of HBV occurs much more often than transmission of HIV. Although HIV is rarely transmitted following occupational exposure incidents, the lethal nature of HIV requires that all possible measures be used to prevent exposure of workers.

This exposure control plan has been established by James Madison University's Campus Police unit within the Office of Public Safety, in order to minimize and to prevent, when possible, the exposure of our employees to disease-causing microorganisms transmitted through human blood, and as a means of complying with the Bloodborne Pathogens Standard. All employees who are exposed to blood and other potentially infectious materials as a part of their job duties are included in this program. (See Part II. Exposure Determination for a discussion of job categories and tasks that have been identified as having exposure.) This plan will be reviewed at least annually and updated as necessary by the Chief of Campus Police in consultation with the Safety Engineer. Copies of this plan are available (for review by any employee) in the following locations within Shenandoah Hall (Public Safety building):

• On the bulletin board in the Squad Room.
• From files maintained by the Safety Engineer.
• From files maintained by the Chief of Campus Police.
• From files maintained by the Director of Public Safety.

An employee may obtain a copy of this plan within 15 days of his/her request to the Chief of Campus Police, the Director of Public Safety, or the Safety Engineer.

Basic components of this exposure control plan include:

• Exposure Determination
• Methods of Compliance
• Hepatitis B Vaccination Policy
• Procedures for Evaluation of Follow-up of Exposure Incidents
• Employee Training
• Recordkeeping Procedures

Exposure Determination

All job categories in which it is reasonable to anticipate that an employee will have skin, eye, mucous membrane, or parenteral contact with blood or other potentially infectious materials (listed below) will be included in this exposure control plan. Exposure determination is made without regard to the use of personal protective equipment. (i.e. employees are considered to be exposed even if they wear personal protective equipment)

Other Potentially Infectious Materials (OPIM)

Body Fluids
• semen
• vaginal secretions
• pleural fluid
• pericardial fluid
• amniotic fluid
• any body fluid visibly contaminated with blood
• saliva in dental procedures
Other Materials
• any unfixed tissue or organ (other than intact skin) from a human (living or dead)
• HIV/HBV containing cell or tissue cultures, organ cultures, and culture medium
• blood, organs, or other tissues from experimental animals infected with HIV or HBV

PUBLIC SAFETY EMPLOYEES CONSIDERED "AT RISK" TO EXPOSURE

All employees in job categories listed here are included in the plan:

• Campus Police Officers
• Campus Police Sergeants
• Campus Police Investigators
• Campus Police Chief
• University Safety Engineer
• Director of Public Safety

Methods of Compliance

Universal Precautions

All blood or other potentially infectious materials (as described in II. Exposure Determination) shall be handled as if contaminated by a bloodborne pathogen. Under circumstances in which differentiation between body fluid types is difficult or impossible, all body fluids shall be considered potentially infectious materials.

Engineering and Work Practice Controls shall be used to eliminate or minimize employee exposure. Where occupational exposure remains after institution of these controls, personal protective equipment shall also be used. The following engineering controls will be utilized:

• Disposable rubber gloves
• Glove carriers, black leather, gunbelt mounted, uniformed patrol
• Glove carriers, nylon, belt mounted, plain clothed officers
• Disposable combination surgical face mask/eye shield
• Disposable coveralls
• Disposable head coverings (hoods) with elastic bands
• Disposable non skid shoe coverings (booties)
• Disposable "sharps" containers
• Warning labels and seals
• Biohazard safety bags
• Disposable germicidal anti-septic cloth towelletes
• Quick evaporating sanitizing liquid hand cleaner
• Disposable absorbant towels
• Utility carrier case for each police vehicle
• All purpose household utility spray bottle (for the 10% chlorine bleach in water solution)
• Sharps containers
• Small refrigerator for biological evidence (blood, etc.) within the evidence storage room
• Caged and Biohazard warning posted storage compound within the evidence room

The above controls will be maintained or replaced on a regular schedule. The schedule for reviewing the effectiveness of the controls is as follows:

The Campus Police Chief and Campus Police Sergeants will inspect the vehicle carrier cases and station based equipment at least weekly to maintain adequate supplies. In the event of an exposure incident the supply cases with be inspected and replenished as soon as practical following the event.

Handwashing and other General Hygiene Measures

Handwashing is a primary infection control measure which is protective of both the employee and the patient. Appropriate handwashing must be diligently practiced. Employees shall wash hands thoroughly using soap and water whenever hands become contaminated and as soon as possible after removing gloves or other personal protective equipment. When other skin areas or mucous membranes come in contact with blood or other potentially infectious materials, the skin shall be washed with soap and water, and the mucous membranes shall be flushed with water, as soon as possible.

Handwashing/showering facilities (lavatories) are conveniently located on all floors of Shenandoah Hall, the Public Safety building contiguous to all police locker rooms, the squad room, the Sergeants' office, the Investigator's office, the Safety Engineer's office, and the evidence room. The latter will be set aside as the primary decontamination scrub down area in the event of major biological soiling of uniforms and protective disposable outerwear. A handwashing facility is located within the communications area.

Each police vehicle is equipped with anti-septic towelettes, absorbant towels, and quick evaporating germicidal liquid hand cleaner for first echelon hand/face/exposed skin cleaning and decontamination in the field. This is not a substitute for handwashing/scrub down with soap and running water. Such decontamination shall take place as soon as feasible on station or at any other suitable alternate location.

Eating, drinking, smoking, applying cosmetics or lip balm, and handling contact lenses are prohibited in work areas where there is a reasonable likelihood of exposure to blood or other potentially infectious materials.

Food and drink shall not be kept in refrigerators, freezers, shelves, cabinets or on countertops or benchtops were blood or other potentially infectious materials are present.

Biological evidence such as liquid blood samples and post sexual assault "PERK" kits containing blood or other body secretions shall be secured in the designated evidence storage refrigerator pending shipment to a certified forensic laboratory. Evidence containing dried blood, blood products, or other body fluids will be properly packaged, Biohazard labeled and stored within the secure caged area in the evidence room.

Employees shall use practices to minimize splashing, spraying, spattering, and generation of droplets during procedures involving blood or other potentially infectious materials.

• Handling suspected contaminated evidence at crime scenes.
• Responding to medical emergencies where exposure to blood and/or other body fluids is possible.
• Handling "perk" kits and clothing of sex crime victims and suspects.
• Securing vehicle accident scenes where exposure to blood and/or other body fluids is possible.
• Effecting arrests where subjects resist and/or exposure to blood or other body fluids is possible.
• Decontamination vehicles of biological soiling (urine, feces, vomitus, saliva, etc.), blood, and/or other body fluids.

Officers will outfit themselves with personal protective equipment and garb to an appropriate level depending on time available. In exigent emergency circumstances it is recognized that outfitting with full protective gear is not always practical or possible. Direct contact with sharps and/or broken glass is to be avoided or if not possible, minimized. Post exposure handwashing and/or full body decontamination shall be a matter of routine.

When exposed to human bites or to the blood or body fluids of another in the line of duty officers shall:

1. Exercise care and caution and, whenever possible, wear personal protective equipment (PPE) to the appropriate level of protection when:
   1. Handling items which may contain blood or body fluid products (hypodermic needles, syringes, etc.).
   2. Searching persons in custody.
   3. Processing crime scenes.
   4. Packaging and handling these items as evidence placing them into an approved sharps container.
   5. Cleaning up blood or other secretions which have contaminated floors, seats, equipment, etc.
   6. Responding to medical emergencies.
   7. Responding to vehicle or other accidents.
2. Thoroughly wash hands with hot water and soap after removing gloves and thoroughly wash hands and other parts of the body after removing and properly bagging soiled clothing which may have been contaminated with blood, secretions, or excretions. When in the field and availability of soap and water is problematic, use the instant germicidal hand sanitizer or disposable antiseptic towelettes provided in the kits provided in the patrol vehicles.
3. If practical to do so wear a disposable gown, head covering, and booties if contamination of clothing by blood, semen, or other body fluids is likely.
4. A disposable resusitation mask shall be used when administering CPR.
5. Deposit such contaminated items in specially labeled or marked containers (red bags or bags labeled with the approved Biohazard warning labels).
6. Promptly notify the immediate supervisor and seek immediate post exposure medical attention after:
   1. Being stuck with knife, hypodermic needle, or other sharp object.
   2. Being exposed to or having contact with blood or body fluids, an open wound, or mucous membrane (through eyes, nose, mouth, or by contact with non intact skin) of any person due to the fact that the true risk of contracting Hepatitis B and HIV is unknown.
7. If the victim of a human bite, immediately:
   1. Encourage the wound to bleed.
   2. Wash the area thoroughly with soap and hot water.
   3. Seek immediate emergency medical attention.
8. Complete a post exposure incident report in detail concerning any suspected exposures to blood or body fluids or human bite.

The immediate supervisor of an employee who is exposed to blood or body fluids or human bite, upon notification, is responsible for:

1. Ensuring that any subject who has bitten a police officer or other employee is asked to consent to a blood test for HBV and HIV by signing an appropriate release form.
2. Upon the refusal by such a subject to consent to a blood test, ensure that the Commonwealth Attorney expediciously seeks a court order for a blood test.
3. Ensuring that the compliance officer (Safety Engineer) and human resource director are forwarded copies of the post exposure incident report.

The University is responsible for post exposure incident testing for HBV and HIV plus subsequent treatment of police personnel.

The Office for Public Safety is responsible for ensuring that:

1. Special clearly marked Biohazard containers are provided for the disposal of all contaminated gloves, gowns, headgear, masks, eye shields, booties, etc.
2. The containers are properly disposed of when necessary.
3. An adequate supply of disposable personal protective equipment (filtration masks, eye shields, etc.) and sanitizing supplies are maintained in the patrol vehicles and on station.
4. An adequate supply of approved cleaning solution (10% chlorine bleach solution or commercial product) is available for use by housekeeping personnel.

When a person in custody has been transported in a patrol vehicle the appropriate officer shall:

1. Ensure the vehicle is thoroughly cleaned and decontamniated immediately following possible contamination by blood, saliva, semen, urine, feces, or other body fluids. To facilitate such decontamination the patrol vehicles equipped with protective cages are to have the rear seats covered in clear vinyl.
2. Ensure that properly trained housekeeping personnel are notified promptly of the situation.
   1. Request that the vehicle and other contaminated areas are thoroughly cleaned and decontaminated.
   2. The U.S. Bureau of Disease Control suggests that a freshly prepared solution of one part household chlorine bleach (5.25% sodium hypochlorite) and nine parts water be utilized for cleaning contaminated areas.
3. Whenever special containers for deposit of biohazard waste, spent cleaning wipes, sharps, etc. are in need of disposal, notify the Chief of Police and Safety Engineer. Arrangements will be made for proper disposal or incineration and an approved site.

All contaminated evidentiary items shall be placed in appropriately labeled containers and sealed with evidence tape.

1. Envelopes, plastic or otherwise, containing possibly contaminated evidentiary shall not be stapled. Care should be taken with such articles if wet or moist. If not dry, biological deterioration can take place which will negatively effect forensic test results rendering such evidence useless in court.
2. The evidence envelope shall be clearly marked with Biohazard warning labels.
3. When handling items where contamination is possible, members of the Campus Police are to wear the appropriate shielding level of Personal Protective Equipment (face masks, eye shields, gowns, head covering, rubber gloves, booties, etc.).
4. For further advice and counsel questions may be directed to the following agencies:
   

   Valley AIDS Network	564-0448
   State AIDS Hotline	1(800)533-4148
   National Hotline for AIDS	1(800)342-AIDS(2437)

Sharps Management

Contaminated needles and other contaminated sharps shall not be bent, recapped or removed. Shearing or breaking of contaminated needles is prohibited.

Sharps containers must be closable, puncture resistent, labeled or color-coded, and leakproof on sides and bottom, and maintained upright throughout use. Containers are to be easily accessible to personnel and located as close as is feasible to the immediate area where sharps are used or found. Contaminated disposable sharps shall be discarded, as soon as possible after use, in the disposable sharps containers. Contaminated broken glass is also to be placed in disposable sharps containers. As soon as possible after use, reusable contaminated sharps are to be placed in the reusable sharps container until properly processed.

Location of sharps container(s): Evidence/decontamination room.

Overfilling of sharps containers creates a hazard when needles protrude from openings. Nearly full containers must be promptly disposed of (or emptied and decontaminated in the case of reusable sharps) and replaced.

Individuals(s)/positions responsible for maintaining sharps containers:

• Police Chief and/or designee.
• Safety Engineer.

Precautions in Handling Specimens

Specimens of Blood or other potentially infectious materials shall be placed in a container which prevents leakage during collection, handling, processing, storage, transport, or shipping. The container must be closed before being stored, transported, or shipped. Examples of containers are:

• Sealable blood vials and mailer packs located in the Squad Room.
• Post sex crime "PERK" kits located at Rockingham Memorial Hospital's Emergency Room. Sharps containers to be sent to the state's Forensic Lab.
• Other evidenciary containers to be sent to the state's Forensic Lab. Such containers are stored in the evidence room. Biological evidence should be refrigerated or dried to prevent putrefacation of the evidence, rendering it useless for court purposes.

Containers must be Biohazard labeled/color-coded if they go out of the facility (Biohazard labeling must also be used in-house if all specimens are not handled using universal precautions.)

Blood vials and mailer packs are exempted from color coding and labeling as they are mailed directly to certified medical and/or forensic labs. These labs routinely use universal precautions in the handling of all such specimens. All are inherently considered to be Biohazard items.

If outside contamination of the primary container occurs, or if the specimen could puncture the primary container, the primary container shall be placed within a secondary container which prevents leakage, and/or, resists puncture during handling, processing, storage, transport, or shipping.

Management of Contaminated Equipment

Assess equipment for contamination, and decontaminate if possible, before servicing or shipping. Equipment which has not been fully decontaminated must have label attached with information about which parts remain contaminated.

The persons within the Office of Public Safety resposible for assessing and decontaminating equipment are the Chief of Police or designee and the Safety Engineer. Universal Precautions (on file and posted at the Squad Room and in the Evidence Room) are to be used in such decontamination.

Personal Protective Equipment

General Guidelines

All personal protective equipment will be provided, repaired, cleaned, and disposed of by the employer at no cost to employees. Employees shall wear personal protective equipment when doing procedures in which exposure to the skin, eyes, mouth, or other mucous membranes is anticipated. The articles to be worn will depend on the expected exposure. Gloves, gowns, laboratory coats, face shields, masks, eye protection, mouthpieces, resuscitation bags, pocket masks are available. A variety of sizes are in stock. Employees who have allergies to regular gloves may obtain hypoallergenic gloves.

For procedures requiring personal protective equipment and the type of protection to be used refer to the previous section covering Handwashing and other General Hygiene Measures.

Personal Protective Equipment and clothing is available for issue by the Chief of Campus Police or the Safety Engineer. Stocks are found in the Public Safety supply room.

If a garment is penetrated by blood or other potentially infectious material, the garment shall be removed as soon as possible and placed in a designated container for laundering or disposal. All personal protective equipment shall be removed before leaving the work area; it shall be placed in assigned containers for storage, washing, decontamination or disposal.

Contaminated garments and other personal protective equipment will be properly bagged and/or Biohazard labeled and left in the secure area of the evidence room. The Chief of Campus Police or designee and the Safety Engineer will be promptly notified so that such such items and materials can be properly processed or disposed of.

Protection for Hands

Gloves shall be worn in the following situations:

• when it can be reasonably anticipated that hands will contact blood or other potentially infectious materials, mucous membranes, and non-intact skin such as taking persons into custody during civil disobediance demonstrations, handling persons in custody, responding to medical emergencies and vehicle accident scenes, processing violent crime scenes;
• if assisting in performing vascular access procedures (taking blood samples);
• when handling or touching possibly contaminated items or surfaces.
• other procedures outlined previously in the section relating to General Hygiene Measures.

Disposable Gloves

• Replace as soon as feasible when gloves are contaminated, torn, punctured, or when their ability to function as a barrier is compromised.
• Do not wash or decontaminate single use gloves for re-use.

Utility Gloves

• Decontaminate for re-use if the gloves are in good condition.
• Discard when gloves are cracked, peeling, torn, punctured or show other signs of deterioration (whenever their ability to act as a barrier is compromised).

Protection for Eyes/Nose/Mouth

Employees shall wear masks in combination with eye protection devices (goggles or glasses with solid side shields) or chin-length face shields whenever splashes, spray, spatter, or droplets of blood or other potentially infectious materials may be generated and eye, nose, or mouth contamination can be reasonably anticipated. Situations which would require such protection are as follows:

• Dealing with civil disobediance demonstrations.
• Responding to vehicle or other accident scenes and certain medical emergencies.
• Processing violent crime or suicide scenes.
• Attending autopsies.

Protection for the Body

A variety of garments including gowns, aprons, lab coats, clinic jackets, etc. are to be worn in occupational exposure situations. Surgical caps or hoods and/or shoe covers or boots shall be worn in instances when gross contamination can reasonably be anticipated. The following situations require the use of protective clothing:

• Processing violent crime or suicide scenes.
• Attending autopsies.
• Investigating particularly violent vehicle or aircraft accidents.

Housekeeping

General Policy

The workplace will be maintained in a clean and sanitary condition. A written housekeeping procedure guide, which gives the appropriate methods and frequency of decontamination based upon the location within the facility, type of surface to be cleaned, type of soil present, and tasks or procedures being performed, must be followed. Refer to the previous section relating to Handwashing and other General Hygiene Measures. Use of a freshly prepared 10% solution of household chlorine bleach in water contained in an all purpose spray bottle is recommended.

Equipment and Environmental and Working Surfaces

Clean contaminated work surfaces with appropriate disinfectant:

• after completing procedures or processing;
• immediately or as soon as feasible when overtly contaminated or after any spill of blood or Other Potentially Infectious Materials (OPIM);
• at the end of the work shift if the surface may have become contaminated since the last cleaning. Examples would be the interiors of patrol vehicles, the fingerprint stand in the processing room, etc.

Regularly inspect/decontaminate police patrol vehicles, fingerprint stands, lavatories used by persons in custody, and other surfaces and areas which may become contaminated with blood or OPIM. If these areas, articles, or surfaces should become visibly contaminated, they should be decontaminated immediately or as soon as feasible. The Chief of Campus Police or designee(s) should inspect said areas daily and initiate the decontamination process if required.

Special Sharps Precautions

Clean up broken glass which may be contaminated using mechanical means such as a brush and dustpan, tongs, or forceps. DO NOT pick up directly with the hands.

Reusable containers are not to be opened, emptied, or cleaned manually or in any other manner which will expose employees to the risk of percutaneous injury. DO NOT reach by hand into a container which stores reusable contaminated sharps.

Regulated Waste

• liquid or semi-liquid blood or other potentially infectious materials;
• contaminated items that would release blood or other potentially infectious materials in a liquid or semi-liquid state if compressed;
• items that are capable of releasing these materials during handling;
• contaminated sharps;
• pathological and microbiological wastes containing blood or other potentially infectious materials.

Waste Containers

Any of the substances listed above must be placed in containers which are: closable; constructed to contain all contents and prevent leakage of fluids during handling, storage, transport or shipping.

In this facility, containers will be Biohazard labeled or be colored red. If a label is used it must be fluorescent orange or orange-red with the biohazard warning and symbol in a contrasting color. The label must be either an integral part of the container or attached as close as is feasible to the container by string, wire, adhesive, or other method that prevents its loss or unintentional removal. Regulated waste that has been decontaminated need not be labeled or color-coded.

Containers must be closed prior to moving/removal to prevent spillage or protrusion of contents during handling, storage, transport, or shipping. If the outside of the container becomes contaminated, it is to be placed in a second container which must have the same characteristics as the initial container as discussed above.

Waste containers are to be disposed of at the Rockingham Memorial Hospital's incineration station by prior arrangement.

Laundry

Employees who handle contaminated laundry are to wear protective gloves and other appropriate personal protective equipment.

Contaminated laundry shall be handled as little as possible with a minimum of agitation. Do not sort/rinse laundry in location of use. Place in container/bag where it was used. Wet contaminated laundry which may soak-through or cause leakage from bag or containers which prevent soak-through and/or leakage of fluids to the exterior.

Bags/containers used will be biohazard labeled or colored red.

Laundry at this facility will be cleaned at the contracted dry cleaners. (When contaminated laundry is shipped off site to a second facility which does not use universal precautions, the bags or containers must be labeled with biohazard label or be color-coded in red.)

Communication of Hazards to Employees

Employees will be informed of hazards through a system of Biohazard labeling or color-coding, as well as a training program which is discussed in Section VI of this written plan.

Warning labels shall be affixed to containers of regulated waste, refrigerators and freezers containing blood or other potentially infectious material; and other containers used to store, transport or ship blood or other potentially infectious materials. Contaminated equipment shall also be labeled in this manner: information about the portions of the equipment that remain contaminated shall be added to the label.

Labels shall be fluorescent orange or orange-red with lettering or symbols in a contrasting color. The label is either to be an integral part of the container or affixed as close as feasible to the container by a method which prevents loss or unintentional removal of the label. The label shall have: the biohazard symbol and the text BIOHAZARD.

Red bags or red containers may be substituted for the warning label.

The labels/color-coding described here are not required in the following instances:

• when containers of blood, blood components, or blood products are labeled as to their contents and have been released for forensic examination;
• when individual containers of blood or other potentially infectious materials are placed in labeled containers during storage, transport, shipment or disposal;
• when regulated waste has been decontaminated.

HEPATITIS B VACCINATION POLICY

General Statement of Policy

All employees who have been identified as having exposure to bloodborne pathogens (see II. Exposure Determination) will be offered the hepatitis B vaccination series at no cost to them. In addition, these employees will be offered post-exposure evaluation and follow-up at no cost should they experience an exposure incident on the job.

All medical evaluations and procedures including the hepatitis B vaccination series, whether prophylactic or post-exposure, will be made available to the employee at a reasonable time and place. This medical care will be performed by or under the supervision of a licensed physician, physician's assistant, or nurse practitioner. Medical care and vaccination series will be according to the most current recommendations of the U. S. Public Health Service. A copy of the bloodborne pathogens standard will be provided to the healthcare professional responsible for the employee's hepatitis B vaccination. (Give the name of responsible licensed healthcare professional.)

All laboratory tests will be conducted by an accredited laboratory at no cost to the employee. The most convenient and frequently utilized laboratory is located at Rockingham Memorial Hospital.

Hepatitis B Vaccination

The vaccination is a series of three injections. The second injection is given one month from the initial injection. The final dose is given six months from the initial dose. At this time a routine booster dose is not recommended, but if the U. S. Public Health Service, at some future date recommends a booster, it will also be made available to exposed employees at no cost.

The vaccination will be made available to employees after they have attended training on bloodborne pathogens and within ten (10) working days of initial assignment to a job category with exposure. The vaccination series will not be made available to employees who have previously received the complete hepatitis B vaccination series; to any employee who has immunity as demonstrated through antibody testing; or to any employee for whom the vaccine is medically contraindicated.

Any exposed employee who chooses not to take the Hepatitis B vaccination will be required to sign a declination statement.

Hepatitus B vaccinations are available at the university's Health Center or at Rockingham Memorial Hospital through a contractural arrangement.

PROCEDURES FOR EVALUATION AND FOLLOW-UP OF EXPOSURE INCIDENTS

An exposure incident is a specific eye, mouth, or other mucous membrane, non-intact skin, or parenteral contact with blood or other potentially infectious materials that results from the performance of an employee's duties.

Officers who experience an exposure incident must immediately report their exposure to the Chief of Campus Police or designee(s). When an employee reports an exposure incident, he/she will immediately be offered a confidential medical evaluation and follow-up including the following elements:

• documentation of the route(s) of exposure, and the circumstances under which the exposure incident occurred;
• identification and documentation of the source individual unless identification is infeasible.

If the infectivity status of the source individual is unknown, the individual's blood will be tested as soon as feasible after consent is obtained. If the source individual's blood is available, and the individual's consent is not required by law, the blood shall be tested and the results documented. The exposed employee will be informed of the results of the source individual's testing.

Note: Virginia Code Section 32.1-45.2; effective July 1, 1992, Testing for Bloodborne Pathogens. Establishes a mechanism for testing for certain bloodborne pathogens when a possible exposure to such pathogens involving public safety employees occurs. Employees of public safety agencies are required to notify immediately their agencies of any possible exposure prone incident. Other persons involved in such possible exposure prone incident may request the agency to review the facts. The agency will then obtain medical consultation and review the facts and determine whether it is reasonable to believe that an exposure prone incident may have occurred. If the agency concludes that an exposure prone incident may have occurred, the person or employee whose body fluids were involved will be requested to consent to testing for Hepatitis B virus and human immunodeficiency virus and disclosure of test results. If the person or employee involved in the possible exposure prone incident is deceased, the agency will request the custodian of the remains to preserve a blood sample and will request consent from the decedent's next of kin. If consent is refused, the agency or the employee or other person may petition the relevant general district court to determine whether an exposure prone incident has occurred and to order testing and disclosure of test results. To order testing, the court must find by a preponderance of the evidence that an exposure prone incident has occurred and must be advised by the Commissioner of Health or his designee in making this finding. The hearing will be closed and the record sealed. The order of the district court may be appealed de novo to the circuit court of the same jurisdiction within ten days. The circuit court must also be advised by the Commissioner or his designee and any order of the such court will be final and nonappealable. Disclosure is made to the district health director who is charged with informing the parties of the test results and counseling them as required by Section 32.1-37.2. Test results are confidential. This provision also provides that persons known or suspected to be positive for infection with Hepatitis B or HIV cannot be refused services for that reason by any public safety agency personnel and that no new duty is created. Definitions of "exposure prone incident" and "public safety agency" are included. Virtually any entity with law enforcement powers, including campus police departments, as well as fire safety organizations, and correctional institutions are included pursuant to the definition of "public safety agency." This provision will expire on July 1, 1994. Law enforcement officers allege that, as first responders to traffic accidents as well as criminal activity, they are at risk for possible exposure to Hepatitis B and HIV. Exposure to these two viruses may occur in the same manner; however, Hepatitis B is more infectious than HIV. It must be noted that there are, to our knowledge, no known cases of work-related transmission of HIV among public safety agency personnel.

The exposed employee's blood shall be collected as soon as feasible after consent is obtained, and tested for HBV and HIV serological status. If the employee consents to baseline blood collection, but does not give consent at that time for HIV serologic testing, the sample shall be preserved for at least ninety (90) days. If, within ninety (90) days of the exposure incident, the employee elects to have the baseline sample tested, such testing shall be done as soon as feasible.

The exposed employee will be offered post-exposure prophylaxis, when medically indicated, as recommended by the U. S. Public Health Service. The exposed employee will be offered counseling and medical evaluation of any reported illnesses.

The following information will be provided to the healthcare professional evaluating an employee after an exposure:

• a copy of 1910.1030 bloodborne pathogens standard;
• a description of the exposed employee's duties as they relate to the exposure incident;
• the documentation of the route(s) of exposure and circumstances under which exposure occurred;
• results of the source individual's blood testing, if available;
• all medical records relevant to the appropriate treatment of the employee including vaccination status.

James Madison University shall obtain and provide the employee with a copy of the evaluating healthcare professional's written opinion within fifteen (15) days of the completion of the evaluation. The written opinion will be limited to the following information:

• the employee has been informed of the results of the evaluation;
• the employee has been told about any medical conditions resulting from exposure to blood or other potentially infectious materials which require further evaluation or treatment.

NOTE: All Other Findings Shall Remain Confidential And Shall Not Be Included In The Written Report.

EMPLOYEE TRAINING

Employees will be trained regarding bloodborne pathogens at the time of initial assignment to tasks where exposure may occur and annually, during work hours. Additional training will be provided whenever there are changes in tasks or procedures which affect employees' occupational exposure; this training will be limited to the new exposure situation.

The training approach will be tailored to the educational level, literacy, and language of the employees. The training plan will include an opportunity for employees to have their questions answered by the trainer.

The Chief of Campus Police or designee(s) are responsible for arranging and/or conducting training. A variety of methods may be used; e. g. lecture, demonstration, videotapes, and written materials.

The following content will be included:

1. explanation of the bloodborne pathogen standard;
2. general explanation of the epidemiology, modes of transmission and symptoms of bloodborne diseases;
3. explanation of this exposure control plan and how it will be implemented;
4. procedures which may expose employees to blood or other potentially infectious materials;
5. control methods that will be used at this facility to prevent/reduce the risk of exposure to blood or other potentially infectious materials;
6. explanation of the basis for selection of personal protective equipment;
7. information on the hepatitis B vaccination program including the benefits and safety of vaccination;
8. information on procedures to use in an emergency involving blood or other potentially infectious materials;
9. what procedure to follow if an exposure incident occurs;
10. explanation of post-exposure evaluation and follow-up procedures;
11. an explanation of warning labels and/or color coding.

RECORDKEEPING PROCEDURES

Procedures are in place for maintaining both medical and training records. If James Madison University should cease business, and there is no successor employer to receive and retain the records for the prescribed period, then the Director of the National Institute for Occupational Safety and Health (NIOSH) will be notified at least three months prior to the disposal of records. The records will be transmitted to NIOSH, if required by the Director, within the three month period.

Medical Recordkeeping A medical record will be established and maintained for each employee with exposure. The record shall be maintained for the duration of employment plus thirty (30) years in accordance with 29 CFR 1910.20. The position/person responsible for maintaining medical records is the Director of Employee Relations and Training, Mr. H. Guthrie Allen.

The record shall include the following:

• name and social security number of the employee;
• a copy of the employee's hepatitis B vaccination status with dates of hepatitis B vaccinations and any medical records relative to the employee's ability to receive vaccination;
• a copy of examination results, medical testing, and any follow-up procedures;
• a copy of the healthcare professional's written opinion;
• a copy of the information provided to the healthcare professional who evaluates the employee for suitability to receive hepatitis B vaccination prophylactically and/or after an exposure incident.

Confidentiality of Medical Records

The record will be kept confidential. The contents will not be disclosed or reported to any person within or outside the workplace without the employee's express written consent, except as required by law or regulation. Employee medical records required under 1910.1030 shall be provided upon request for examination and copying to the subject employee and to the Commissioner of the Virginia Department of Labor and Industry in accordance with 29 CFR 1910.20.

Training Records

Training records shall be maintained for three (3) years from the date on which the training occurred.

The following information shall be included:

• dates of training sessions;
• contents or a summary of the training sessions;
• names and qualifications of trainer(s); and
• names and job titles of all persons attending.

Training records shall be provided upon request for examination and copying to employees, to employee representatives, and to the Commissioner of the Virginia Department of Labor and Industry in accordance with 29 CFR 1910.20.

This Exposure Control Plan was Prepared by:
Alan D. MacNutt
Director of Public Safety
James Madison University