1.    Methods of Compliance
2.    Standard Precautions
3.    Engineering Controls
4.    Work Practice Controls
5.    Personal Protective Equipment
6.    Housekeeping

METHODS OF COMPLIANCE

We understand that there are a number of areas that must be addressed in order to effectively eliminate or minimize exposure to bloodborne pathogens in our facility.   The first five areas we deal with in our plan are:

By rigorously following the requirements of OSHA's Bloodborne Pathogens Standard in these five areas, we feel that we will eliminate or minimize our employees exposure to bloodborne pathogens as much as possible.

UNIVERSAL PRECAUTIONS

In our facility, we have observed the practice of "Universal Precautions" to prevent contact with blood and other potentially infectious materials since August 1, 1992.  As a result, we treat all human blood and the following body fluids as if they are known to be infectious for HBV, HIV, and other bloodborne pathogens:

In circumstances where it is difficult or impossible to differentiate body fluid types (i.e., blood tinged fluids), we assume all body fluids to be potentially infectious.

ENGINEERING CONTROLS

One of the key aspects to our Exposure Control Plan is the use of Engineering Controls to eliminate or minimize employee exposure to bloodborne pathogens.  As a result, our facility employs equipment, such as sharps disposal containers, and ventilating laboratory hoods as appropriate.

The following engineering controls are used, when needed, throughout the facility.

(See procedures for the safe disposal of biohazardous waste)

WORK PRACTICE CONTROLS

In addition to engineering controls, our facility uses a number of Work Practice Controls to help eliminate or minimize employee exposure to bloodborne pathogens.   Many of these Work Practice Controls have been in effect for some time.

Our facility has adopted the following Work Practice Controls as part of our Bloodborne Pathogens Compliance Program:

Engineering controls and work practice controls will be examined and maintained or replaced on a regular schedule.  The schedule for reviewing the effectiveness of the controls is the responsibility of Laboratory Supervisors/Department Supervisors.  This facility will also identify the need for changes in these controls through OSHA logs and accident reviews and investigations.  Evaluations will identify:

Sharps with engineered sharps injury protection and needleless systems are required by OSHA when there is the potential for a bloodborne pathogens exposure. When necessary, University personnel or departments evaluate devices for effectiveness in reducing the risk of exposure incidents. Where possible, alternatives must be utilized and if the elimination of needle-bearing devices is not possible, needle devices with safety features will be evaluated.  Methods for evaluation may include interviews, questionnaires or trial runs. Examples of Safe Needle Devices

(See procedures for biohazard control in our Biosafety Manual)

PERSONAL PROTECTIVE EQUIPMENT

Personal protective equipment is our employees' "last line of defense" against bloodborne pathogens.  Because of this, our facility provides (at no cost to our employees) the Personal Protective Equipment that they need to protect themselves against such exposure.  This equipment includes, but is not limited to:

Hypoallergenic gloves, glove liners and similar alternatives will be made available to employees who are allergic to the gloves our facility normally provides.

Laboratory Supervisors and Department Supervisors will ensure that personal protective equipment is provided and worn by employees as needed and that training in the proper wearing and use of such equipment is provided.  Contact the EHRS Department if additional help is required.  Supervisors must consult with the EHRS Department for assistance with the selection and training of employees for the use of non-routine personal protective equipment such as respirators. 

To ensure that personal protective equipment is not contaminated and is in the appropriate condition to protect employees from potential exposure, our facility adheres to the following practices:

To make sure that this equipment is used as effectively as possible, our employees adhere to the following practices when using their personal protective equipment:

(See additional information on Personal Protective Equipment in the Safety Manual)

HOUSEKEEPING

Maintaining our facility in a clean and sanitary condition is an important part of our Bloodborne Pathogens Compliance Program.  The schedule for cleaning floors, bathrooms, hallways, residence halls, offices and general use areas is maintained by the Facilities Services Department.

Special use areas, i.e., the laboratory or chemical, radioactive and biohazard storage areas, are cleaned only after consultation with the individual responsible for that area.  

The following practices will be carried out by the individuals directly responsible for the laboratory and hazardous substance storage areas.

The Laboratory Supervisor/Department Supervisor shall ensure that the laboratory or area of responsibility is maintained in a clean and sanitary fashion and shall establish decontamination procedures.  A 1:10 or 1:100 dilution of household bleach made fresh daily may be used. However, this may be corrosive to some equipment and environmental surfaces and therefore, may not be an appropriate choice for all situations.  Call the EHRS Department if further assistance is needed. 

We are also very careful in our facility in handling regulated waste, including contaminated sharps, used bandages and other potentially infectious material.   The following procedures are used with all of these types of wastes:

The EHRS Department is responsible for the collection and disposal of our facility's contaminated waste.

(See additional information on biohazardous waste from the Biosafety Manual)


University of the Sciences in Philadelphia • 600 South Forty-third Street • Philadelphia, PA 19104-4495 • phone: 215-596-8800 • email: safety@usp.edu