Bloodborne Pathogens

Exposure Control Plan

Required elements:

1. Exposure determination identifying job classifications with occupational exposure and the specific tasks/procedures where exposure occurs.
2. Procedures for evaluating circumstances of exposure incidents.
3. A schedule of how other provisions of the BBP standard are implemented.  Methods of compliance include:
   1. Universal Precautions
   2. Engineering and work practice controls
   3. PPE
   4. Housekeeping (decon. & waste removal)
4. Documentation of:
   1. Annual consideration/implementation of safer medical devices
   2. Solicitation of non-managerial employees representing all areas where exposure can occur in updating engineering and work practice controls.
5. Reviewed and updated annually and when tasks/procedures/positions change.

Removing BBP

Sources of Terminology

• http://www.cdc.gov/oralhealth/infectioncontrol/glossary.htm
• http://www.midsussex.gov.uk/8172.htm?pageID=1783
• Wikipedia

Terms Related to Removal of BBP

Surfaces (non-living)	Living Tissue	Both
Disinfectants	Antibiotics	Biocides
Sanitizers	Antiseptics
Sterilization

Sterilization  >  Disinfection  ≈  Sanitization

Sterilization

• Destroys all microorganisms including large numbers of resistant bacterial spores.

Disinfection

• Destroys most microorganisms but not necessarily all microbial forms, such as bacterial spores.

Sanitization

• Combination of cleaning and disinfecting the surface.

Types of Removing Agents

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• http://www.health.ny.gov/professionals/protocols_and_guidelines/antibiotic_resistance/docs/hospital_disinfectants_for_general_disinfection_of_environmental_surfaces.pdf

Modifications to the BBP standard required under the Needlestick Safety and Prevention Act

Categorized into four categories:

1. Modification of definitions relating to engineering controls;
2. Revision and updating of the Exposure Control Plan;
3. Solicitation of employee input; and
4. Recordkeeping

1.  Modification of definitions relating to engineering controls

• Added "Sharps with Engineered Sharps Injury Protections"
• Added "Needleless Systems"
• Modified "Engineering Controls" by adding "safer medical devices…."

2.  Revision and updating of the Exposure Control Plan

• During annual review and update of the ECP, consider new technology that may be safer and document this consideration and, if applicable, implementation.

3.  Solicitation of employee input

• Solicit non-managerial  employees who are responsible for direct patient care for input on engineering controls and work practice controls.
• Not all employees but a representation of all ranges of exposure types.
• Document this solicitation.

4.  Recordkeeping

• Require a sharps injury log; except for those not required to keep injury and illness logs (OSHA-300/301).
• Minimum info: Device involved, location of incident, description of events
• Log can contain personal info but only if employee's personal info is withheld when sharing data with other parties.
• No specific format required.
• OSHA-300 logs and 301 forms can be used as long as:
  • Type and brand of device is included (either 300 or 301)
  • Recorded in such a way that it segregates sharps sticks from other illness/injuries; or allows them to be easily separated (e.g., computer filter; separate page of paper; etc.)
• 1904.8 already requires sharps injuries involving contaminated instruments to be recorded in 300/301 forms.

Miscellaneous

• If any potentially infectious material is released on to a surface that may be contacted by employees, that surface must be disinfected. (Diane's email 1/29/2014)