Exposure Control Plan

  • Purpose: The Mountain Brook City School System is committed to providing a safe and healthful work environment for our entire staff. In pursuit of this endeavor, the following exposure control plan (ECP) is provided to eliminate or minimize occupational exposure to blood-borne pathogens.

    Table of Contents:

    Program Administration Determination of employee exposure Implementation of various methods of exposure control:

    Standard precautions, Engineering and work practice controls, Personal Protective Equipment, Housekeeping,Hepatitis B vaccination, Post-exposure evaluation follow-up and record-keeping, Employee Training


    A. Documentation of Annual Training

    B. Proper hand Washing Technique

    C. Guidelines for Personal Protective Devices

    D. Safe Glove Use

    E. Latex Allergies

    F. Post exposure Incident Report

    G. Healthcare Professional’s Written Opinion

    H. Resources Program Administration .

    Amanda Hood  is responsible for the implementation of the ECP. The Administrative Team will maintain, review, and update the ECP at least annually, and whenever necessary to include new or modified tasks and procedures.

    Employees who are determined to have occupational exposure to blood or other potentially infectious materials(OPIM) will be instructed to comply with the procedures and work practices outlined in this ECP.

    The school system nurse will make available all necessary personal protective equipment (PPE), engineering controls, labels and red bags as required by ADEM. The school system nurse will ensure that adequate supplies of the aforementioned equipment are available in the appropriate sizes. Contact location/phone number: 205-802-4992.

    Each School Administrator/ School Nurse will be responsible for training, documentation of training, and making the written ECP available to employees.
    Employee Exposure Determination

    Definition: Occupational exposure-reasonably anticipated skin, eye, mucous membrane, or parenteral (through the skin) contact with blood or other potentially infectious materials that may result from the performance of an employee’s duties.

    Text Box: Job Title Tasks/Risks
Administrators, Teachers, Coaches, Security Officers, Clerical Staff, Aides, and Bus Drivers Providing assistance to students with bleeding or other potentially infectious materials injuries, CPR, and seizure precautions. Controlling combative behavior. Crisis management interventions.
Special Education Teachers and Aides In addition to the responsibilities listed for teachers, toileting, feeding, changing menstrual pads, tooth brushing, cleaning nose and mouth secretions. Controlling combative behavior.
Speech Therapists Cleaning nose and mouth secretions, biting, controlling combative behavior, delivering first aid. Controlling combative behavior.
Physical and Occupational Therapists Assisting with tooth brushing, providing assistance to students with bleeding or other potentially infectious materials injuries, and controlling combative behavior.
Child nutrition personnel Providing assistance to students with bleeding or other potentially infectious materials injuries.
Maintenance personnel Maintaining and repairing equipment and facilities, including sewage lines and plumbing equipment, contaminated with potentially infectious materials and

    Text Box: providing first aid.
Custodians Cleaning spills and surfaces possibly containing blood and/or body fluids and disposing of garbage and waste materials containing potentially infectious body fluids. Cleaning sewage overflow
School Nurse Providing nursing procedures such as administering injections; checking blood glucose; providing assistance to students with bleeding or other potentially infectious materials injuries, tracheostomy and catheter care; administering tube feedings, performing CPR and crisis management intervention.


    Methods of Implementation and Control Standard Precautions:

    All employees will utilize standard precautions.

    Engineering Controls-supplies and facilities needed to create a safe work environment.

    1. Hand washing facilities (running water, soap and paper towels) or hand sanitizer will be readily accessible to employees and students.
    2. Antiseptic hand cleaners will be provided when hand washing facilities are not available (field trips and school buses).
    3. Puncture proof, disposable, labeled containers will be used to dispose of needles, syringes and sharps.
    4. Disposable, single-use gloves will be provided to all staff, regardless of their potential for exposure.
    5. CPR mouth shields will be provided to designated CPR responders, as well as office staff and school nurse.
    6. Other personal, disposable, single-use protection equipment will be provided as required by specific tasks.
    7. Appropriate disinfectants, supplies and equipment to clean surfaces and waste receptacles will be provided.
    8. Disposable, plastic liners will be provided for waste receptacles, including those placed inside bathroom stalls.
    9. School buses will be equipped with first aid and body fluid kits.


    Work Practice Controls-behaviors employees adopt and practice that are necessary to create and maintain a safe work environment.

    1. All employees will immediately wash their hands after removal of disposable gloves or other personal protection equipment; after assisting with toileting of students; and before handling food.
    2. Protective equipment such as disposable gloves will be worn when handling any contaminated surface or body fluid and discarded after each use.
    3. Contaminated needles, lancets and other sharps will not be recapped or bent.
    4. All medical waste will be disposed of in compliance with the Medical Waste Plan.
    5. Plastic liners will not be reused in waste receptacles once removed.
    6. Employees will immediately report all exposure incidents to the principal. The principal will notify the parent/guardian of exposure incidents involving students.
    7. Any disposable item contaminated with blood or other body fluids will be double bagged prior to discarding.
    Personal Protective Equipment:

    PPE will be made available to employees at no cost to them. The types of PPE available to employees are as follows: Gloves, eye protection, masks, plastic aprons, CPR masks. PPE is located in each schools office and may be obtained through the School Nurse.

    All employees using PPE must observe the following precautions:

    • Wash hand immediately or as soon as feasible after removal of gloves or other PPE.
    • Remove PPE after it becomes contaminated, and before leaving the work area.
    • Used(contaminated) PPE may be disposed of in regular trash cans provided it is doubled bagged.
    • Wear appropriate gloves when it can be reasonable anticipated that there may be hand contact with blood or OPIM, and when handling or touching contaminated items or surfaces: replace gloves if torn, punctured, contaminated, or if their ability to function as a barrier is compromised.
    • Utility gloves may be decontaminated for reuse if their integrity is not compromised; discard utility gloves if they show signs of cracking, peeling, tearing, puncturing, or deterioration.
    • Never wash or decontaminate disposable gloves for reuse.
    • Wear appropriated face and eye protection when splashes, sprays, spatters, or droplets of blood or OPIM pose a hazard to the eye, nose, or mouth.
    • Remove immediately or as soon as feasible any garment contaminated by blood or OPIM, in such a way as to avoid contact with the outer surface.


    Medical Waste will be stored and disposed of in accordance to the Medical Waste Management Plan.

    Procedures for working around potentially infection material will be established and made available to all custodial and maintenance personnel.

    Hepatitis B Vaccination:

    Employees will be provided training on hepatitis B vaccinations, addressing the safety, benefits, efficacy, methods of administration and availability. Hepatitis B vaccine is currently recommended for healthcare workers and public-safety workers who have exposure to blood in the workplace, persons in training in schools of medicine, dentistry, nursing, laboratory technology and other allied health professions, by the Centers for Disease Control.
    The hepatitis B vaccination series is available to employees through their primary care physician according to their medical insurance program guidelines.

    Documentation for hepatitis B Vaccine will be maintained on all health care workers employed by the Mountain Brook School System.

    Post-­Exposure Evaluation and Follow­up

    1. Recognize and exposure/contact has occurred. (If uncertain assume an incident has occurred and continue procedure)
    2. Immediately wash hands and any other body surface exposed with soap and water. Flush exposed mucous membranes (mouth or eyes) with copious amounts of water.
    3.   Notify School administrator or extended day program director of the incident and individuals involved.
    4. Notify school nurse of incident.
    5. Comply with further guidance form administrator and school nurse with regard to further action as determined by the incident and individuals involved.

     Procedure for Administrator/School Nurse:

    For Student to Student Exposures:
    1. Contact parent/guardian of each Student.
    2. Meet with parent/guardian of students separately to maintain confidentiality.
    3. Refer to private physician for medical follow-up.
    4. Complete Exposure Incident Report and Evaluation.
     For Employee to Student Exposures:

    1. Contact and meet with the parent/guardian of the student
    2. Refer the student to their private physician for medical follow-up.
    3. Meet with the employee/the option for disclosure of personal medical information to the parent/guardian is at the employee’s discretion. If the employee agrees to have testing to reassure the parent/guardian, the cost of testing shall be handled according to the medical insurance program guidelines and release of the information is up to the employee.

    Complete Exposure Incident Report and Evaluation.

    ReFor Student to Employee Exposure: 1. Refer the employee to their private physician or the Jefferson County Department of Public Health.


    1                 Request a Healthcare Professional’s Written Opinion: Post-Exposure Evaluation and Follow-up.

    2                 Complete Exposure Incident Report and Evaluation.

    3                 File Healthcare Professional’s Written Opinion: Post Exposure Evaluation and Follow-up Report in the employee’s personnel file.


    Employee-to Employee Exposures: Follow same procedure for Student to Employee Exposures.

    For Exposures of Volunteers or Others in the School Environment who are not employees, students, or contract personnel:

    1                 Refer individuals to their private physician/The Jefferson County Health Department for medical follow-up.

    2                 Complete Exposure Incident Report and


    Evaluation. For Volunteer/Other to Student Exposures:

    1                 Contact the Parent/Guardian of the incident involving the student.

    2                 Proceed as thought it is an Employee to Student Exposure (Note: medical expenses are the responsibilities of the individual parties.)

    3                 Contract personnel medical expenses are the responsibility of the individual, however, the Healthcare Professional’s Written Opinion Post-Exposure Evaluation and Follow-up document is required for the personnel file of the contracted individual.


    Phone Number for the Jefferson County Department of Public Health: (205)933-9110

    The program administrator and the school system nurse should be notified of all exposure incidents.

    Documentation of exposure incidents, training, Hepatitis B vaccinations, and Health Professional’s Written Opinions will be recorded and stored according to state guidelines. Training records will be kept for a three year period. Hepatitis B vaccination records and waivers, post-exposure incidents, and Health Professional’s Written Opinions will be maintained 30 years post-employment.

    Confidentiality will be strictly protected for those involved in exposure incidents.

    Employee Training

    Annual training will be provided to all school personnel to improve their knowledge and work practice controls regarding prevention and avoidance of exposure to blood borne pathogens in the workplace. The current Communicable Disease/HIV policy and Exposure Control Plan will be made available to all employees.

    Appendix A


    I acknowledge that I have received training and information regarding the following topics:

                      Location of Exposure Control Plan

                      Obtaining a copy of the Exposure Plan

                      Epidemiology and transmission of blood borne pathogens

                      Recognizing activities with exposure potential

                      Methods and practices to prevent or reduce exposure

                      Engineering controls, work practice controls, and protective equipment

                      Proper medical waste handling and disposal procedures

                      Hepatitis B Vaccination

                      Appropriate procedure for exposure incidents

                      Appropriate reporting procedures

                      Opportunities to have my questions answered by the instructor


    Name of instructor conducting training:

    Qualifications of instructor conducting the training: _____________________________ Appendix B



    PROPER HAND WASHING TECHNIQUE: Hand washing is the single most important technique for preventing the spread of infectious diseases.

    When to wash your hands:

                      Wash your hands when they are dirty.

                      Before you prepare food to eat.

                      After touching raw meat like chicken or steak.

                      Before you eat.

                      After you use the restroom

                      After you change a diaper or assist someone with personal hygiene.

                      Before and after you care for someone who is sick or injured.

                      After touching animals, such as dogs and cats.



    1                 Wet hand with running water.

    2                 Apply soap and lather well. Liquid soap is preferred.

    3                 Wash hands, using a circular motion and friction for 15-30 seconds. Include the front and back surfaces of the hands, between the finger, and knuckles and around the nails and entire wrist. Wash under jewelry as well.

    4                 Ring the hands well under running water.

    5                 Dry the hands well with paper towels, turn off the water faucet with a paper towel and discard the towels.

    6                 Apply lotion as desired.


    Appendix C


    Guidelines for prevention of transmission of HIV and HBV to school system personnel

    Text Box: Task or Activity Disposable Gloves Protective Clothing Protective Mask Eyewear
Bleeding control with spurting blood YES YES YES YES
Bleeding control with minimal blood YES NO NO NO
Cleaning of athletic mats/area of blood YES NO NO NO
Cleaning of health room cots/stretchers YES NO NO NO
Preparing or using chemical dilutions for disinfectant use YES NO NO YES
Repairing sewage lines and plumbing equipment YES YES YES YES
Cleaning spills and surfaces containing contaminates YES NO NO NO
Disposing of garbage and waste materials YES NO NO NO
Assisting a student with blood glucose monitoring YES NO NO NO
Diapering YES NO NO NO
Oral /Nasal Suctioning YES NO NO YES
Procedures specific to school nursing position YES YES* YES* YES


    *Procedures specific to school nursing including but not limited to gastrostomy tube feedings and care, tracheotomy care, catheter care, injections, blood glucose monitoring require the use of PPE as determined by the professional nurse in accordance with OSHA guideline and best practice standards in the medical/nursing environment.



    Hand washing is essential to prevention and is not replaced by the use of gloves.

    Gloves help prevent the transmission of germs from one person to another.

    Gloves may be worn to protect the wearer or they may be worn to protect others from the wearer. For example, gloves may be worn to protect the wearer when assisting a person with a bloody nose. However, food preparers wearing gloves protect the public from the wearer.

    If you wear contaminated gloves in public areas and touch things such as telephones, doors, drawer handles or elevator buttons, you put everyone at risk for infection.

    Gloves do not provide total protection, since defects may occur. The combination of gloves, followed by good hand washing upon removal, offers the most complete protection.

    To put on single-use disposable gloves:

                      Check gloves for tears.

                      Put gloves on so that they fit smoothly and are not too big or loose.


    • Avoid gloves once they are on to make sure there are no holes. To remove gloves: The outside of used gloves should be considered a health hazard. Avoid contacting any

    bare skin with the outside of used gloves.

                      Grasp the cuff area of one glove using other gloved hand.

                      Pull the glove off the hand, allowing it to turn inside out.

                      Grasp and contain the removed glove within the palm of the gloved hand.

                      Place the thumb of the un-gloved hand underneath the cuff (between skin and glove) of the gloved hand, and remove it by pulling inside out, over the first glove.

                      Both soiled glove surfaces are now contained inside the second glove.

                      Discard gloves immediately in a bio-hazard bag or as recommended.


    • After removing gloves, wash and dry hands thoroughly. Gloves must be changed:

                      Between each person touched.

                      When gloves are torn or develop a hole.

                      Upon completion of each task involving contamination with body fluids.


    Appendix E


    National Institute of Occupational Safety and Health (NIOSH) Alert

    Workers exposed to latex glove and other products containing natural rubber latex may develop allergic reactions such as skin rashes; hives; nasal, eye, or sinus symptoms; asthma; difficulty breathing; and (rarely) shock, DHHS, (NIOSH), Publication No 97-135 at http://www.cdc.gov/niosh/latex.html

    What Is Latex Allergy?

    It is an allergic reaction to products made from natural latex (NRL). It should never be confused with the more common irritant-type reactions that are caused by direct injury to the skin, as from frequent hand washing with detergents. Latex products contain native or endogenous substances such as proteins as well as added processing chemicals. A person can be allergic to the proteins, the focus of this fact sheet, or the chemicals.

    Who Is At Risk?

    People who are genetically susceptible to latex allergy, just as some people are genetically susceptible to developing hay fever, bee stings and peanut allergies, can become allergic after exposure to latex-containing products. People with a history of multiple allergies, such as hay fever, food allergy, asthma and eczema also can develop latex allergy. Most people who encounter latex products only through their general use in society have no health problems from the use of these products. According to scientific literature, the major risk groups are:

                      Children with spina bifida and other congenital (at-birth) abnormalities. It is thought that since these children undergo many medical procedures to correct their medical problems, they are exposed more frequently to products containing NRL. It is not known if other genetic factors related to their conditions predispose them to latex allergy.

                      Workers who are genetically predisposed to latex allergy. To protect themselves from exposure to life-threatening blood borne diseases, this group frequently uses and continuously changes NRL gloves as required by OSHA.

                      People with conditions that require the frequent use of indwelling catheters or other rubber devices.

                      People with a history of allergies such as rhinitis, asthma or food allergies with a positive skin test.


    In identifying those who are at higher risk to react to latex, consideration should be given to:

                      Health history of allergies

                      Hives under gloves

                      Hand dermatitis related to gloves with dry cracking skin, sores, bumps or itching

                      Allergic conjunctivitis after rubbing eye with recently de-gloved hand

                      Swelling around mouth after dental procedure or blowing up a balloon

                      Vaginal burning after a pelvic exam or contact with a condom

                      History of occupational asthma where increased latex exposure may be the culprit


    If latex allergy is suspected, the individual should contact his/her physician for further medical evaluation.

    Some Common Products Contain Latex

    Text Box: Medical Equipment & Supplies Office Supplies Household Items
Gloves Rubber bands Automobile tires
Blood pressure cuffs Erasers Balloons
Stethoscopes Dishwashing gloves
Intravenous tubing Expandable fabric (waistbands)
Syringes Shoe soles
Goggles Carpeting
Respirators Motorcycle and bicycle grips


    Appendix F


    1                 Name (employee or student):

    2                 Social Security Number: _________________________3. Date of incident:


    1                 Notification of parent/guardian (if student): YES___ NO___ Date: ________Time: Name and relationship of person notified:

    2                 Description of individual’s duties/activities during the exposure incident:

    3                 The route of exposure was:


    a. Needle stick with contaminated needle to (area of body involved) ______

    b. Piercing of skin with contaminated sharp to (area of body involved)________________________________________________________________

    c. Splashing/spraying of blood or other potentially infectious material to (area of body involved)

    d. Other:


    11. Describe the circumstances under which the incident occurred:


    8. Name of the source individual, if known: ____________________________________

    9. Can repetition of the incident be reduced or minimized by instituting a new engineering or work practice control? YES ___ NO ___

    10. If yes, describe the actions that should be taken in the future:

    11. Date this action was instituted and made part of the Exposure Control Plan:


    Note: Maintain this record for duration of employment or attendance, PLUS 30 YEARS.

    Appendix G



    Hepatitis B Vaccination is indicated for this employee. YES ___ NO ___

    If yes, indicate if employee has previously received or is currently receiving vaccination series. Dates Received

    (_____________________,______________________,_________________) If vaccine declined by individual, indicate date _________________________________.

    Enter date completed:

    _______________Employee has been informed of the results of the post-exposure evaluation.

    _______________Employee has been told about medical conditions, if any, resulting from the exposure incident which may require additional evaluation or treatment.

    Text Box: ____________________________________
Employee’s Signature
Employee’s Name (printed)
Signature of Physician
Physician’s Name (printed)

    Appendix H



    Centers for Disease Control


    Medline Plus: The National Library of Medicine, a part of the National Institutes of Health, created and maintains MedlinePlus to assist you in locating authoritative health information


    Jefferson Department of Health