There Will Be Blood Employers Should Protect First Responders with an Exposure Control Plan

First responders face unique scenarios due to uncontrolled settings and the possible presence of large volumes of blood at the scene. Exposure risk is heightened in chaotic work situations with uncooperative patients or suspects.

These workers can be easily exposed to blood and other potentially infectious body fluids in their jobs. Emergency responders may perform urgent, invasive procedures on unstable patients, treat open wounds, and stop bleeding. Law enforcement officers may encounter used needles or be assaulted. These events put them at increased risk for contracting bloodborne pathogen infections, including hepatitis B virus, hepatitis C virus, and human immunodeficiency virus (HIV) infections.

For employers of these workers, a comprehensive exposure-prevention program for bloodborne pathogens will help protect employees. One component of such a program is a written exposure control plan.

For many companies, these plans are required by the federal Occupational Safety and Health Administration (OSHA) Bloodborne Pathogens Standard. In addition, local regulations, employer policy, or collective bargaining agreements may call for such a program.

Plan of Action

An exposure control plan is the focal point of any exposure-prevention program for bloodborne pathogens. It details in writing a company’s plan for reducing exposures to bloodborne pathogens and explains what steps to take when an exposure occurs. The plan specifies all steps taken to protect workers.

Why is this important? First — and most important — an exposure control plan helps protect frontline workers from exposure to bloodborne pathogens. Second, if workers are at risk for exposure, the law might require a written plan.

Third, the costs of an exposure incident can be significant, including post-exposure treatment and counseling, as well as loss of employee work time. If an employee does contract an illness, costs can dramatically escalate due to increased workers’ compensation, lost work time, training of a replacement, etc. The plan helps control these costs by reducing exposures to bloodborne pathogens in the first place.

The written policy for protecting employees from bloodborne pathogens exposures includes:

A designated individual responsible for administering the plan;
A list of job classifications where employees may be exposed;
Hepatitis B virus vaccination provisions;
Employee training (initial and annual);
Methods for control of bloodborne pathogens;
Universal precautions;
Engineering controls (e.g., safety devices and sharps containers);
Work practice controls (e.g., sharps handling and disposal, handwashing, cleanup);
Personal protective equipment (e.g., disposable gloves or face shields);
Housekeeping protocols;
Post-exposure reporting, evaluation, counseling, and follow-up procedures;
Procedures for evaluating circumstances surrounding an exposure incident; and
Record keeping, including sharps injury logs, training records, and annual plan updates.
The exposure control plan should include a description of how each department meets the basic elements. The plan may also cover additional topics, such as how volunteers are protected.

Tips for Improving the Exposure Control Plan

The National Institute for Occupation-al Safety and Health (NIOSH) has identified a number of problems with exposure control plans at emergency medical services and fire and police departments. Here are some tips on how to avoid these problems.

Make sure the plan is in writing and updated annually.
Tell current workers where the plan is located. Also, during initial and annual bloodborne pathogens training, tell workers about the plan and where they can find it.
Designate a person to implement the plan.
Do an ‘employee exposure determination.’ Make one list of job titles in which all employees have reasonably anticipated contact with blood or other potentially infectious materials, and another list of job titles where specified tasks or procedures put some employees at risk of exposure.
Provide safety devices engineered to prevent needle sticks and other sharps injuries to employees who use these devices. The use of these devices will help prevent exposures to blood.
Involve frontline employees in the evaluation and selection of safety devices. Document the selection process in the exposure control plan.
Specify work practices to control exposures to bloodborne pathogens. For example, the plan should cover decontamination of work surfaces and equipment and inspection and replacement of sharps disposal containers, including who is responsible for doing these tasks.
Provide guidelines on when and how to use different types of personal protective equipment, including disposable gloves, other protective clothing, face and eye protection, and ventilation devices. Under normal conditions, such equipment should not permit blood or body fluids to reach the workers’ skin, eyes, mouth, outer clothing, or undergarments.
Encourage hepatitis B protection. Offer the vaccination series at no cost to employees after required training, which includes information on the vaccine. Vaccination is encouraged unless the employee has been previously vaccinated, is immune, or vaccination is not medically indicated. The plan must also designate someone responsible for the vaccination program and include a vaccination declination form.
Let employees know the procedure for reporting exposures, and have a plan for immediate medical evaluation and follow-up.
This information is provided by the National Institute for Occupational Safety and Health.

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