How should an exposure control plan address physical protection of employees?

OSHA Instruction CPL 2-2.60 March 7, 1994 Office of Occupational Medicine

SUBJECT: Exposure Control Plan for Federal OSHA Personnel with Occupational Exposure to Bloodborne Pathogens

A. Purpose. This instruction provides for uniform policy for protection of OSHA personnel who, as part of their job, face reasonably anticipated exposure to bloodborne pathogens.

B. Scope. This instruction applies OSHA-wide.

C. Cancellation. This instruction replaces the memorandum of December 11, 1992 regarding Hepatitis B vaccinations. That memorandum served as interim guidance while this Exposure Control Plan was under development.

D. References.

1. 29 CFR 1910.1030, Occupational Exposure to Bloodborne Pathogens.2. 29 CFR 1910.20, Access to Employee Exposure and Medical Records.

E. Action. OSHA Regional Administrators and Area Directors shall use this Plan to ensure that OSHA personnel who have occupational exposure to bloodborne pathogens are afforded protection in accordance with 29 CFR 1910.1030.

Joseph A. Dear Assistant Secretary

Distribution: National, Regional and Area Offices

OSHA INSTRUCTION CPL 2-2.60 March 7, 1994 Office of Occupational MedicineEXPOSURE CONTROL PLAN FOR FEDERAL OSHA PERSONNEL WITH OCCUPATIONAL EXPOSURE TO BLOODBORNE PATHOGENS

I. EXPOSURE DETERMINATION

All compliance officers who, as a result of performing their job duties, must engage in activities where exposure to blood or other potentially infectious materials is reasonably anticipated, are considered to have occupational exposure. Through interviews, surveys, and careful consideration of expected activities of compliance officers, certain groups of tasks have been identified as those where occupational exposure could be reasonably anticipated. These include handling equipment contaminated with blood or other potentially infectious materials (e.g., removing a personal sampling device that has become contaminated with blood); decontaminating pumps, lines, or other parts of equipment contaminated with blood; and handling or decontaminating charcoal sampling tubes or other devices which require the compliance officer to make contact with contaminated equipment for accomplishment of an investigation. Contamination of equipment may occur in some inspections related to bloodborne pathogens or waste anesthetic gases, as well as some inspections for other hazards (e.g., formaldehyde in funeral home inspections, checking personal protective equipment or safety equipment in explosions or other incidents where there has been wide contamination with blood or other potentially infectious materials).Compliance officers shall take necessary precautions to avoid direct contact with body fluids and shall, except when absolutely necessary for the performance of duties, not participate in activities nor enter areas that will require them to come into contact with body fluids, needles, or other instruments or surfaces that are contaminated with blood or other potentially infectious materials. Any procedure that can be avoided (e.g., kneeling in a pool of blood to get a close-up photo) is not to be undertaken. Moreover, even in cases of occupational exposure (e.g., unavoidable contact with contaminated sampling equipment that must be removed), extreme caution must be observed by the compliance officer.In cases where compliance officers must, as an essential part of their investigation, gather evidence or handle otherA-1

OSHA Instruction CPL 2-2.60 March 7, 1994 Office of Occupational Medicine

items that have become contaminated, or where they cannot avoid handling contaminated items, occupational exposure is reasonably anticipated. Compliance officers who must engage in such activities are therefore covered by this Plan.Area Directors, in consultation with Regional Administrators, will determine which employees will be assigned to tasks which could involve unavoidable occupational exposure. The extent to which a compliance officer's academic background, training, and experience may be related to such assignments will be considered. Where feasible, these tasks will be assigned to volunteers with backgrounds in the area of biologicals. In addition, such inspections should be assigned to a limited number of personnel. This procedure allows the compliance officer to develop expertise in performing such inspections. In addition, such an assignment pattern is needed for optimal utilization of training and medical resources.OSHA employees designated as First Aid Responders are also considered at risk of occupational exposure due to the nature of these duties (e.g., assisting bleeding victims, resuscitation) and are included in this Plan. Such responders generally would involve those compliance officers already conducting inspections with occupational exposure as well as a few personnel at the Salt Lake Technical Center.Finally, OSHA personnel who engage in clinical tasks such as drawing blood or other patient care duties (e.g., some OSHA medical officers) as part of their OSHA activities are at risk for occupational exposure and are included in this Plan.

II. METHODS OF IMPLEMENTATION

A. Methods of Compliance1. Universal PrecautionsOSHA personnel are not to handle contaminated objects unless absolutely necessary for performance of an inspection. For example, compliance officers shall not place hands in a trash can or laundry bag where regulated waste or contaminated laundry may be present.OSHA personnel shall use universal precautions (see Standard for definition) when contact with any bloodA-2OSHA Instruction CPL 2-2.60 March 7, 1994 Office of Occupational Medicineor other potentially infectious materials is absolutely necessary (e.g., removing a sampling device that has become contaminated with blood).2. Work Practice Controls a. Handwashing FacilitiesAntiseptic towelettes will be provided by the Regions to CSHOs with duties in Section I of this Plan. These towelettes are to be carried by compliance officers on inspections where soap and running water may not be immediately available (e.g., ambulance inspections) and used if contact of any skin surface with blood or other potentially infectious material occurs. Such towelettes should be disposed of as would any other trash except in a very rare circumstance where they would become contaminated to the extent (see standard) that they would be considered regulated waste. In such case, see section II.A.4 of this Plan. When such towelettes are used, hands or other skin surfaces cleansed using towelettes are to be washed as soon as feasible with soap and running water.Employees are to wash hands with soap and water as soon as feasible after removal of gloves. Employees are to wash hands and any other skin with soap and water, and flush mucous membranes with water, immediately or as soon as feasible following contact of those body areas with blood or any other potentially infectious material.b. Contaminated EquipmentIn order to prevent occupational exposure to Technical Center or other laboratory personnel, equipment and sampling media (e.g., charcoal tubes) that may become contaminated with blood or other potentially infectious materials are to be examined at the Area Office or other OSHA facility (e.g., Salt Lake Technical Center) prior to servicing or shipping and decontaminated (e.g., wiped off with bleach or other disinfectant, as determined by theA-3

OSHA Instruction CPL 2-2.60 March 7, 1994 Office of Occupational Medicine

Office Director) as necessary. All equipment that can be easily decontaminated at the Office level (e.g., wiped off) should be decontaminated there. Contaminated equipment or other contaminated items are not to be placed or stored in areas where food is kept, and decontamination should be accomplished as soon as possible following the inspection or incident where contamination occurred. Decontamination is not to take place in any area where food or drink is consumed. Cloths used to wipe contaminated equipment can be discarded as refuse unless they would somehow become contaminated to the extent that they would be considered regulated waste (see standard). In that case, see Section II.A.4 of this Plan. A biohazard label is to be attached to any large contaminated equipment and is to state which portions are or remain contaminated. For smaller pieces of equipment, the biohazard label should be attached as above, and the piece of equipment should be placed in a bag prior to shipping. The compliance officer shipping equipment that remains contaminated is to notify the receiving servicing center or manufacturer that contaminated equipment is being sent so that the receiving facility can take proper precautions upon the arrival of such equipment. In addition, the compliance officer should contact the transportation company that will be shipping the contaminated equipment regarding appropriate packaging for the item(s).3. Personal Protective EquipmentAlthough compliance officers are expected to avoid the handling of blood or other potentially infectious materials as well as contact with surfaces or items contaminated with such materials, some duties may make contact with such items unavoidable (See Section I). OSHA will provide appropriate gloves of proper size which the compliance officer will carry on those inspections where such activities, tasks, or procedures are likely to take place. Such gloves are to be replaced as soon as practical when contaminated or as soon as feasible if they become torn, punctured, or when their ability to function as a barrier appears to be compromised. These gloves are not to be washed or decontaminated for reuse.A-4OSHA Instruction CPL 2-2.60 March 7, 1994 Office of Occupational MedicineThe compliance officer is to determine the extent of contamination of gloves prior to their removal. If gloves can be considered regulated waste as defined in the Standard (a very rare circumstance), they are to be placed in a regulated waste container located in the facility inspected. It is possible that such a container may not be available (e.g., in a facility not in compliance with 29 CFR 1910.1030 regarding regulated waste). In this instance, see section II.A.4.First aid supplies to be used by designated First Aid Responders are to include disposable resuscitation masks as well as gloves. Such gloves will be available in the size(s) needed by those expected to function as First Aid Responders. Such equipment is to be used for the employee's protection in cases where the employee is expected to provide ventilatory assistance.It is not anticipated that compliance officers or other OSHA personnel will require personal protective equipment other than gloves. In situations where other equipment would be needed, it is expected that the compliance officer will avoid such areas. Should situations occur where such exposure would be necessary for one's job performance, this Plan will be revisited and appropriately amended.4. Regulated WasteOnly in rare circumstances is it anticipated that the duties of a compliance officer will generate regulated waste. For example, gloves which are worn to remove a personal sampling device which has become contaminated with blood from a mortuary procedure may rarely be contaminated to the extent that they are regulated waste. Such gloves are to be disposed of in the facility's nearest regulated waste container. If no such container is available at the facility, the compliance officer is to discard contaminated gloves and other regulated waste in an OSHA-supplied bag. Such bags will be supplied to compliance officers performing tasks and procedures where regulated waste could be generated (See Section I).A-5

OSHA Instruction CPL 2-2.60 March 7, 1994 Office of Occupational Medicine

Compliance officers are to note that regulated waste includes other materials contaminated to the extent that they can be defined as such in 29 CFR 1910.1030 (e.g., cloths used to clean contaminated sampling devices and which become saturated with blood). First aid supplies to be used by designated First Aid Responders are to include a bag to be used for containment of any regulated waste generated by the employee in the performance of first aid duties.The bag containing regulated waste is to be returned to the OSHA office or Technical Center by the employee, where the Office or Technical Center Director or designee will arrange for appropriate removal of such waste. Disposal of such waste is to be accomplished in accordance with applicable state and local laws. Where such laws require that the particular waste item be handled by a medical waste disposal company, the OSHA Office Director or designee will arrange for such disposal.The Salt Lake Technical Center Director or designee will provide containers in accordance with paragraph (d)(4)(iii)(A) for sharps disposal in areas where sharps are expected to be encountered and disposal is needed. B. Hepatitis B Vaccination and Post-exposure Evaluation and Follow-upOSHA offers the hepatitis B vaccine and vaccination series to personnel with duties specified in Section I. OSHA offers post-exposure evaluation and follow-up following an exposure incident to any employee who suffers an exposure incident while performing duties on the job at OSHA. All medical evaluations and procedures are to be made available at no cost to OSHA personnel, at a reasonable time and place, and under the other conditions set forth in 29 CFR 1910.1030(f).1. Hepatitis B VaccinationOSHA will make the hepatitis B vaccine available to employees at the Public Health Service facility where physical examinations are performed. In rare cases, anA-6OSHA Instruction CPL 2-2.60 March 7, 1994 Office of Occupational Medicine Area Office may be in a location that is remote from the nearest Public Health Service facility. If a compliance officer is not otherwise due to undergo a physical examination, the Area Director or designee in the remote location may determine that it is cost effective for the employee to be offered hepatitis B vaccinations at a local facility. In such case, the Area Director or designee, in consultation with the Regional Administrator and the Office of Occupational Medicine, is to make such arrangements.All OSHA employees whose job duties involve occupational exposure, (see Section I of this Plan) are to be offered the hepatitis B vaccination. The vaccine will be made available after the training required in 29 CFR 1910.1030 has been accomplished, and within 10 days of initial assignment of the employee to duties with occupational exposure. It is desirable that all employees with duties such as those described in Section I be immunized against hepatitis B. However, OSHA realizes that some personnel, even after training, may decline to receive the hepatitis B vaccine. In such case, the declining OSHA employee is to sign the declination statement which is Appendix A of 29 CFR 1910.1030 (see also Appendix B of this Plan). The employee can receive the vaccine after signing the declination statement if a change of mind occurs and if duties still involve those with occupational exposure. The Area Office Director or Technical Center Director or designee will assure that each employee scheduled for immunization at a Public Health Service facility is provided with the written opinion sample format in Appendix C of this Plan. Any employee receiving vaccination at another site is to be provided with both the written opinion sample format and a copy of the Standard (see Appendix C). These materials are to be taken by the employee to the evaluating physician for completion. The written opinion should be returned to the Office where the employee is assigned. A copy of medical records related to hepatitis B vaccination should be obtained by the compliance officer or first aid provider before departing the facility where vaccination takes place. The compliance officer should insert this copy of suchA-7

OSHA Instruction CPL 2-2.60 March 7, 1994 Office of Occupational Medicine

records in a copy of Appendix D. Appendix D should then be carried by the compliance officer on any inspection where occupational exposure could be reasonably anticipated. Should an exposure incident occur, Appendix D, including the hepatitis B related records, serves as the Materials for the Evaluating Physician and is to be given to the evaluating physician.2. Post-exposure Evaluation and Follow-upThe Area Director or designee will provide Materials for the Evaluating Physician found in Appendix D of this Plan to each compliance officer assigned duties discussed in Section I. Prior to each inspection involving such tasks, the compliance officer is to ensure that the materials to be taken on the inspection include the Materials for the Evaluating Physician (containing the hepatitis B vaccination-related records inserted by the compliance officer). This information is vital should an exposure incident occur. In anticipation of possible exposure incidents, The Area Director or designee shall instruct the compliance officer to seek medical attention in the same manner that it would be sought should any injury occur during an inspection (e.g., emergency room, physician's office, urgent care clinic). In the event of an exposure incident (as defined in 29 CFR 1910.1030), the OSHA employee is to immediately wash any skin with soap and water and flush mucous membranes with water when such areas have had contact with blood or other potentially infectious materials. The employee should then seek medical attention. It must be realized that any exposure incident is an event for which immediate attention must be sought, as the effectiveness of prophylaxis depends on the immediacy of its delivery. In addition, the employee who has had an exposure incident is to report such incident to his or her supervisor as soon as possible. The supervisor will inform the Area Director or designee (Technical Center Director or designee at SLTC) who will contact the facility where the exposure incident occurred as well as OSHA's Office of Occupational Medicine. The Area Director or designee is to work together with the facility, with theA-8OSHA Instruction CPL 2-2.60 March 7, 1994 Office of Occupational Medicineassistance of OOM if needed, to ascertain the source individual's identity, arrange for testing of the source individual, and communicate with the physician evaluating the OSHA employee.Following an exposure incident, an Exposure Incident Report (see Appendix D) will be completed by the OSHA employee. The completion of this report should be done in consultation with the supervisor when the supervisor is immediately available by telephone. In no instance should report completion and physician evaluation be delayed. The report is to be given by the employee to the evaluating physician. Report information will include (a) a description of the exposed employee's duties as they relate to the exposure incident; and (b) documentation of route(s) of exposure and circumstances under which exposure occurred. Through direct input by the employee, the evaluating physician is best able to understand exactly what exposure occurred and therefore direct treatment appropriately.3. Information Provided to the Evaluating PhysicianPost-exposure evaluation and follow-up are to be provided to the employee consistent with the requirements of 29 CFR 1910.1030. Therefore, upon presenting for evaluation, the employee will give to the physician the Materials for the Evaluating Physician (Appendix C of this Plan for Hepatitis B vaccination, Appendix D of this Plan for Evaluation following Exposure Incident). The instructions for the physician describe the requirements of 29 CFR 1910.1030 and instruct the physician to give the physician's written opinion to the employee to return to the supervisor. The office to which the employee is assigned will maintain the physician's written opinion. A copy of the actual evaluation results is to be returned by the physician to OSHA's Office of Occupational Medicine. The evaluation results will become a part of the compliance officer's confidential medical record maintained in the CSHO Medical Records Section. Records regarding any exposure incidents of Technical Center personnel will be maintained in a confidential manner as well in the Office of Occupational Medicine.A-9

OSHA Instruction CPL 2-2.60 March 7, 1994 Office of Occupational Medicine

C. Communication of Hazards to Employees1. Labels and BagsOSHA will provide biohazard labels to be affixed to bags containing any contaminated equipment until they can be returned to an OSHA office or shipped to another facility (see section II.A.2.b. of this Plan). Biohazard labels are to be carried by each compliance officer performing an inspection where contamination of equipment is likely.OSHA will provide appropriate bags for containment of any regulated waste or contaminated equipment generated by compliance officers performing procedures in section I of this Plan. A bag and biohazard labels are to be carried by the compliance officer when there is any question of appropriate handling of regulated waste by the facility undergoing inspection or when contamination of equipment is reasonably anticipated.In addition, a bag and biohazard labels will be provided in any First Aid kit expected to be used by designated First Aid Responders.Bags will be disposed of as ordinary refuse unless in the rare instance when they are contaminated to the extent that they are considered regulated waste as defined by the standard. In such case, see Section II.A.4 of this Plan.2. Information and TrainingPersonnel whose job duties involve occupational exposure, as specified in section I of this Plan are to participate in OSHA's training program for bloodborne pathogens at the time of initial assignment to tasks where occupational exposure occurs. The training program contains all the elements specified in 29 CFR 1910.1030(g)(2). OSHA uses a train the trainer approach in bloodborne pathogens, whereby at least one representative from each OSHA Region participates in bloodborne pathogens training at the OSHA Training Institute. After OTI training, the regional representatives conduct training sessions for other OSHA personnel covered by this Plan in their Regions.A-10OSHA Instruction CPL 2-2.60 March 7, 1994 Office of Occupational MedicineThe OTI course is conducted by a combination of health care professionals and nonhealth care professionals with expertise in the standard. Personnel participating in the OTI training course who will function as solitary trainers at the Regional or Area Offices or other OSHA facilities must have a biological sciences background. Such prior background enables the trainer to answer questions that arise in the interactive component of bloodborne pathogens training. Other OSHA or contract personnel (e.g., physicians or occupational health nurses) may provide training assistance as needed. In addition, the Area Director or designee will determine where site- specific training is needed and will ensure that such training is provided.Training will be conducted on an annual basis, and Office Directors will ensure that updates are given when there are changes in duties or procedures.D. Recordkeeping1. Medical RecordsMedical records are to be maintained by the Office of Occupational Medicine, CSHO Medical Records section, as part of the medical files of compliance officers. Such records are maintained in accordance with 29 CFR 1910.20 and are kept confidential.In the case of certain personnel (e.g., chemists who are also designated First Aid Responders) at the Salt Lake Technical Center, medical records will be maintained along with other medical records at the Public Health Service facility which provides service to the Salt Lake Technical Center. A copy will be maintained confidentially in the Office of Occupational Medicine.2. Training RecordsTraining records are to contain all information specified in 29 CFR 1910.1030(h)(2) and will be maintained for 3 years from the date on which the training occurred. Training records will be held by the OSHA Office or location at which training tookA-11

OSHA Instruction CPL 2-2.60 March 7, 1994 Office of Occupational Medicine

place (e.g., OTI will maintain records of training at OTI, while area offices will maintain records of training at those locations).3. Transfer of RecordsOSHA will comply with the requirements of 29 CFR 1910.20(h) involving any transfer of records.Exposure incident records will remain at the Office where the employee was assigned when the incident occurred, with a copy sent to the Office of Occupational Medicine. The employee may request and receive a copy of such records when transferring to another assignment.

III. EVALUATION OF CIRCUMSTANCES SURROUNDING AN EXPOSURE INCIDENT

The evaluation of circumstances surrounding an exposure incident is to be done by the Area Director or designee from the Area Office where the covered employee is assigned. If a First Aid Responder is assigned to the Salt Lake Technical Center, the Technical Center Director or designee will evaluate the circumstances surrounding the exposure incident. This evaluation will consist of at least:(a) a review of the Exposure Incident Report completed by the OSHA employee;(b) documentation regarding a plan to reduce the likelihood of a future similar exposure incident; and(c) notification of the Office of Occupational Medicine and discussion of any similar incidents and planned precautions.Such reports will be maintained in the Area Office or Technical Center (where employee is assigned), and a copy is to be sent to the Office of Occupational Medicine (OOM). OOM will review these reports on a periodic basis so that reported information can be considered in the review and update of this Plan. In addition, OOM will issue an alert to the Regions should similar incidents or trends among Regions be noted so that further incidents can be anticipated and prevented.A-12OSHA Instruction CPL 2-2.60 March 7, 1994 Office of Occupational MedicineAPPENDIX B

_______________________________________________________________________

| | | DECLINATION STATEMENT | | | | I understand that due to my occupational exposure to blood or | | other potentially infectious materials I may be at risk of | | acquiring Hepatitis B virus (HBV) infection. I have been given | | the opportunity to be vaccinated with Hepatitis B vaccine, at no | | charge to myself. However, I decline Hepatitis vaccination at this | | time. I understand that by declining this vaccine, I continue to | | be at risk of acquiring Hepatitis B, a serious disease. If in the | | future continue to have occupational exposure to blood or other | | potentially infectious materials and I want to be vaccinated with | | Hepatitis B vaccine, I can receive the vaccination series | | at no charge to me. | | | | | | | | | | ______________________________ ________________________ | | Employee Signature date | | | | | | | |_______________________________________________________________________|

B-1OSHA Instruction CPL 2-2.60 March 7, 1994 Office of Occupational MedicineAPPENDIX CWRITTEN OPINION

To the Evaluating Physician:

After you have determined whether there are contra indications to vaccination of this OSHA employee with Hepatitis B vaccine, please state in the space below only (A) if vaccine was indicated (B) if vaccine was received

(All other findings are to remain confidential and are not to be included on this page)

Please return this sheet to this employee,______________________.

(name of employee)

Thank you for your evaluation of this employee.

__________________________________

physician's signature

__________________________________ __________________________

physician's name (printed) dateC-1OSHA Instruction CPL 2-2.60 March 7, 1994 Office of Occupational Medicine

The rest of the text for Appendix C can be found in the December 6, 1991 issue of the Federal Register. (FR 56:64175-64182)

C-2OSHA Instruction CPL 2-2.60 March 7, 1994 Office of Occupational Medicine APPENDIX DINSTRUCTIONS FOR THE EVALUATING PHYSICIAN

This OSHA employee may have suffered an exposure incident as defined in the Bloodborne Pathogens Standard. In accordance with the standard's provision for post exposure evaluation and follow up, the employee presents to you for evaluation. Included to assist you in this evaluation are:

(A) A copy of 29 CFR 1910.1030, Occupational Exposure to Bloodborne Pathogens;

(B) A description of the exposed employee's duties as they relate to the exposure incident;

(C) Documentation of the routes of exposure and circumstances under which exposure occurred;

(D) Results of the source individual's blood testing, if available; and (E) All medical records relevant to this employee's appropriate treatment, including vaccination status.

After completing the evaluation, please:

(A) Inform the employee regarding the evaluation results and any follow up needed;

(B) Complete the attached written opinion form and give it to the employee. (This form will be maintained in the office to which the employee is assigned); and

(C) Send a copy of all evaluation results and records to:

U.S. Department of Labor - OSHA Office of Occupational Medicine Room N3653 200 Constitution Avenue, NW Washington, DC 20210CONFIDENTIAL: MEDICAL RECORDSThese copies will be maintained as part of the employee's confidential medical record in OSHA's Office of Occupational Medicine Medical Records Section.

Should you have any questions regarding the evaluations or medical records, please contact OSHA's Office of Occupational Medicine at (202) 219-5003.

D-1

OSHA Instruction CPL 2-2.60 March 7, 1994 Office of Occupational Medicine

The rest of the text for Appendix D can be found in the December 6, 1991 issue of the Federal Register. (FR 56:64175-64182)

D-2OSHA Instruction CPL 2-2.60 March 7, 1994 Office of Occupational MedicineEXPOSURE INCIDENT REPORT
           (Routes and Circumstances of Exposure Incident)
                         Please Print

Employee's Name_________________________________Date______________

Date of Birth__________________SS#________________________________

Telephone (Business) ______________ (Home)________________________

Job Title__________________________________________________________

Date of Exposure___________ Time of Exposure _______ AM___PM______

Hepatitis B Vaccination Status_____________________________________

Location of Incident_______________________________________________

Describe what job duties you were performing when the exposure incident occurred__________________________________________________

___________________________________________________________________

Describe the circumstances under which the exposure incident occurred (what happened that resulted in the incident)_____________

___________________________________________________________________

___________________________________________________________________

What body fluid(s) were you exposed to?____________________________

___________________________________________________________________

What was the route of exposure (e.g., mucosal contact, contact with nonintact skin, percutaneous)?________________________________

___________________________________________________________________

Describe any personal protective equipment in use at time of exposure incident__________________________________________________

___________________________________________________________________

Did PPE fail?____________If yes, how?______________________________

___________________________________________________________________

Identification of source individual(s) (names) ____________________

___________________________________________________________________

Other pertinent information________________________________________

___________________________________________________________________

D-13BLANK D-14OSHA Instruction CPL 2-2.60 March 7, 1994 Office of Occupational MedicineTO THE EMPLOYEE:INSERT COPY OF YOURHEPATITIS B VACCINATION RECORDSANDOTHER RELEVANT MEDICAL RECORDSHERED-15BLANKD-16OSHA Instruction CPL 2-2.60 March 7, 1994 Office of Occupational MedicineWRITTEN OPINION

To the Evaluating Physician:

After your evaluation of this OSHA employee, please assure that the following information has been furnished to the employee and provide your initials beside the following statements:

(A) ___________The employee has been informed of the results

of this evaluation.

(B) ___________The employee has been told about any medical

conditions resulting from exposure to blood or other potentially infectious materials which require further evaluation and treatment.

No other findings are to be included on this report.

Please return this sheet to this employee,_____________________

(name of employee)

Thank you for your evaluation of this employee.

___________________________________

physician's signature

___________________________________ ______________________

physician's name (printed) dateD-17OSHA Instruction CPL 2-2.60 March 7, 1994 Office of Occupational MedicineAPPENDIX ESUPPLIES FOR COMPLIANCE OFFICERS

Prior to departing for an inspection where occupational exposure to blood or other potentially infectious materials is reasonably anticipated, the CSHO should have the following materials to carry on the inspection:

1. At least 2 bags (for containment of any regulated waste that cannot be disposed of on site or for contaminated equipment)

2. Biohazard labels (at least 2 for purposes above)

3. Gloves of appropriate material and size (at least 2 pairs)

4. Materials for the evaluating physician

In addition, if the CSHO is inspecting a site where running water may not be available (e.g., an ambulance), antiseptictowelettes should be carried.

FIRST AID SUPPLIES

In addition to supplies for rendering first aid assistance, first aid kits should contain:

1. Disposable resuscitation mask

2. Gloves of sizes needed by personnel performing first aid

3. Bags (at least 2)

4. Biohazard labels (at least 2)

In addition, if first aid assistance is expected to be rendered at a site where running water may not be available, antiseptic towelettes should be included in the first aid kit.

E-1

What other key areas should be contained in an exposure control plan?

Elements of an Exposure Control Plan.
Statement of purpose..
Responsibilities of the owner, prime, employer, designated resources (i.e. H&S Manager), supervisors, and workers..
Health hazards and risk categories for each product in your worksite..
Written work procedures and practices..

What are the 5 steps of an exposure control plan?

Contact the Office of Risk Management for questions..
Step 1: Required Personal Protective Equipment. ... .
Step 2: Equipment. ... .
Step 3: Decontamination Procedures. ... .
Step 4: Disposal. ... .
Step 5: Decontaminate Re-useable Equipment. ... .
Step 6: Wash Your Hands..

What is the purpose of an exposure control plan?

Exposure Control Plan (ECP) — written procedures that specify the methods used to reduce exposures to bloodborne pathogens and treat individuals who may have been exposed to bloodborne pathogens.

What does exposure control plan consist of?

The Exposure Control Plan consists of the employer's policy and procedures, defining the protective measures that will be taken by the employer to eliminate or minimize any risk of employee exposure to blood, bodily fluids or other potentially infectious material (OPIM).